Narrative for Changes to Employment Standards Supporting Statement

Table of Changes for PRA for Employment Standards

Question #2-

The third sentence was changed.

2006 – “TSA civil aviation inspectors…”

2009 – “TSA Transportation Security Inspectors”

Reason – the title of the position changed.

Question #6-

The second sentence was inadvertently changed.

2006 – “…the TSA inspection process.”

2009 – “the inspection process.”

Reason – I inadvertently dropped “TSA” from the sentence.

Question #8-

The Federal Register information in the second sentence needed to be filled in.

2006 – “…Federal Register (70 FR 74838, December 16, 2005);…”

2009 – “…Federal Register (insert FR# and date of notice);…”

Reason – the information was not available at the time.

Question #10-

Language added to the sentence.

2006 – “49 CFR 1542.209(k)(4) and 1544.229(k)(3) require…”

2009 - “49 CFR 1542.209(k)(4) and 1544.229(k)(3) and a related Security Directive require…”

Reason – additional security requirement was mandated through a TSA Security Directive.

Question #13-

Change in requirement for information inclusion.

2006 – Annual recordkeeping cost estimate: $4,472,041 (183,506 x $24.37)

2009 – “There are no There are no industry costs estimated, beyond the hourly burden, for this collection.”

Reason –This information is no longer required.

Question #14-

Change in numeric values.

2006 – “The rule requires TSA to verify the information collected by the 1405 respondents as outlined above. Verification is estimated to take 3 hours per respondent at $40.39 per hour. Thus the annual cost to the Federal government is estimated to be $170,243.85.”

2009 – “Number of respondents: 1,321

TSA Verification per respondent: 3.5 hours

Average TSI hourly loaded wage rate: $51.05

Annual cost to Federal Government: $202,325”

Reason – The number of respondents changed, the hourly rate of the employees changed, and the level of security requirements increased.

Question #15-

Explanation of Adjustments.

2006 – “Adjustments reported in Items 13 and 14 of OMB Form 83-I are due to increases in the number of airport operators under Part 1542 and aircraft operators under Part 1544 since 2002. Additionally, the average cost per hour for recordkeeping for each respondent increased almost $3.00, which also accounts for the higher cost burden.”

2009 – “The cost burden reported in Item 13 has been removed because the hourly burden is already captured in item 12.”

Reason – self-explanatory