Supporting Statement OTIEC and Outreach (04-02-2010)

Supporting Statement for the Information-Collection Requirements of the
OSHA Outreach Training Program
and
OSHA Training Institute Education Centers Program Data Collection
OMB Control No. 1218 –0NEW (March 2010)
A.

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.
Section 21 of the Occupational Safety and Health Act of 1970 (the “OSH Act”)
(29 U.S.C. 670) (Attachment A) authorizes the Occupational Safety and Health
Administration (“OSHA” or the “Agency”) to conduct directly, or through grants
and contracts, education and training courses. These courses must ensure an
adequate number of qualified personnel to fulfill the purpose of the Act, provide
them with short-term training, inform them of the importance and proper use of
safety and health equipment, and train employers and employees to recognize,
avoid, and prevent unsafe and unhealthful working conditions.
Consistent with the authority of Section 21 of the OSH Act, the Agency created
two educational programs, the OSHA Outreach Training Program and the OSHA
Training Institute Education (OTI) Centers Program.
In 1971, the OSHA Outreach Training Program was established to rapidly
disseminate basic safety and health information to workers. Today, the Outreach
Training provides awareness training to workers on the recognition, control and
prevention of occupational safety and health hazards. Trainers who successfully
complete an OSHA trainer course are authorized to conduct 10- and 30-hour
outreach training courses on occupational safety hazards. This is a voluntary
program. Students who complete these outreach courses receive a course
completion cards from OSHA.
During the 1980s, the number of requests for training from private sector
personnel and Federal personnel from agencies other than OSHA increased
substantially and the demand eventually exceeded the capacity of the OSHA
Training Institute (OTI). To meet the increased demand, in October 1992, the
OSHA Training Institute Education Centers Program was created when OSHA
began partnering with nonprofit organizations and other training and educational
institutions to conduct OSHA Training Institute courses for private sector
personal and federal personnel from agencies other than OSHA. These approved
centers are referred to as the OSHA Training Institute Education Centers or “OTI
Education Centers.”

Subsequently, additional organizations were selected through a series of national
competitions. The program currently has 25 OTI Education Centers comprised of
44 member organizations.
The Directorate of Training and Education (DTE) is responsible for policy
guidance, management and administration of the OSHA Outreach Training
Program and the OTI Education Centers Program, among other programs. The
Directorate of Training and Education collects and reports student training
information on a monthly basis.
To be a participant in one of the educational programs, an individual/organization
must provide the DTE, Office of Training and Educational Programs (OTEP),
with certain information. Items 2 and 12 below list and describe the 13
information-collection requirements necessary for implementing OSHA’s OTI
Education Centers and Outreach Training Programs.
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.
A.

Title: Application to become an OSHA Training Institute Education
Center (OTI Education Center)
Information Collected: identifying data such as name; organization;
address; type of application and application organization; authority to
apply; evidence of nonprofit status; status as a training organization;
relevant occupational safety and health training experience; staff
qualifications; description of classroom facilities; ability to offer distance
learning; description of systems to administer OSHA Outreach Training
Program; copy of the applicant’s tuition and fee schedule; a description of
the applicant’s recruitment, marketing, and registration plans; a
description of the applicant’s accessibility of the training facility for
students and a description of lodging accommodation availability;
information concerning the organizations ability to provide off-site
courses; and copies of the organization's non-discrimination policies for
staff and students. (Attachment B, copy of Federal Register #72:3985139859, OSHA Training Institute Education Center; Notice of Competition
and Request for Applications.)
Purpose: To obtain basic information about the applicant organization and
application, to evaluate the qualifications of the applicants and their ability
to serve the regional population and to determine ability to conduct OSHA
courses for private sector personnel and federal personnel from agencies
other than OSHA. To evaluate the applicant organization’s competence to
provide the proposed training (including the qualifications of the
personnel to manage and implement the training).

Page 2

B.

Title: OTI Education Centers Monthly Summary Report for the OTI
Education Centers and Outreach Training Program Activities
B1. Information Collected for OTI Education Center Program: OTI
Education Centers must submit monthly information to the Directorate of
Training and Education (DTE), Office of Training and Educational
Programs, on the OTI Education Center’s activities including: course
numbers/titles, OTI Education Center name, dates and locations of
training courses (training location city, state, or country if outside the
U.S.), number of students trained, number of students attempting exams,
number of students passing exams, student contact hours, course
chairperson, instructor name(s), and demographic student breakdown
(Federal OSHA Personnel, Other Federal Agency Personnel, State OSHA
Personnel, Other State Personnel, Private Sector Personnel; U.S. Students,
or Foreign Students).
B2. Information Collected for the Outreach Training Program: OTI
Education Centers receive requests from Outreach Trainers for cards to
provide to their students who have successfully completed one of their
training courses (see item D, Outreach Training Program Report Forms).
With this information, the OTI Education Centers report monthly the
number of classes conducted and the number of students trained for each
outreach training program (Construction, General Industry, Maritime, and
Disaster Site Worker). OTI Education Centers receive their outreach
training card supply from the Directorate of Training and Education
(DTE), Office of Training and Educational Programs.
Purpose: Program management, oversight, and reporting. To monitor
training activity and evaluate training conducted versus established goals
and objectives of the Agency. Collection of data needed for the
submission of the annual workload summary. To monitor the
implementation of new performance measures; track performance
outcomes and efficiency measures; measure monthly, annual and longterm performance targets established for the programs and OSHA uses this
information to prepare annual reports to Congress.

C.

Title: “Statement of Compliance with Outreach Training Program
Requirements” (proposed) 1 /
Information Collected: Trainer signature, date, typed or printed name,
name of course and course dates (to be completed by OTI Education
Center), and name of OTI Education Center (to be completed by the OTI

1

/ OSHA believes the Statement of Compliance is not within the definition of “information” under 5 CFR
1320.3(h) (1). This Statement does not entail additional burden other than to identify the respondent, the date, and
the nature of the instrument (training course information).

Page 3

Education Center) (Attachment D, Statement of Compliance with
Outreach Training Program Requirements). 2 /
Purpose: Execution of the Statement of Compliance will serve as a self
certification of outreach trainer knowledge of and compliance with
program guidelines and to improve processing efficiency while
maintaining program integrity and deterring fraud.
D.

Title: Outreach Training Program Report Forms (includes
Construction, General Industry, Maritime and Disaster Site Worker)
Information Collected: trainer signature; the date the trainer signed the
report; type of course conducted (i.e., 10- or 30-hour construction; 10- or
30-hour general industry; 10- or 30-hour maritime; or disaster site
worker); course information (indicate whether course was offered in
Spanish, to Youth [age 18 or less], indicate the language if other than
English or Spanish, whether training was conducted outside the U.S.
and/or whether training conducted was related to an OSHA Alliance or
Partnership); training site; course duration – start and end times and dates,
number of students; first and last name of students; trainer identification
number (if applicable); trainer first and last name; trainer course number;
expiration date (of the trainer’s authorization); the following information
is requested to determine where student cards should be sent: 3 / company
name/department; address; city; state; zip; phone number; extension;
email; copy of trainer card; topic list and time spent on each required,
elective or optional topic.
Each outreach training program (i.e., the 10- and 30-hour construction,
10- and 30-hour general industry, 10- and 30-hour maritime, and disaster
site worker) has a set of required, elective, and optional course topics.
Because training topics covered and the length of time for each topic area
may vary, the Outreach Training Program Report must be completed
following each course conducted.
In order to maintain program integrity and deter fraud, outreach trainers
are required to maintain records which include student sign-in sheets,
student addresses, and a copy of the documentation sent in to request
cards, including a list of the topics taught and the amount of time spent on
each topic. (Attachment E, Outreach Training Report for Construction;
Attachment F, Outreach Training Report for General Industry;

2

/ Unless otherwise noted, the information requested would be provided by an authorized OSHA Outreach Trainer.
/ If the outreach trainer already has an ID number and the address where student cards should be sent has not
changed since the last request for students cards, the trainer may leave this section blank. The mailing address
information only needs to be completed the first time and at which time there has been a change of address since the
last submission.

3

Page 4

Attachment G, Outreach Training Report for Maritime, and Attachment H,
Outreach Training Program Report for Disaster Site Worker).
Purpose: To monitor training activity and evaluate training conducted
versus established goals and objectives of the Agency. These forms are
necessary to review compliance with the outreach training program
requirements and in order to get student completion cards to the trainer(s).
This information is also needed to improve processing efficiency while
maintaining program integrity and deterring fraud.
E.

Title: Online Outreach Training Program Report
Information Collected: Trainer identifying information, statement of
certification, student names, time each student spent online, final test
scores, evaluation summary and evaluation data.
Purpose: To monitor online training activity and evaluate training
conducted versus established goals and objectives of the Agency. This
document is necessary to review compliance with the requirements and in
order to get student completion cards to the trainer(s). OSHA has
recommended format for submission via U.S. mail (Attachment I, Online
Outreach Training Program Report).

F.

Title: Active Trainer List (proposed)
Information Collected: trainer name, city, state, company, phone number,
and email address.
Purpose: To maintain a list of authorized trainers who have conducted
more than two outreach training courses within the last twelve months.
These lists are provided to individuals who are searching for outreach
training courses available in their vicinity.

G.

Title: OSHA Training Institute Student Survey (OSHA Form 49 11-05
Edition) (proposed) (OMB 1225-0059) (Attachment J, OSHA Form 49
11-05 Edition).
Information Collected: Course number, course dates, instructor name, and
feedback from student concerning the course; (proposed additional
information will be requested: OSHA region, OTI Education Center
Name, and the city and state where the training was conducted).
Purpose: OSHA uses the information to evaluate the usefulness,
effectiveness, and content of the courses offered by the OTI Education
Centers.

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H.

Title: Attendance Documentation for OTI Education Centers
Information Collected: student first name, middle initial, and last name;
course name and number; date; city and state the course was conducted;
instructor name and signature, and the name of the OTI Education Center
who sponsored or conducted the training.
OSHA believes the daily training roster is not within the definition of
“information” under 5 CFR 1320.3(h) (1). The daily training roster does
not entail additional burden other than to identify the student, the date, and
the course name and signature of trainer. However, OSHA will take a
minimum burden for OTI Education Centers to provide this information to
OSHA during quarterly audits.
Purpose: Program management and oversight. To verify student
attendance as reflected in monthly summary reports.

I.

Title: Outreach Online Training Certification Statement
Information Collected: Online organization and type of outreach training
program and changes made since the last certification that their online
program was current.
Purpose: To ensure program is periodically reviewed and updated to
reflect current OSHA requirements.

J.

Title: Instructor and Staff Resumes (this includes anyone who may be
assigned to conduct OSHA classes, whether an online provider,
contractor, subcontractor, employee, adjunct professor, etc.)
Information Collected: This information is collected from the OTI
Education Centers and includes resumes of current staff and position
descriptions and minimum hiring qualifications for all positions, whether
filled or vacant, that may be assigned to conduct OSHA classes. Work
history, education, and other qualifications such as Certified Safety
Professional (CSP), Professional Engineer (PE), or Certified Safety
Hygienist (CIH).
Purpose: For program management and oversight and to obtain the
instructor knowledge and experience with OSHA standards and their
application to hazards and hazard abatement.

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K.

Title: Course Material Upon Request by OSHA from OTI Education
Centers
Information Collected: curriculum related content, manuals, test questions,
etc.
Purpose: To monitor the program content and ensure quality and
consistency. The materials are helpful in developing future curriculum
and meeting the needs of the Agency’s product/service users.

L.

Title: Course Schedules from OTI Education Centers (proposed)
Information Collected: Course title, description, registration hyperlink,
OSHA region, address of OTI Education Center, phone number for OTI
Education Center, web site address, class date, class time, class address,
and any additional class location information.
Purpose: To help workers find occupational safety and health training
offered by the OTI Education Centers.

3.

Describe whether, and to what extent, the collection of information involves
the use of automated, electronic, mechanical, or other technological collection
techniques or forms of information technology, e.g., permitting electronic
submission of responses, and the basis for the decision of adopting this means
of collection. Also describe any consideration of using information
technology to reduce burden.
OSHA has endeavored to make the collection of the above-referenced information
easy for program participants to complete and submit. Currently program
participants have the option to complete and submit the following data
electronically:
A. Application to become an OSHA Training Institute Education Center
(OTI Education Center)
B. OTI Education Center Monthly Summary Report for OTI Education
Centers and Outreach Training Program Activities
D. Outreach Training Program Report Forms (includes Construction,
General Industry, Maritime and Disaster Site Worker Outreach
Programs)
E. Online Outreach Training Program Report
F. Active Trainer Lists
I. Outreach Online Training Certification Statement
J. Instructor and Staff Resumes
K. Course Materials Upon Request by OSHA from OTI Education Centers
upon Requests

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Beginning with the FY 2010 reporting period, program participants will have the
option to complete and submit the following data electronically:
C. “Statement of Compliance with Outreach Training Program
Requirements”
L. Course Schedules from OTI Education Centers
Due to the nature of the material requested, currently program participants are
required to manually submit the following:
G. OSHA Training Institute Student Surveys
H. Attendance Documentation for OTI Education Centers
With regard to G, students must complete the OSHA Training Institute
Student Survey (OSHA Form 49 11-05 Edition) manually because it is not
available using advanced information technology and the collection is
made in a classroom setting or are mailed to participants who complete
training online. OSHA is continuing to explore electronic-information
techniques for use in the future.
With regard to H, OTI Education Centers submit copies of student
attendance documentation which includes multiple student signatures.
However, if the attendance documentation is scanned into .PDF format,
the OTI Education Centers may send documentation electronically to the
Agency.
Whenever possible, the Agency is making efforts to allow electronic submissions
in order to increase efficiency and consistency, and minimize the burden on
program participants.
4.

Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use of the
purposes described in Item 2 above.
This information is not available in any other manner. The paperwork
requirements of the documents listed above are specific to each student, trainer, or
OTI Education Center involved, and no other source or agency duplicates these
requirements or can make the required information available to OSHA.

5.

If the collection of information impacts small businesses or other small
entities (Item 5 of OMB Form 83-1), describe any methods used to minimize
burden.
The collection of this information does not have a significant economic impact on
small entities. The information provided to OSHA from the OTI Education
Centers and the Outreach Trainers imposes a minimal burden on the students,
trainers, and/or OTI Education Centers. When ever possible, the Agency is

Page 8

making efforts to allow electronic submissions in order to minimize the burden to
the program participants.
6.

Describe the consequences 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 burden.
Without this information the agency would be unable to determine the extent to
which OSHA’s overall training goals and objectives are met.
Additionally, the number of workers receiving safety and health training via the
OSHA Outreach Training Program may decline and the rate of accidents, injuries,
and even death will likely increase. Without the collection of the data,
monitoring, and reporting requirements, the Program may be subject to fraudulent
activity.

7.

Explain any special circumstance(s) that would cause information collection
to be conducted in a manner:
(1) requiring respondents to report information to the agency more often
than quarterly;
Data collected monthly from OTI Education Centers provide appropriate level of
program oversight and an opportunity to timely reconcile reporting discrepancies.
Trainer data collected as courses are delivered to verify course information and
ensure timely dissemination of student completion cards to course attendees.
Active trainer lists are required to ensure workers are informed where they can
obtain safety and health training. The Trainer Watch List is required to prevent
additional program misconduct, fraud, and/or abuse.
(2) requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it;
The Agency does not require respondents to prepare a written response to a
collection of information in fewer than 30 days after receipt.
(3) requiring respondents to submit more than an original and two copies of
any document;
There are no instances where the Agency requires the submission of an original
and two copies of any document.

Page 9

(4) requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records for more than three years;
OTI Education Centers record retention is based on the organizations’ policy.
Outreach Training Program records are retained by OSHA, the OTI Education
Centers, and the authorized trainers for five years to ensure the identification of
students and records associated with a trainer during the trainer’s authorization
period. This also ensures that students are able to obtain replacement cards when
they are lost or misplaced.
(5) 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;
Not applicable.
(6) requiring the use of a statistical data classification that has not been
reviewed and approved by OMB;
Not applicable.
(7) 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
Not applicable.
(8) requiring respondents to submit proprietary trade secrets, or other
confidential information unless the agency can demonstrate that it has
instituted procedures to protect the information’s confidentiality to the
extent permitted by law.
Not applicable.
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 these
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
instruction and record keeping, disclosure, or reporting format (if any), and
on the data elements to be recorded, disclosed, or reported.

Page 10

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 Federal Register notice on September 22, 2009 (74 FR 48293, Docket No.
OSHA-2009-0022) requesting public comment on the information collection
requirements contained in the Requirements for the OSHA Training Institute Education
Centers Program and OSHA's Outreach Training Program. This notice was part of a
preclearance consultation program intended to provide those interested parties the
opportunity to comment on OSHA’s request for Office of Management and Budget
(OMB) approval of the information collection requirements found in OSHA's. The
Agency received one comment from Mr. Parascos Pandelos (Document OSHA-20090022-0003).
Mr. Pandelos agreed with OSHA in that tracking outreach training is important. Mr.
Pandelos expressed concern that some authorized trainers are not providing sufficient
information and knowledge to their students and that tracking may increase
accountability. The OSHA Outreach Training Program is voluntary. However, because
OSHA outreach-related training is often becoming a requirement for gaining
employment, the Outreach Training Program has experienced some instances of
fraudulent activity. OSHA will continue to counteract instances of fraudulent activity
related to the program by adding control measures. OSHA also believes that establishing
routine reporting processes, requiring trainer compliance, and tracking training activities
will result in a product and system which will instill confidence within employers and
workers across the country. The required reporting of training content will address Mr.
Pandelos’s concerns.
9.

Explain any decision to provide any payment or gift to respondents, other
than remuneration 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, regulations, or agency policy.
The Agency provides no assurance of confidentiality regarding the information
that is collected from OTI Education Center applicants or data received from the
OTI Education Centers.
Participants understand that if approved to participate in the OSHA Training
Institute Education Center or the OSHA Outreach Training Program, their
application/information becomes public record. Information collected in the
application concerning financial disclosures remains confidential and are not
available to the public.

Page 11

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 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 information-collection requirements do not involve 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 and aggregate the hour burdens in
Item 13 of OMB Form 83-I.
Provide estimates of annualized cost to respondents of 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.
Summary of Burden Hours, Costs and Responses
Collection of Information requirement
A. Application to become an OSHA
Training Institute Education Center
(OTI Education Center)
B. OTI Education Centers Monthly Course
Summary Report (OSHA Form 4-50.8)
OTI Education Centers and Outreach
Training Program Activities (OSHA
Form 4-50.9)

Page 12

Burden
Hours

Costs

Responses

600

$18,192

10

1,200

$30,546

600

Burden
Hours

Costs

0

$0

0

9,151

$266,294

36,602

E. Outreach Reporting Required for Online
Trainers (OSHA From 4-50.5)

62

$1,804

365

F.

24

$698

300

G. OSHA Training Institute Student
Survey (OSHA Form 49 11-05 Edition)
(proposed) (OMB 1225-0059)

0

0

0

H. Attendance Documentation for OTI
Education Centers

3

$65

100

I.

Outreach Online Training Certification
Statement

10

$291

60

J.

Instructor and Staff Resumes

1

$29

25

K. Course Material Upon Requests by
OSHA from OTI Education Centers

75

$3,728

25

L. Course Schedules from OTI Education
Centers (proposed)

9

$262

50

11,135

$321,909

38,137

Collection of Information requirement
C. “Statement of Compliance with
Outreach Training Program
Requirements” (proposed)
D. Outreach Training Program Report
Forms:

Responses

Construction (OSHA Form 4-50.1)
General Industry (OSHA Form 4-50.2)
Maritime (OSHA Form 4-50.3)
Disaster Site Worker (OSHA Form 450.4)

Active Trainer List (proposed)

Totals

OSHA’s estimates of the burden hours and costs for each information-collection
requirement are calculated below. Costs and burden hours are rounded to total
dollar and hour amounts. The number of applications, OTI Education Centers,
and Outreach Trainers, and students trained are based on previous numbers
submitted or the most current data available at this time. In addition, the Agency

Page 13

uses the following wage rates in making the cost determination for the
Information Collection Requests: 4 /
ƒ
ƒ
ƒ
A.

Manager $43.71
Employee: $29.10
Clerical:
$21.81
Title: Application to become an OSHA Training Institute Education
Center (OTI Education Center).
OSHA publishes a notice announcing the opportunity for interested
nonprofit organizations to become an OTI Education Center. In 2002, the
Agency received approximately 45 applications; and in 2007, the Agency
received approximately 50 applications. Given OSHA only publishes
notices approximately every five years, we have annualized the number of
application to 10 (45 + 50 = 95 / 2 = 47.5 / 5 years = 9.5).

Number of
Responses
(# of OTI
Education
Centers)

Frequency of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

10

1 time

10 hours

100 hours

$4,371

10

1 time

40 hours

400 hours

10

1 time

10 hours

100 hours

$43.71
(manager)
$29.10
(employee)
$21.81
(clerical)

Totals
B.

600 hours

$11,640
$2,181
$18,192

Title: OTI Education Center Monthly Summary Report for the OTI
Education Centers and Outreach Training Program Activities.
B1. OSHA Training Institute Education Centers Reporting
(OSHA Form 4-50.8):
OTI Education Centers must submit monthly information to the
Directorate of Training and Education (DTE), Office of Training and
Educational Programs, including: course numbers/titles, OTI Education
Center name, dates and locations of training courses (training location
city, state, or country if outside the U.S.), number of students trained,
number of students attempting exams, number of students passing exams,

4

/ These hourly wage rates have been derived from the May 2007 National Industry-Specific Occupational
Employment and Wage Estimates published by the Bureau of Labor and Statistics. These wages have been adjusted
to reflect the fact that fringe benefits comprise roughly 29.3 percent of total employee compensation in the private
sector. The costs of labor used in this analysis are therefore estimates of total hourly compensation.

Page 14

student contact hours, course chairperson, instructor names, and
demographic student breakdown (Federal OSHA Personnel, Other Federal
Agency Personnel, State OSHA Personnel, Other State Personnel, Private
Sector Personnel; U.S. Students, or Foreign Students).
Based on the wage rates referenced above, each OTI Education Center
expends approximately two hours per month preparing and submitting a
monthly summary report. One hour is allocated by a general employee
earning $29.10 per hour and the other hour is allocated towards the
preparation of the monthly summary report by clerical staff earning
approximately $21.81.
Number of
Responses
(# of OTI
Education
Centers)

Frequency of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

25

Monthly

1 hour

300

$8,730

25

Monthly

1 hour

300

$29.10
(employee)
$21.81
(clerical)

Totals

600

$6,543
$15,273

B2. OSHA Outreach Training Program Reporting (OSHA Form 4-50.9):
OTI Education Centers collect outreach trainer data (see item D, Outreach
Training Program Reports) and process these requests. Each month, they
report the number of classes and the number of students in each type of
outreach training that they processed during the month. Trainer requests
for student cards are processed by the OTI Education Center where the
Trainer received training. OTI Education Centers receive their outreach
training card supply from the Directorate of Training and Education
(DTE), Office of Training and Educational Programs.
Number of
Responses
(# of OTI
Education
Centers)

Frequency
of Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

25

Monthly

1 hour

300

$29.10
(employee)

$8,730

25

Monthly

1 hour

300

$21.81
(clerical)

$6,543

Totals

600

Page 15

$15,273

C.

Title: “Statement of Compliance with Outreach Training Program
Requirements” (proposed)
OTI Education Centers are the primary administrators of the OSHA
Outreach Training Program. As a heightened measure to address concerns
regarding outreach trainer misconduct or fraudulent activity with the
Outreach Training Program, OSHA is asking each OTI Education Center
to gather a Statement of Compliance for each student who completes any
of the train-the-trainer courses. 5 / At the end of each trainer course, the
OTI Education Centers will have each student sign and return the
Statement of Compliance to the OTI Education Center and the OTI
Education Center will retain the Statement of Compliance as part of the
outreach trainer’s permanent file.
OSHA believes the Statement of Compliance is not within the definition
of “information” under 5 CFR 1320.3(h)(1). This Statement does not
entail additional burden other than that necessary to identify the
respondent, the date and the nature of the instruction (training course
information). Therefore, the Agency has provided no burden hours as the
Statement of Compliance is not within the definition of “information”
and/or generally includes customary and usual business practices.

D.

Title: Outreach Training Program Report Forms (includes
Construction (OSHA Form 4-50.1), General Industry (OSHA Form 4-50.2),
Maritime (OSHA Form 4-50.3) and Disaster Site Worker (OSHA Form
4-50.4 Outreach Programs)
Upon completion of each outreach course, the trainer must submit
information as stated under Item 2, B2. OSHA estimates that for each
course the trainer will take 15 minutes (.25 hour) to obtain, document and
submit the required information. The number of courses has been
averaged over a three year period, 2006 through 2008. For purposes of
estimating courses, the Agency estimates that an Outreach Trainer earns
approximately $29.10 per hour:
Estimated
Number of
Courses

Frequency of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

36,602

After each
outreach
course

.25 hour

9,151

$29.10
(employee)

$266,294

5

/ The train-the-trainer courses currently include the following: #500 - Trainer Course in Occupational Safety and
Health Standards for the Construction Industry; #501 - Trainer Course in Occupational Safety and Health Standards
for General Industry; #502 - Update for Construction Industry Outreach Trainers; and #503 - Update for General
Industry Outreach Trainers; #5400 - Trainer Course in OSHA Standards for the Maritime Industry; #5600 - Disaster
Site Worker Train-the-Trainer Course; and #5602 - Update for Disaster Site Worker Trainer Course.

Page 16

E.

Title: Outreach Reporting Required for Online Trainers (OSHA 4-50.5)
Upon completion of each online outreach course, the online provider must
collect information as stated under Item 2, E above. Depending on the
number of online programs offered, the online providers provide a report,
no more than twice a month, to the Directorate of Training and Education,
Office of Training and Educational Programs. OSHA estimates the
number of reports received per year at 365 and that for each course the
online provider conducts, it will take approximately 10 minutes (.17 hour)
to obtain, document and submit the required information. For purposes of
estimating courses, the agency estimates that a Trainer earns $29.10 per
hour:

F.

Estimated
Total
Number of
Reports per
year
(averaged)

Frequency of
Response
Varies

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

365

1

.17 hour

62

$29.10
(employee)

$1,804

Title: Active Trainer List (proposed)
The OTI Education Center collects information concerning outreach
trainers who have conducted two or more courses per year. Since this
information is readily available (Necessary information is being provided
when Trainers request student cards for their students), OSHA assumes
that it will take approximately 5 minutes (.08 hour) per month for the OTI
Education Centers to prepare and submit this report electronically.

G.

Estimated
Number
of
Responses
(per year)

Frequency
of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

25

Monthly

.08 hour

24

$29.10
(employee)

$698

Title: OSHA Training Institute Student Survey (OSHA Form 49 11-05
Edition) (proposed) (OMB 1225-0059)

The OSHA Directorate of Training and Education (DTE) conducts courses
on occupational safety and health provided through the OSHA Training
Institute (OTI) and the OTI Education Centers Program.

Page 17

Since the OTI Education Centers Program currently includes 25 OTI
Education Centers around the country, DTE would like to modify the
current OSHA Training Institute Student Survey to include the OSHA
Region, the identity of the OTI Education Center, the city and state where
the training was conducted.
The information on this survey is obtained from students upon completion
of training by the OTI Education Centers. OSHA uses this information to
evaluate the usefulness and effectiveness of the course content and
instruction.
Training classes vary in the type of delivery (instructor led classroom
training, computer-based training, and blended). Some parts of the survey
may not apply to some classes. Students answer each question on the
Course Evaluation form by filling in the box that corresponds to their
rating for that course element. Each box has a numeric value that is
processed by computer for tabulation of the data. The forms are processed
through an optical reader linked to a personal computer. The computer
automatically tabulates the rating scores for each Student Survey form and
an overall score for the course
The burden hours are not included in this PRA since the burden hours are
being captured in another OMB Approval Process for No. 1225-0059.
H.

Title: Attendance Documentation for OTI Education Centers
The Agency requires the OTI Education Centers to collect daily student
sign-in sheets for each course conducted; however, the Agency only
requests this information during random audits on a quarterly basis.
For reporting purposes, an attendance roster is created with the printed
name of the students registered for each OTI numbered course.
Each student is required to sign their name next to their printed name.
OSHA requires the OTI Education Centers keep an attendance roster for
each day the course is offered. OSHA also requires the instructor to sign
the attendance roster to certify the attendance documentation is accurate.
Since all OTI Education Centers have electronic registration, the printed
name of registered students is readily available.
OSHA believes the daily training roster is not within the definition of
“information” under 5 CFR 1320.3(h) (1). The daily training roster does
not entail additional burden other than to identify the student, the date, and
the course name and signature of trainer. However, OSHA will take a
minimum burden for OTI Education Centers to provide this information to
OSHA during quarterly audits.

Page 18

OSHA assumes that it will take approximately 3 minutes (.05 hour) for the
OTI Education Centers to provide the daily student training roster to
OSHA.

I.

Estimated
Number of
Education
Centers
(per year)

Frequency of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per
hour

Estimated
Annualized
Costs

25

Quarterly

.03 hour

3

$21.81
(clerical)

$65

Title: Outreach Online Training Certification Statement
At a minimum, an Outreach Online Training provider must provide to the
Directorate of Training and Education a bi-annual report (essentially a
negative report) or must immediately report any significant changes made
to an Outreach Online Training Program. The Outreach Online Training
provider is required to sign a statement of certification that the online
OSHA training courses have been conducted in accordance with the
current OSHA Outreach Training Program Guidelines and document in
detail any changes made. If no changes are implemented, the Outreach
Online Program provider must provide the Directorate of Training and
Education a negative report.
OSHA currently has 30 accepted online Outreach Training programs.
OSHA estimates the average organization will take 10 minutes (.17 hour)
per accepted program to obtain, document, and submit the required
information. For purposes of estimating courses, the agency estimates that
a Trainer earns $29.10 per hour:

J.

Estimated
Number of
Programs
(per year)

Frequency of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

30

2 x per
year

.17 hour

10 hours

$29.10
(employee)

$291

Title: Instructor and Staff Resumes (this includes anyone who may be
assigned to conduct OSHA classes, whether an online provider,
contractor, subcontractor, employee, adjunct professor, etc.)
During the application process for new OTI Education Centers or as new
staff is hired or changes are made, the Agency requires the OTI Education
Centers to provide OSHA with a copy of the resume of the instructor
and/or their staff. The Agency encourages the submission of the resumes
in an electronic format (via email). Since it is likely that the OTI
Education Center receives the resumes electronically, OSHA estimates
Page 19

that it will take the OTI Education Center Director or their staff
approximately 3 minutes (.05 hour) to submit the required information.
For purposes of estimating courses, the agency estimates that an OTI
Education Center employee earns $29.10 per hour.

K.

Estimated
Number of
Instructors/Staff
personnel

Frequency of
Response

Estimated
Burden-Hours
per
Respondent

Estimated
Annual
Burden
Hours

Cost per hour

Estimated
Annualized
Costs

25

1 x or when
staff changes
are made

.05 hour

1

$29.10
(employee)

$29

Title: Course Material Upon Requests from OTI Education Centers
On an as-needed basis, the Directorate of Training and Education requests
the OSHA Training Institute Education Centers to provide curriculum
related content, manuals, test questions, etc. in order to monitor program
content and ensure quality and consistency. These materials are provided
to the Directorate of Training and Education, Office of Training and
Educational Programs.
Since most of the materials have already been created or are in existence,
the Agency calculates the burden by using 3 hours as the average yearly
total.

L.

Estimated
Number of
Responses
(per year)

Frequency of
Response

Estimated
BurdenHours per
Respondent

Estimated
Annual
Burden
Hours

Cost per
hour

Estimated
Annualized
Costs

25

Varies

3 hours

75

$43.71
(manager)

$3,728

Title: Course Schedules from OTI Education Centers (proposed)
This collection of this information is voluntary. Quarterly or as course
schedules are updated, the OTI Education Centers may provide
information for their upcoming courses.
OSHA estimates that each OTI Education Center will likely update their
course schedules a minimum of two times per year. Since course
schedules will already likely be available electronically, the Agency
estimates it will take 10 minutes (.17 hour) to obtain, document and
submit the course catalogue electronically to the computer server. For
purposes of estimating courses, the Agency estimates that an employee at
the OTI Education Center earns $29.10 per hour:

Page 20

13.

Estimated
Number of
Respondents

Frequency of
Response

Estimated
Burden-Hours
per
Respondent

Estimated
Annual
Burden Hours

Cost
per hour

Estimated
Annualized
Costs

25

2 x per year

.17 hour

9

$29.10

$262

Provide an estimate of the total annual cost burden to respondents or record
keepers 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 services 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
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 respondents (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 determined under Item 12 accounts for the total annual cost burden to
respondents or record keepers resulting from the collection of information
requirements.

14.

Provide estimates of 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

Page 21

have been incurred without this collection of information. Agencies may also
aggregate cost estimates from Items 12, 13, and 14 in a single table.
To determine the costs to the Federal Government, the Agency estimated how
much time the government spends on each information-collection requirement,
and then totaled the burden hours for all of the collection of information
requirements. (See Table below – Burden Hours for Federal Government).
OSHA estimates that 860 hours are spent on the collection of information
requirements contained in the OSHA Training Institute Education Center
Program, and the Outreach Training Program.
For each collection, several government employees at differing grades may be
involved in processing, analyzing, and if necessary preparing reports. The
Agency estimated the overall amount of time the government spends on each
collection of information, and then determined that a GS 12, step 5 ($40.14 )
represents the average wage rate for the government staff working on these
collections of information requirements.
The total cost to the Federal government is $34,520 (860 hours x $40.14 =
$34,520 (rounded).

Burden Hours for
Federal Government
Collection of Information
requirement

Action

Time per
Response

Total Hours

A. Application to become an OSHA
Training Institute Education
Center (OTI Education Center)
B. OTI Education Center Monthly
Summary Report, including
Outreach Reporting

Review 10
Applications

20 hours

200

1 hour

300

C. Statement of Compliance with
Outreach Training Program
Requirements” (proposed)

Not Applicable: These Requirements are
processed at the OTI Education Centers and
costs are assumed under Item 12.

Review Summary
Reports
(25 x 12 = 300)

D. Outreach Training Program
Report Forms (includes
Construction, General Industry,
Maritime and Disaster Site
Worker Outreach Programs)

Page 22

N/A

Collection of Information
requirement

Action

E. Outreach Reporting Required for
Online Trainers

Review and process
.33 hours
365 student
completion card
requests and report
same
Ensure receipt of
.08 hours
Active Trainer Lists
from 25 OTI
Education Centers;
file, compile and
send out Active
Trainer Lists as
requested by
potential students
(average requests
per month = 300.
(25 + 300 = 325)
Federal Costs taken under DOL’s Customer
Satisfaction Survey (1225-0059)

F. Active Trainer List (proposed)

G. OSHA Training Institute Student
Survey (OSHA Form 49 11-05
Edition) (proposed) (OMB 12250059)
H. Attendance Documentation for
OTI Education Centers

I.

Outreach Online Training
Certification Statement

J.

Instructor and Staff Resumes

L. Course Material Upon Requests
from OTI Education Centers

M. Course Schedules from OTI
Education Centers (proposed)

OSH Education
Centers – 100
requests for student
rosters
Analyze Online
Training
Certifications (25 x
2)
Review new
resumes/
approximately 25
Review new Course
materials
(25 Education
Centers)
Review 50 updated
course materials

TOTAL

15.

Time per
Response

Total Hours
120 hours

26 hours

N/A

1 hour to
analyze/compare to
monthly reports

100

.25 hour

13 (rounded)

.50 hour

13 (rounded)

1.5 hour

38

1 hour

50

860

Explain the reasons for any program changes or adjustments reported in
Items 13 or 14 of the OMB Form 83-I.
OSHA is requesting a program change increase of 11,135 hours. OSHA has
identified a set of collections of information necessary for operating the Agency’s
two educational programs, the OSHA Training Institute (OTI) Education Centers
Program and OSHA Outreach Training Program. The OTI Education Centers are
non-profit organizations that provide training at their location. The Outreach

Page 23

Training Program trains individuals who become authorized to train other
individuals. The trainers determine when and where training sessions will be held.
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
the report, publication dates, and other actions.
Not applicable.

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.
The expiration date will be displayed on the data collected.

18.

Explain each exception to the certification statement identified in Item 19,
“Certification for Paperwork Reduction Act Submissions,” of OMB
Form 83-I.
There are no exceptions to the certification statement.

B.

Collections of Information Employing Statistical Methods.
The agency should be prepared to justify its decision not to use statistical methods
in any case where such methods might reduce burden or improve accuracy of
results. When Item 17 on Form OMB 83-I is checked “Yes,” the following
documentation should be included in the Supporting Statement to the extent that it
applies to the methods proposed.
Item 17 on Form OMB 83-I is checked “No.”

Page 24