SS_1218-0224 (overhead gantry cranes) (12-21-10)-3

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS OF THE
OVERHEAD AND GANTRY CRANES STANDARD (29 CFR 1910.179) 1
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0224 (December 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.

The main objective of the Occupational Safety and Health Act of 1970 (i.e., “the Act”) is to
“assure so far as possible every working man and woman in the Nation safe and healthful
working conditions and to preserve our human resources” (29 U.S.C. 651). To achieve this
objective, the Act authorizes “the development and promulgation of occupational safety and
health standards” (29 U.S.C. 651).
Section 6(b)(7) of the Act specifies that “any standard promulgated under this subsection shall
prescribe the use of labels or other appropriate forms of warning as are necessary to insure that
workers are apprised of all hazards to which they are exposed, relevant symptoms and
appropriate emergency treatment, and proper conditions and precautions of safe use or
exposure.” This provision goes on to state that “[t]he Secretary, in consultation with the
Secretary of Health and Human Services, may by rule promulgated pursuant to section 553 of
title 5, United States Code, make appropriate modifications in the foregoing requirements
relating to the use of labels or other forms of warning . . . as may be warranted by experience,
information, or medical or technological developments acquired subsequent to the promulgation
of the relevant standard” (29 U.S.C. 655).
With regard to recordkeeping, the Act specifies that “[e]ach employer shall make, keep and
preserve, and make available to the Secretary . . . such records . . . as the Secretary . . . may
prescribe by regulation as necessary or appropriate for the enforcement of this Act . . . ” (29
U.S.C. 657). The Act states further that “[t]he Secretary . . . shall prescribe such rules and
regulations as [he/she] may deem necessary to carry out [his/her] responsibilities under this Act,
including rules and regulations dealing with the inspection of an employer’s establishment” (29
U.S.C. 657).
Under the authority granted by the Act, the Occupational Safety and Health Administration (i.e.,
“OSHA” or “the Agency”) published at 29 CFR 1910.179 a safety standard for general industry
regulating the operation of overhead and gantry cranes (i.e., “the Standard"). The paperwork
provisions of the Standard specify requirements for: Marking the rated load of cranes; preparing
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The purpose of this Supporting Statement is to analyze and describe the burden hours and cost 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, the Standard.

certification records to verify the inspection of the crane hooks, hoist chains, and rope; preparing
reports of rated load test for repaired hooks or modified cranes. Records and reports must be
maintained and disclosed upon request. Items 2 and 12 below describe in detail the specific
information collection requirements of the Standard.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection,
indicate the actual use the Agency has made of the information received from the current collection.

The Standard specifies several paperwork requirements. The following sections describe who
uses the information collected under each requirement, as well as how they use it. The purpose
of these requirements is to prevent death and serious injuries among workers by ensuring that all
critical components of the crane are inspected and tested on a periodic basis and that the crane is
not used to lift loads beyond its rated capacity.
(A) Marking the Rated Load (§§ 1910.179 (b)(3), (b)(5), and (k)(2))
Paragraph (b)(5) requires that the rated load be plainly marked on the side of each crane. If the
crane has more than one hoist, the rated load must be marked on each hoist or the load block.
The manufacturer will mark the rated loads. If the crane is modified, paragraph (b)(3) requires
the new rating to be determined and marked on the crane. Also, paragraph (k)(2) requires
employers to retain rated test load results and that the results are readily available to appointed
personnel. Marking the rated load capacity of a crane ensures that employers and workers will
not exceed the limits of the crane, which can result in crane failure.
(B) Inspection of and Certification Records for Hooks and Hoist Chains (§§ 1910.179
(j)(2)(iii), (j)(2)(iv), and (j)(4))
Paragraphs (j)(2)(iii) and (j)(2)(iv) require monthly inspections with certification records of
hooks and hoist chains. The certification must include the date of the inspection, the signature of
the person who performed the inspection, and the serial number, or other identifier, of the
inspected hook or hoist chain. Paragraph (j)(4) requires cranes that are not in regular use meet
the requirements of paragraph (j)(2). Paragraph (j)(4)(iii) specifically requires that standby
cranes be inspected semi-annually in accordance with paragraph (j)(2). Certification records
provide employers, workers, and OSHA compliance officers with assurance that the hooks and
hoist chains used on cranes regulated by the Standard have been inspected as required by the
Standard. These inspections help assure that the equipment is in good operating condition,
thereby preventing failure of the hooks or hoist chains during material handling. These records
also provide the most efficient means for the compliance officers to determine that an employer
is complying with the Standard.
(C) Repair and Testing of Defective Hooks (§§ 1910.179(l)(3) and (k)(2))
As required by paragraph (k)(2), employers must make readily available test reports of load
rating tests of repaired crane hooks conducted under paragraph (l)(3)(iii)(a). These reports
inform the employer, workers, and OSHA compliance officers that a rated load test was
performed, providing information about the capacity of the crane and the adequacy of the

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repaired hook. This information is used by crane operators so that they will not exceed the rated
load of the crane or hook.
(D) Inspection of and Certification Records for Ropes (§§ 1910.179 (m)(1) and (m)(2))
Paragraph (m)(1) requires employers to inspect thoroughly all running rope in use, and do so at
least once a month. In addition, rope which has been idle for at least a month must be inspected
before use, and a record prepared to certify that the inspection was done. The certification record
must include the inspection date, the signature of the person conducting the inspection, and the
identifier of the rope inspected. Employers must keep the certification records on file and
available for inspection. The certification records provide employers, workers, and OSHA
compliance officers with assurance that the ropes are in good condition.
In addition, paragraph (m)(2) requires that the employer thoroughly inspect all rope which has
been idle for period of a month or more. This inspection shall be for all types of deterioration
and shall be performed by an appointed person whose approval shall be required for further use
of the rope. A certification record shall be prepared and include the date of inspection; the
signature of the person who performed the inspection; and, an identifier for the rope which was
inspected.
(E) Disclosure of Inspection Certification Records
The disclosure of certification records provide the most efficient means for OSHA compliance
officers to determine that an employer is complying with the Standard.
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 informationcollection techniques, or other forms of information technology (e.g., electronic submission of
responses) when establishing and maintaining the required records. The Agency wrote the
paperwork requirements of the Standard in performance-oriented language (i.e., in terms of what
data to collect, not how to record the data).
4. Describe efforts to identify duplication. Show specifically why any similar information already available
cannot be used or modified for use for the purpose(s) described in 2 above.

The requirements to collect and maintain information are specific to each employer and worker
involved, and no other source or agency duplicates these requirements 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 the methods used
to reduce the burden.

The information collection requirements specified by the Standard do not have a significant
impact on a substantial number of small entities.

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6. Describe the consequence to Federal program or policy activities if the collection is or is not conducted
less frequently and any technical or legal obstacles to reducing the burden.

The Agency believes that the information collection frequencies required by the Standard are the
minimum frequencies necessary to effectively regulate overhead and gantry cranes, and thereby
fulfill its mandate “to assure so far as possible every working man and woman in the nation safe
and healthful working conditions and to preserve our human resources” as specified in the Act at
29 U.S.C. 651. Accordingly, if employers do not perform the required information collections,
or delay in providing this information, workers may not have the information they need about the
lifting limits of the crane or the condition of critical components, thus potentially increasing the
risk of death and serious injury to workers.
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, grantin-aid, or tax records for more than three years;

•

In connection with a statistical survey that is not designed to produce valid and reliable results
that can be generalized to the universe of study;

•

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

•

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

•

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
confidentially to the extent permitted by law.

No special circumstances exist that require employers to collect information using the procedures
specified by this item. The requirements are within the guidelines set forth in 5 CFR 1320.5.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register
of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection before
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
burdens.
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, revealed, or reported.

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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 mitigate against 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 July 28, 2010 (75 FR 44288) requesting comments
from the public and other interested parties on the information collection requirements contained
in the Standard on Overhead and Gantry Cranes (29 CFR 1910.179). The notice was part of a
preclearance consultation program that provided interested parties with an opportunity to
comment on OSHA’s request for an extension by the Office of Management and Budget of a
previous approval of the information collection requirements found in the above standard. The
Agency did not receive any comments in response to this notice.
9. Explain any decision to provide any payments or gift to respondents, other than reenumeration of
contractors or grantees.

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

The paperwork requirements specified by the Standard do not involve 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
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.

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

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

•

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

•

Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage-rate categories.

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Burden-Hour and Cost Determinations
According to the Preliminary Economic Analysis for the Proposed Rule on Cranes and Derricks
for Construction (73 FR 59713), there are 34,994 cranes operating in the general industry sector
annually and at most, 90% (31,495) of the cranes are overhead and gantry cranes. Based on staff
expertise, OSHA estimates that approximately 85% (26,771) of these cranes are in full-time
service (i.e., used more than once a month) and the remaining 15% (4,724) are cranes in the
category of idle or standby (i.e., not in use for more than one month or more at a time).
The Agency used wage rates of $24.90 for a crane and tower operator and $31.12 for a
supervisory crane and tower operator in determining the cost of the paperwork requirements
specified by the Standard. For the relevant occupational categories, OSHA adjusted the mean
hourly earnings from the September 2009 National Compensation Survey by the Bureau of
Labor Statistics to allow for fringe benefits, which comprise about 29.2 percent of total
compensation in the private sector. With wages comprising 70.6 percent of employee
compensation, the Agency multiplied wages by 1.4 (1/0.706) to derive total hourly employee
compensation. Therefore, the costs of labor used in this analysis are estimates of total hourly
compensation.
$24.90 for a Crane and Tower Operator
$31.12 for a Supervisory Crane and Tower Operator
(A) Marking the Rated Load (§§ 1910.179(b)(3), (b)(5), and (k)(2))
Crane manufacturers mark the rated load on cranes as required by paragraph (b)(5) of the
Standard as a usual and customary business practice. However, there are cases where an
employer modifies a crane. In those situations, paragraph (b)(3) of the Standard requires that the
new rating be determined and the new rated load posted. The new rated load information would
be obtained and posted after engineering calculations are performed and various tests are
conducted. It is estimated that the entire activity would take a crane operator about 2 hours,
including obtaining the information and marking it on the crane and hoist as required by the
Standard. The 2 hours also includes the time for an operator to place the test report on file where
it is readily available to appointed personnel in accordance with §1910.179(k)(2). OSHA
estimates that very few, if any; cranes are modified each year; no more than .1% (31).
Therefore, the total annual burden hour and cost estimates for these paperwork requirements are:
Burden hours:
Cost:

31 cranes x 2 hours = 62
62 hours x $24.90 = $1,544

(B) Inspection of and Certification Records for Hooks and Hoist Chains (§§ 1910.179
(j)(2)(iii), (j)(2)(iv), and (j)(4))
Employers must perform monthly inspections of the hooks and hoist chains on the 26,771
overhead and gantry cranes in full-time service. Cranes that have been idle are also subject to
inspection either before being put into service or at least every six months so that they are always
standing by, ready for activation. For the purpose of calculating the burden associated with the

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inspection records, OSHA assumes that when one crane is put into service, another becomes idle,
so that at any time during the year, all 26,771 cranes are subject to either a monthly inspection;
or are being inspected prior to being placed in service; or are being inspected semi-annually
because they have been idle for 6 months or more. OSHA assumes that a crane operator takes
approximately 30 minutes (.50 hour) to conduct the monthly inspection of the hooks, hoist
chains, and ropes and to develop and maintain a certification record of the inspection. Therefore,
the total annual burden hour and cost estimates for this paperwork requirement are:
Burden hours:
Cost:

26,771 inspections x 12 (monthly) x .50 hour = 160,626
160,626 hours x $24.90 = $3,999,587

(C) Repair and Testing of Defective Hooks (§ 1910.179(l)(3) and (k)(2))
Paragraph (l)(3)(iii)(a) states that crane hooks showing defects described in paragraph (j)(2)(iii)
of this section shall be discarded. Repairs by welding or reshaping are not generally
recommended. If such repairs are attempted they shall only be done under competent
supervision and the hook shall be tested to the load requirements of paragraph (k)(2) of this
section before further use. Paragraph (k)(2) requires that a copy of the test reports from rated
load test be placed on file and available to appointed personnel.
Such tests are required when repairs to hooks are made by welding or reshaping ((l)(3)(iii)(a)).
OSHA believes the number of hooks being tested would be few, given that the standard
discourages repairing and testing hooks and, in general, it is more cost effective to replace the
hook. The Agency believes the number of hooks being tested would be fewer than the number
of cranes; however, for calculating burden hours and cost the Agency, assumes no more than .1%
of the hooks on the 31,495 cranes (31) would be tested.
The test would be conducted by either a crane operator or engineer. OSHA estimates it will take
about 1 hour to conduct the test and prepare and maintain the report. Note that the Standard does
not specify what information must be included in the report.
Burden hours:
Cost:

31 cranes x 1 hour = 31
31 hours x $ 24.90 = $772

(D) Inspection of and Certification Records for Ropes (§ 1910.179 (m))
Paragraph (m)(1) requires employers to inspect thoroughly all running rope in use, and to do so
at least once a month. In addition, rope which has been idle for at least a month must be
inspected before use, as prescribed by paragraph (m)(2), and a record prepared to certify that the
inspection was done. The certification records must include the inspection date, the signature of
the person conducting the inspection, and the identifier of the rope inspected. Employers must
keep the certification records on file and available for inspection. The certification records
provide employers, workers, and OSHA compliance officers with assurance that the ropes are in
good condition. OSHA assumes that a crane operator takes 30 minutes (.50 hour) to inspect the
rope and to develop and maintain a certification record of each inspection. The assumptions

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discussed in (B) above regarding the number of cranes in use and those idle are used here,
resulting in total annual burden hour and cost estimates of:
Burden hours:
Cost:

26,771 cranes x 12 monthly inspections x .50 hour = 160,626
160,626 hours x $24.90 = $3,999,587

(E) Disclosure of Inspection Certification Records
OSHA believes that approximately 441 cranes covered by the Standard 2 will be subject to an
OSHA inspection and the employer will be required to disclose certification records annually
(see Item 14 below). OSHA estimates that it will take a supervisory crane operator 5 minutes
(.08 hour) to gather and disclose the requested information.
Burden hours:
Cost:

441 inspections x .08 hour = 35
35 burden hours x $31.12 = $1,089

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.

Item 12 above provides the total cost of the information collection requirements specified by the
Standard.
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), any other expense that would not have been incurred
2

The Agency estimated the number of inspections by determining the inspection rate (1.4%) for all cranes
under the jurisdiction of the Act (including both Federal OSHA and approved state-plan agencies), and then
multiplying the total number of cranes regulated under the Standard (i.e., 31,495 by this percentage (i.e., 31,495
cranes x 1.4% = 441 cranes inspected). Note: This determination assumes one crane per employer.

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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 $37.37 3 ,
spends about five minutes (.08 hour) during an inspection reviewing the documents required by
the Standard. The Agency has determined that its compliance officers will inspect about 441
employers who use cranes regulated by the Standard during each year covered by this ICR (see
footnote 2). 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:
Cost: 441 inspections x .08 hour x $37.37 = $1,318
15. Explain the reasons for any program changes or adjustments.

The Agency is requesting an adjustment decrease of 38,764 hours, from 360,144 to 321,380.
The decrease is a result of new information showing that there are 31,495 overhead and gantry
cranes in use, down from the previously estimated 35,000. Table 1 below describes each of the
requested burden hours.
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 information, completion of report,
publication dates, and other actions.

OSHA will not publish the information collected under the Standard.
17. If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be appropriate.

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

OSHA is not seeking an exception to the certification statement in ROCIS.

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SOURCE: U.S. Office of Personnel Management, General Schedule and Locality Tables, Salary Table
2010-RUS, http://www.opm.gov/oca/10tables/pdf/rus_h.pdf.

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B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This Supporting Statement does not contain any collection of information requirements that
employ statistical methods.

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Table 1: Requested Burden Hours and Adjustments

Information Collection
Requirements
(A)

Marking the Rated Load ((§§

Requested
Burden
Hours
62

Current
Burden
Hours

Adjustment

Cost Under
Item 12

Responses

70

-8

$1,544

31

1910.179(b)(3), (b)(5), and (k)(2))
(B)

Inspection of and Certification
Records for Hooks and Hoist Chains
(§§ 1910.179 (j)(2)(iii), (j)(2)(iv), and
(j)(4))
Repair and Testing of Defective
Hooks (§ 1910.179(l)(3) and (k)(2))

160,626

180,000

-19,374

$3,999,587

321,252

31

35

-4

$772

31

(D)

Inspection of and Certification
Records for Ropes (§ 1910.179 (m))

160,626

180,000

-19,374

$3,999,587

321,252

(E)

Disclosure of Inspection Certification
Records

35

39

-4

$1,089

441

321,380

360,144

-38,764

$8,002,579

643,007

(C)

Totals

Explanation for Adjustment

New data showed a drop in the number of
cranes as previously estimated from 35,000 to
31,495.
New data showed a drop in the number of
cranes as previously estimated from 35,000 to
31,495.
New data showed a drop in the number of
cranes as previously estimated from 35,000 to
31,495.
New data showed a drop in the number of
cranes as previously estimated from 35,000 to
31,495.
A decrease in the number of cranes relates to a
decrease in the number of inspections.