1625-0016
Supporting Statement
for
Welding and Hot Work Permits; Posting of Warning Signs
A. Justification
1) Circumstances that make the collection of information necessary.
A) To conduct welding, cutting or other hot work on a Liquefied Natural Gas (LNG) and Liquefied Hazardous Gas (LHG) facility, the approval of the Coast Guard Captain of the Port (COTP) is required per 33 CFR 127.617 and 127.1603. Upon determination that welding is safe, the Coast Guard COTP issues a permit allowing such activity. Hot work and welding have the capacity to cause fires and explosions that can lead to significant injuries and deaths, as well as structural damage. It is important that the COTP is informed about where hot work is being done and who is doing it. The permittee is required to supply the COTP with the following information:
(a) Description of the work;
(b) Location of the hot work in relation to dangerous cargo and/or vessel; and
(c) Expected duration of the activity.
B) Warning signs must be posted as required under 33 CFR 126.15(a)(3) on all designated Class I (Explosive) facilities. These signs should meet the requirements of the National Fire Protection Association (NFPA) 307.
This information collection supports the following strategic goals:
Protection
Safety
Protection of the Natural Resources
Prevention Policy & Response Policy Directorates (CG-5P & CG-5R)
Safety: Eliminate deaths, injuries, and property damage associated with commercial maritime operations.
Human and Natural Environment: Eliminate environmental damage associated with maritime transportation and operations on and around the nation’s waterways.
2) By whom, how, and for what purpose the information is to be used.
A) COTPs use this information to ensure compliance with minimum safety standards. The COTP issues permits to facility owners/operators and vessel officers. These permits are issued by most COTPs for up to one year for most terminals, and on a job by job basis for vessels. Terminals and vessels report their hot work or welding operations at least 24 hours before the hot work operations begin. The COTP boarding teams check these reports and design their patrols to check that all safety precautions per the permit are being enforced.
B) Posting of warning signs is expected to contribute to a higher level of marine safety on waterfront facilities.
3) Consideration of the use of improved information technology.
The information may be submitted in writing or electronically via e-mail. The information is submitted to the COTP using form CG-4201. The form is available at— http://www.uscg.mil/forms/cg/CG_4201.pdf. In most cases a phone call will suffice for renewal of the permit. Contact info for CG COTPs can be found at http://www.uscg.mil/top/units/.
We estimate that 80% of the reporting and recordkeeping requirements can be done electronically. At this time, we estimate that approximately 50% of these responses are collected electronically.
4) Efforts to identify duplication. Why similar information cannot be used.
There is no other similar Federal requirement known to exist.
5) Methods to minimize the burden to small business if involved.
This information collection does not have an impact on small businesses or other small entities.
6) Consequences to the Federal program if collection were conducted less frequently.
The COTP would not be able to effectively target these activities for safety oversight.
7) Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with guidelines.
This information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).
8) Consultation.
The USCG published a 60 Day FRN [USCG-2012-0472], (June 1, 2012, 77 FR 32657) seeking public comments. The USCG received no comments. USCG published a 30 Day FRN (September 4, 2012, 77 FR 53898). The USCG received no comments.
9) Explain any decision to provide any payment or gift to respondents.
There is no offer of monetary or material value for this information collection.
10) Describe any assurance of confidentiality provided to respondents.
There are no assurances of confidentiality provided to the respondents for this information collection.
11) Additional justification for any questions of a sensitive nature.
There are no questions of sensitive language.
12) Estimates of reporting and recordkeeping hour and cost burdens of the collection of information.
The annual number of respondents is 259.
The annual number of responses is 967.
The estimated annual hour burden is 546.
The estimated annual cost burden is $31,619.
Reporting
There are approximately 177 LNG and LHG facilities that must submit a request for welding or hot work permits. On average, each facility submits 5 applications per year, or a total of 885 applications for all facilities. It will take an average of approximately 0.25 hours of management time to prepare and review the information required for the permit. It will likewise take approximately 0.25 hours of clerical time to type this information. The estimated time involved to complete the paperwork is 0.50 hours per facility or a total of 443 hours1 annually for these respondents. Total annual cost to submit for permits is $26,329. Table 1 represents the annual cost to the public for submitting the application for a hot work permit.
Total
Reporting Burden Hours is 443 hours and the
Total Reporting
Cost to Respondents is $26,329.
Recordkeeping
A) It will take approximately 0.10 hours per permit to file the resulting paperwork at a wage cost of $50 (GS-09 rate). The annual recordkeeping burden is [0.10 hours X 885 permits] 89 hours2. The annual cost for recordkeeping is approximately $4,450. Table 1 represents the annual cost to the public for recordkeeping of the permits.
B) Title 33 CFR 126.15(a)(3) requires that on certain designated waterfront facilities, warning signs be installed in accordance with NFPA (National Fire Protection Association) 307, Chapter 7-8.7. The warning signs must be easily visible, not obstructed by cargo storage, and contain the words HAZARDOUS MATERIALS-NO SMOKING, in capital letters not less than 150 mm (6 in) in height.
According to Coast Guard Marine Information for Safety and Law Enforcement (MISLE) data, there are approximately 820 facilities that handle, store, and transfer packaged and bulk solid dangerous cargo that must post warning signs. We assume that all 820 designated waterfront facilities need to post 4 warning signs, and that the warning signs are replaced every ten years (approx. 82 facilities/year). The average time to comply with this requirement per facility is estimated as 0.25 hours. The total annual hour burden for these facilities, or respondents, is estimated to be 21 hours3 (82 facilities x 0.25 hours/facility). Estimating the hourly wage of the person who posts the signs on the facility at $40 (WG-05 rate), the cost to respondents is $840.
Total Recordkeeping Burden Hours is 103 hours [82 + 21] and the Total Recordkeeping Cost to Respondents $5,290 [$4,450 + $840].
TOTAL ANNUAL RESPONSES = 967 (885 permit applications + 82 facilities posting new warning signs)
TOTAL NUMBER OF RESPONDENTS = 259 (177 LNG and LHG facilities that must submit requests for welding and hot work permits + 82 waterfront facilities that handle, store, and transfer packaged and bulk solid dangerous cargo that must post warning signs).
TOTAL
REPORTING AND RECORDKEEPING BURDEN HOURS = 546
(443
+ 103)
TOTAL
REPORTING AND RECORDKEEPING COSTS = $31,619
($26,329
+ $5,290)
13) Estimates of annualized capital and start-up costs.
There are no capital, start-up or maintenance costs associated with this information collection.
14) Estimates of annualized Federal Government costs.
The burden hours for issuing permits equals 443 hours4 (885 x 0.5 hours).
It will take an average of approximately 0.25 hours of management time to prepare and review the information required for the permit. It will likewise take approximately 0.25 hours of clerical time to type this information. According to our data querying LHG facilities, there will be 885 requests for hot work permits. Hourly wages for the Coast Guard personnel utilize standard Coast Guard personnel rates in the COMDTINST 7310.1M, of $95 (O-5 rate) per hour, and $54 (E-6 rate) per hour. Total annual cost to process and review permits is $32,966. Table 2 represents the annual cost to the Federal Government for processing and reviewing hot work permit.
The burden hours with government recordkeeping equals 89 hours5 [177 recordkeeping X 0.5 hours]. The 0.5 hours are a result of 5 applications per respondent. Permits must be maintained for one year at the work site as well as at the local Coast Guard COTP Office. It will take approximately 0.10 hours per permit to file the resulting paperwork at a wage cost of $54. Total annual cost for recordkeeping is $4,806. Table 2 represents the recordkeeping costs to the Federal Government.
Total Hour burden to the Federal Government = 532 hours (443 + 89).
Total Cost to the Federal Government = $37,745.
15) Explain the reasons for the change in burden.
The change in the burden is an ADJUSTMENT. There is no proposed change to the reporting or recordkeeping requirements of this collection. The reporting and recordkeeping requirements, and the methodology for calculating burden, remain unchanged.
The following items listed below are changes to the collection:
Increase in burden (i.e., burden hours) is due to a increase in the facility population.
Updates are provided for cost burden associated with this collection of information.
The Coast Guard has updated printable instructions for this collection of information for clarity and to add expiration date of ICR.
16) For collections of information whose results are planned to be published for statistical use, outline plans for tabulation, statistical analysis and publication.
This information collection will not be published for statistical purposes.
17) Explain the reasons for seeking not to display the expiration date for OMB approval of the information collection.
The Coast Guard will display the expiration date for OMB approval of this information collection.
18) Explain each exception to the certification statement.
The Coast Guard does not request an exception to them certification of this information collection.
B. Collection of Information Employing Statistical Methods.
This information collection does not employ statistical methods.
TABLE 1
Cost of Application and Permit (to the Public)
Annual Costs to Submit for Permit
|
Rate/hr (a) |
Hours (b) |
Total Costs(a + b) |
Clerical Wage |
$50 (GS-09) |
.25 |
$12.50 |
Management Wage |
$69 (GS-12) |
.25 |
$17.25 |
Total Wage Rate |
|
|
$29.75 |
Number of issued permits (annually) = 885.
(1) Total Response (Annual Application) Costs = $12.50 x 885 + $17.25 x 885 = $26,329
Recordkeeping Cost
Clerical Wage $50
Time to file permit .10 (hours)
Clerical Cost per permit $5
Filing cost per permit $5
Permits filed annually 885
(2) Total Recordkeeping Cost = $4,425 [$5 X 885]
(1) + (2) = $30,754 Paperwork Cost to the Public
Cost of Posting Warning Signs
|
Rate/hr (a) |
Hours (b) |
Total Costs(a X b) |
Labor Wage |
$40 (WG-05) |
.25 |
$10 |
Total Wage Rate |
|
|
$10 |
(3)
Total cost for posting warning signs = $ 820
[82 X $ 10]
Total Cost of Collection
(1) + (2) + (3) = $31,574 [$26,329 + $4,425 + $820]
TABLE 2
Cost to the Federal Government
Cost to Process and Review Permits
|
Rate (a) |
Hours (b) |
Total Costs(a X b) |
Enlisted Wage |
$54 (E-6) |
.25 |
$13.50 |
Officer Wage |
$95 (O-5) |
.25 |
$23.75 |
Total Wage Rate per review |
|
|
$37.25 |
Cost per Review ($37.25) X Total Reviews (annually) 885 =
(1) Total Response (Annual Application) Costs = $32,966
Recordkeeping Cost
Enlisted Wage $54
Time to file permit .10 (hours)
Cost of recordkeeping $5.40
Cost of recordkeeping $5.40
Permits filed annually 885
(2) Total Recordkeeping Cost = $4,779 [$5.40 X 885]
(1) + (2) = $37,745 Paperwork Cost to the Federal Government
1 Rounded.
2 Rounded.
3 Rounded.
4 Rounded.
5 Rounded.
| File Type | application/msword |
| File Title | Supporting Statement |
| Author | Ryan Sonner |
| Last Modified By | KATyler |
| File Modified | 2013-01-07 |
| File Created | 2013-01-07 |