SS_1218-0223-Slings-(03-27-2015)

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Slings Standard (29 CFR 1910.184)

OMB: 1218-0223

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Department of Labor

Occupational Safety and Health Administration

Final Supporting Statement



SUPPORTING STATEMENT FOR

THE INFORMATION COLLECTION REQUIREMENTS OF

THE STANDARD ON SLINGS (29 CFR 1910.184)1

OFFICE OF MANAGEMENT AND BUDGET

(OMB) CONTROL NO. 1218-0223 (March 2015)



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 “[a]ny 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 1910.184 a safety standard for general industry regulating the use of slings (i.e., “the Standard"). The collection of information (paperwork) provisions of the Standard specify affixing identification tags or markings on slings, developing and maintaining inspection records, and retaining proof testing certificates. 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 collections of information (paperwork) requirements, depending on the type of sling. The purpose of each of these requirements is to prevent workers from using defective or deteriorated slings; thereby, reducing their risk of death or serious injury caused by sling failure during material handling.


Paragraph (e) of the Standard covers alloy steel chain slings.


Paragraph (e)(1) requires that alloy steel chain slings have permanently affixed and durable identification stating size, grade, rated capacity, and reach of the sling. The information, supplied by the manufacturer, is typically marked on a metal tag and affixed to the sling.


Paragraph (e)(3)(i) requires the employer to make a thorough periodic inspection of alloy steel chain slings in use on a regular basis, but at least once a year. Paragraph (e)(3)(ii) requires the employer to make and maintain a record of the most recent month in which each alloy steel chain sling was thoroughly inspected, and make this record available for examination.


Paragraph (e)(4) requires the employer to retain certificates of proof testing. Employers must ensure that before use, each new, repaired, or reconditioned alloy steel chain sling, including all welded components in the sling assembly, has been proof tested by the sling manufacturer or an equivalent entity. The certificates of proof testing must be retained by the employer and made available for examination.

Paragraph (f) of the Standard covers wire rope slings.


Paragraph (f)(1) requires employers to use only wire-rope slings that have permanently affixed and legible identification markings as prescribed by the manufacturer, and indicates the recommended safe working load for the types of hitchs used, the angle upon which it is based, and the number of legs if more than one.

Paragraph (f)(4)(ii) requires that all welded end attachments of wire rope slings be proof tested by the manufacturer at twice their rated capacity prior to initial use, and that the employer retain a certificate of the proof test and make it available for examination.


Paragraph (g) of the Standard covers metal mesh slings.


Paragraph (g)(1) requires each metal mesh sling to have a durable marking permanently affixed that states the rated capacity for vertical basket hitch and choker hitch loadings.


Paragraph (g)(8)(ii) requires that once repaired, each metal mesh sling be permanently marked or tagged, or a written record maintained to indicate the date and type of the repairs made, and the person or organization that performed the repairs. Records of the repairs shall be made available for examination.


Paragraph (h) of the Standard covers natural and synthetic fiber-rope slings.


Paragraph (h)(1) requires each natural and synthetic fiber-rope sling to have permanently affixed and legible identification markings stating the rated capacity for the type of hitch used and angle upon which it is based, type of fiber material, and the number of legs if more than one.


Paragraph (i) of the Standard covers synthetic web slings.


Paragraph (i)(1) requires that synthetic web slings be marked or coded to show the rated capacities for each type of hitch and the type of synthetic web material used in the sling.


Paragraph (i)(8)(i) prohibits the use of repaired synthetic web slings until they have been proof tested by the manufacturer or an equivalent entity. Paragraph (i)(8)(ii) requires the employer to retain a certificate of the proof test and make it available for examination.


The information on the identification tags, markings, and codings assist the employer in determining whether the sling can be used for the lifting task. The sling inspections enable early detection of faulty slings. The inspection and repair records provide employers with information about when the last inspection was made and about the type of repairs made. This information provides some assurance about the condition of the slings. Proof-testing certificates give employers and workers assurance that slings are safe to use.


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 information collection 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 A.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.


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 slings, 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 by 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 inadvertently use defective or deteriorated slings; thereby, increasing their probability of death or serious injury caused by sling failure during material handling.


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, grant-in-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.


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.


Pursuant to the Paperwork Reduction Act of 1995 (PRA-95) (44 U.S.C. 3506(c)(2)(A)), OSHA published a notice in the Federal Register on October 22, 2014 (79 FR 63172) soliciting comments on its proposal to extend the Office of Management and Budget’s approval of the information collection requirements specified by the Standard on Slings (29 CFR 1910.184). This notice was a part of a preclearance consultation program that provided the general public and government with an opportunity to comment. The Agency received one comment in response to this notice from Mr. Matthew C. Whitman. Mr. Whitman based his comments on the four issues specified by the Federal Register Notice (FRN).


1. Whether the proposed information collection requirements are necessary for the proper performance of the Agency’s functions, including whether the information is useful;


Mr. Whitman agreed that the information collection requirements are necessary for OSHA’s function; he stated, “the information that is required to be collected by OSHA regarding 29 CFR 1910.184 is paramount to ensuring the safety of the users of slings….” And that the “collection requirements contained in the Standard on Slings must continue.


2. The accuracy of OSHA’s estimate of the burden (time and costs) of the information collection requirements, including the validity of the methodology and assumptions used;


Mr. Whitman agreed with the methodology of increasing the estimated burden hours based upon increasing the number of slings. Mr. Whitman quotes the Federal Register’s “Average Time Per Response “Varies from 1 minute (0.02 hour) to maintain a certificate to 30 minutes (0.50 hour) for a manufacturing worker to acquire information from a manufacturer for a new tag, make a new tag, and affix it to a sling (Federal Register).” Mr. Whitman then questions that one minute is rarely enough time to maintain a record. He goes on to cite paragraphs 1910.184(e)(3)(ii) that requires employer to make and maintain an inspection record, and 1910.184(e)(3)(iii), that requires employers to inspect alloy steel chains, stating that activities associated with these collection requirements would take a considerable amount of time, and that it depends on the amount of slings and the frequency of use. He goes on to state the importance of a thorough inspection and the ““value” should result in complete and thorough inspection resulting in safe equipment, efficiency in the use of time, and monetary cost savings.”


The commenter seems to indicate that OSHA is only taking one minute (.02 hour) to maintain and inspect alloy steel chain slings. However, the supporting statement takes 15 minutes (0.25 hour) for an employer to inspect each alloy steel chain sling and to generate and maintain the inspection record. In addition, the Agency assumes that employers could expend up to 30 minutes (0.5 hour) to acquire information, make a new tag and affix it to a sling. Finally, OSHA’s burden hour and cost estimates are based on the time needed to maintain one sling then it is multiplied by OSHA’s estimates of the total number of slings. OSHA maintains these time estimates absent any specific recommendations


Mr. Whitman recommend removing the statement “acquire information from a manufacturer for a new tag, make a new tag, and affix it to a sling” since, based on his experience, it is not accurate or realistic. He then provided rational why it is cost prohibitive for employers to ship slings back to the manufacturer to obtain a “tag.” OSHA concurred with Mr. Whitman and removed the references to “the manufacturer” since few, if any employers would choose this option. However, OSHA is maintaining the average 30 minute (0.5 hour) estimate. As the standard is performance-oriented, employers can choose the least burdensome means, such as ordering or making their own new tags, to replace tags. Discussion with a staff member with field experience indicated the 30 minutes was reasonable; and the commenter did not provide any specific time recommendations.

3. The quality, utility, and clarity of the information collected;


Mr. Whitman recommends that employers use materials such as OSHA’s guide on sling inspections and information found on the National Institute of Occupational Safety and Health’s (NIOSH) website (www.niosh.org) to obtain lists and forms to ensure slings are in good condition and will not fail under proper use. Further, using electronic forms would enable the employee to easily complete necessary inspections that would be of great value to an organization’s safety personnel. However, Mr. Whitman noted that this could be burdensome for employers. “For example, if one were to use NIOSH’s example inspection forms to complete daily inspection of: shackles, chain slings, wire rope or cable slings, synthetic web slings, static hanging lines, and auxiliary hoisting lines, that process would consist of six different paper forms an inspector would have to use. This is time consuming and unrealistic to expect a proper inspection to be completed on a job site with this method…”


To improve the collection of information requirements, Mr. Whitman recommends that OSHA and NIOSH develop an application similar to the highly successful “Ladder Safety” application (“app”). Such an app would be beneficial for the employee completing a sling inspection as well as the organization’s safety department in reviewing data.” He then recommends “three specific categories of data that could be developed to aid in ensuring the data will be utilized to its greatest ability.” The categories of data are Overlooked Data; Environmental Conditions, and Collection Resources. For each of these data categories, Mr. Whitman provides details as to how electronic means such as laptops, electronic tablets, and apps can enhance the data and make it easier to for the employer to analyze and use.


OSHA appreciates the detailed explanation of how technology can improve the quality of information and can be used to keep burden hours and costs to a minimum when inspecting slings. As OSHA has specified in the supporting statement, employers may use automated, electronic, mechanical, or other technological information collection 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). Employers may choose to develop forms, lists and databases, and use them on laptops to main such data. The recommendation to develop a sling app in conjunction with NIOSH has been shared with the appropriate office for consideration.


4. Ways to minimize the burden on employers who must comply; for example, by using automated or other technological information collection and transmission techniques.


Mr. Whitman again stressed how technology can be used to reduce paper and reduce burden on employers, and quoted a study that concluded “using an electronic tablet is both quicker and cheaper in relative costs compared to using paper and pen survey method.” He suggested how “the cloud” could be used to allow inspections to be reviewed by safety personnel before they are complete.


As stated above, employers may use information technology to develop and maintain inspection records required by the standard. A competent person inspecting a sling may use laptops to develop and maintain inspection records required by the standard as long as this information can be made available.


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 request 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.


· Provide estimates of annualized cost to respondents for 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 13.


The Agency believes the use of permanently attached identification markings will eliminate duplicative, inconsistent, and outdated information; thus, minimizing confusion over the rated capacity of any type of sling used by workers. Furthermore, reliance on the information marked on the sling simplifies compliance for employers by eliminating the need to check tables or other sources of information.


OSHA amended its standards regulating slings at §1910.184 (general industry), as well as §§1915.112, 1915.113, and 1915.118 (shipyard employment), and §1926.251 (construction) on June 8, 2011 (76 FR 33590) in its Standards Improvement Project Phase III. OSHA removed outdated tables that specified safe working loads, and revised other provisions (e.g., §§1910.184(e)(6) and 1915.112) that reference the outdated tables. The load-capacity tables in OSHA’s standards were based on the American National Standards Institute (ANSI) B30.9-1971 standard and were obsolete, and no longer conformed to the load-capacity tables of the updated ANSI B30.9-2010 standard. OSHA replaced the outdated tables with a requirement that prohibits employers from loading slings in excess of the recommended safe working load as prescribed on permanently affixed identification markings. In addition it prohibits the use of slings that do not have such markings.


Manufacturers produce slings with markings that indicate the sling’s rated capacity (i.e., safe working load), the name or trademark of the manufacturer, and other specifications (e.g., size, material used in manufacturing the sling); this information prevents misuse of slings; thereby, increasing worker safety and reducing costs.

Burden-Hour and Cost Determinations


The Agency estimates that the Standard covers approximately 1,350,000 slings, and that roughly 8% (108,000) are alloy steel chain slings, 60% (810,000) are wire rope slings, 2% (27,000) are metal-mesh slings,2 and 27% (364,500) are synthetic-web slings, 3% (40,500) are nature and synthetic fiber rope slings. OSHA used a wage rate of $33.63 for a crane operator in determining the cost of the paperwork requirements specified by the Standard.3


(A) Alloy Steel Chain Slings (§1910.184(e))


Paragraph 1910.184(e)(1) requires that alloy steel chain slings have permanently affixed and durable identification stating size, grade, rated capacity, and reach of the sling. The information, supplied by the manufacturer, is typically marked on a metal tag and affixed to the sling. The manufacturer provides this information as a usual and customary practice at the time of sale. However, if the tag comes off, another tag or marking with the required information must be affixed to the sling. OSHA estimates that only a small percentage of slings would fall into this category, as low as .1% (108), and that it would take about 30 minutes (.5 hour) to acquire the information, make a new tag, and affix it to the sling. A crane operator would perform this task.


Burden hours: 108 slings × .5 hour = 54 hours

Cost: 54 hours × $33.63 = $1,816


Paragraph (e)(3)(i) requires the employer to make a thorough periodic inspection of alloy steel chain slings in use on a regular basis, but at least once a year. Paragraph 1910.184(e)(3)(ii) requires the employer to make and maintain a record of the most recent month in which each alloy steel chain sling was thoroughly inspected. OSHA estimates that approximately 70% (75,600) of alloy steel chain slings are in use on a regular basis each year. It is also estimated that it takes 15 minutes (.25 hour) for a crane operator to conduct the inspection and to generate and maintain the inspection record once a year.


Burden hours: 75,600 slings × .25 hour = 18,900 hours

Cost: 18,900 hours × $33.63 = $635,607


Paragraph 1910.184(e)(4) requires the employer to ensure that before use, each new, repaired, or reconditioned alloy steel chain sling, including all welded components in the sling assembly, be proof tested by the sling manufacturer, and that the certificate of proof testing be maintained by the employer and made available for examination. The manufacturer normally performs the proof test and marks the equipment. OSHA estimates that 25% (27,000) of the alloy steel chain slings are replaced, repaired, or reconditioned each year. The manufacturer will prepare a certificate of the proof test as a usual and customary practice, so the employer has no burden for this activity. However, the employer will incur a burden to maintain the certificate, which the Agency estimates takes a crane operator 1 minute (.02 hour) to perform for each sling.


Burden hours: 27,000 slings × .02 hour = 540 hours

Cost: 540 hours × $33.63 = $18,160


(B) Wire Rope Slings (§1910.184(f))


Paragraph 1910.184(f)(1) requires each wire-rope sling to have permanently affixed and legible identification marking that indicates the safe working load for the type of hitch used, the angle upon which it is based, and the number of legs if more than one. This information will be supplied by the manufacturer initially, and the only burden to the employer would be to replace the initial tag or marking. OSHA estimates that only a small percentage of slings would fall into this category, as low as .1% (810), and it would take about 30 minutes (.50 hours) for a crane operator to acquire the information, make a new tag, and affix it to the sling.


Burden hours: 810 slings × .50 hour = 405 hours

Cost: 405 hours × $33.63 = $13,620


Paragraph 1910.184(f)(4)(ii) requires that all welded end attachments be proof tested by the manufacturer at twice their rated capacity prior to initial use, and that the employer maintain the certificate of proof test. OSHA estimates that 10% (81,000) of the wire rope slings have welded end attachments. The employer has no burden associated with the proof testing because the manufacturer, for liability reasons, and as a normal and customary practice, will test the equipment and provide a certificate to the employer. However, the employer must maintain the certificate. OSHA estimates that a crane operator spends 1 minute (.02 hour) maintaining a certificate for each sling.


Burden hours: 81,000 slings × .02 hour = 1,620 hours

Cost: 1,620 hours × $33.63 = $54,481


(C) Metal Mesh Slings (§1910.184(g))


Paragraph 1910.184(g)(1) requires each metal mesh sling to have a durable marking permanently affixed to it that indicates the rated capacity for vertical basket hitch and choker hitch loadings. This information will be supplied by the manufacturer initially, and the only burden to the employer would be to replace the initial tag or marking. OSHA estimates that only a small percentage of slings would fall into this category, as low as .1% (27), and it would take about 30 minutes (.50 hours) for a crane operator to acquire the information, make a new tag, and affix it to the sling.


Burden hours: 27 slings × .50 hour = 14 hours

Cost: 14 hours × $33.63 = $471


Paragraph 1910.184(g)(8)(ii) requires that once repaired, each sling shall be permanently marked or tagged, or a written record prepared for the employer, that contains the information specified in the Standard. The employer must maintain this record. Accordingly, OSHA estimates that the manufacturer, as a usual and customary practice, will affix markings stating the rated capacity for vertical basket hitch and choker hitch loadings as required under paragraph 1910.184(g)(1). OSHA also estimates that manufacturers will provide written records for about 10% (2,700) of the repaired slings. The remaining slings are either tagged or marked permanently as specified in the Standard. The manufacturer will prepare the certificate for the employer, and will provide tags or markings, as a usual and customary practice; hence, the employer has no burden for this activity. However, the employer must maintain the written records as required by paragraph 1910.184(g)(8)(ii). The Agency estimates that it takes a crane operator 1 minute (.02 hour) to complete this task.


Burden hours: 2,700 slings × .02 hour = 54 hours

Cost: 54 hours × $33.63 = $1,816


(D) Natural and Synthetic Fiber Rope Slings (§1910.184(h)(1))


Paragraph (h)(1) requires each natural and synthetic fiber-rope sling to have permanently affixed and legible identification markings stating the rated capacity for the types of hitchs used and angle upon which it is based, type of fiber material, and the number of legs if more than one. This information will be supplied by the manufacturer initially, and the only burden to the employer would be to replace the initial tag or marking. OSHA estimates that only a small percentage of slings would fall into this category, as low as .1% (41), and it would take about 30 minutes (.50 hours) for a crane operator to acquire the information, make a new tag, and affix it to the sling.


Burden hours: 41 slings ×.50 hour = 21 hours

Cost: 21 hours × $33.63 = $706


(E) Synthetic Web Slings (§1910.184(i))


Paragraph (i)(1) requires that synthetic web slings be marked or coded to show the rated capacities for each type of hitch, and the synthetic web material used in the sling. This information will be provided by the manufacturer as a usual and customary practice at the time of sale. However, if the mark or code needs to be replaced, OSHA estimates that it will take a crane operator about 30 minutes (.50 hour) to acquire the information and attach the marking or coding to the sling. OSHA estimates that only a few slings, about .1% (365), fall into this category.


Burden hours: 365 slings × .50 hour = 183 hours

Cost: 183 hours × $33.63 = $6,154


Paragraph 1910.184(i)(8)(ii) prohibits the use of repaired synthetic web slings that have not been proof tested by the manufacturer. The employer shall maintain a certificate of the proof test. The manufacturer will prepare a certificate of the proof test as a usual and customary practice, so the employer has no burden for this activity. However, the employer will incur a burden to maintain the certificate. The Agency estimates that a crane operator spends 1 minute (.02 hour) performing this activity. OSHA estimates that, in any given year, 25% (91,125) of the synthetic web slings are repaired.


Burden hours: 91,125 slings × .02 hour = 1,823 hours

Cost: 1,823 hours × $33.63 = $61,307


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 without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a single table.


There is no cost to the Federal Government associated with this information collection request.


15. Explain the reasons for any program changes or adjustments.


OSHA is proposing to increase the existing burden hour estimate for the collection of information requirements specified by the Standard from 20,001 hours to 23,614 hours (a total increase of 3,613 hours). This increase in burden hours is a result of an adjustment in the number of slings (from 1,116,667 to 1,350,000). The Agency has determined that inspection activities are not within the scope of the PRA; therefore, the Agency is no longer taking burden hours or costs for disclosing records.


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.


OSHA lists current valid control numbers in §§1910.8, 1915.8, 1917.4, 1918.4, and 1926.5 and publishes the expiration date in the Federal Register notice announcing OMB approval of the information collection requirement (see 5 CFR 1320.3(f)(3)). OSHA believes that this is the most appropriate and accurate mechanism to inform interested parties of these expiration dates.


18. Explain each exception to the certification statement.


OSHA is not seeking an exception.


B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS


The supporting statement does not contain any collection of information requirements that employs statistical methods.

Table 1


Proposed Burden-Hour Adjustments



Information Collection Requirement

Current

Burden Hours

Proposed

Burden Hours


Adjustment

(Hours)


Cost Under

Item 12



Responses



Explanation of Adjustment

(A) Alloy Steel Chain Slings







§1910.184 (e)(1)

45

54

9

$1,816

108

New data indicates an increase in the number of alloy steel chain slings from 89,333 to 108,000.

§1910.184(e)(3)(i)

15,633

18,900

3,267

$635,607

75,600

New data indicates an increase in the number of alloy steel chain slings from 89,333 to 108,000.

§1910.184(e)(4)

447

540

93

$18,160

27,000

New data indicates an increase in the number of alloy steel chain slings from 89,333 to 108,000.

(B) Wire Rope Slings







§1910.184(f)(1)


335

405

70

$13,620

810

New data indicates an increase in the estimated number of wire rope slings from 670,000 to 810,000.

§1910.184(f)(4)(ii)

1,340

1,620

280

$54,481

81,000

New data indicates an increase in the estimated number of synthetic web slings from 301,500 to 364,500.

(C) Metal Mesh Slings






New data indicates an increase in the estimated number of metal mesh slings from 22,333 to 27,000.

§1910.184(g)(1)

11

14

3

$471

27

New data indicates an increase in the estimated number of metal mesh slings from 22,333 to 27,000.


§1910.184(g)(8)(ii)

45

54

9

$1,816

2,700

New data indicates an increase in the number of synthetic web slings from 301,500 to 364,500.

(D) Natural and Synthetic Fiber Rope Slings







§1910.184(h)(1)

17

21

4

$706

41

New data indicates an increase in the estimated number of natural and synthetic fiber rope slings from 301,500 to 364,500.


(E) Synthetic Web Slings







§1910.184(i)(1)

151

183

32

$6,154

365

New data indicates an increase in the estimated number of synthetic web slings from 301,500 to 364,500.

§1910.184(i)(8)(ii)

1,508

1,823

315

$61,307

91,125

New data indicates an increase in the number of synthetic web slings from 301,500 to 364,500.

Disclosure of Certificates

469

0

-469

$0

0

The Agency has determined that inspection activities are not within the scope of the PRA; therefore, the Agency is no longer taking burden hours or costs for disclosing records.

TOTALS

20,001

23,614

3,613

$794,138


303,076



1The 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, these provisions.



2OSHA contacted two chain and wire companies to obtain information on the number of chain slings in use. The Agency was not able to obtain data from industry representatives on the number of slings in use; therefore, for this ICR, OSHA extrapolated from the change in the number of slings from 2008 (1,000,000) to 2010 (1,116,667) and estimated the 2014 value, based on the assumption that the number of slings has increased at the same average annual rate since 2008.


3Source: Employer Costs for Worker Compensation – December 2014, Bureau of Labor Statistics, U.S. Department of Labor, May 2014 (http://www.bls.gov/oes/current/oes537021.htm). Based on a mean hourly wage rate of $25.75 for a crane operator (OES Code: 53-7021) including fringe benefits of 30.6% obtained from Employer Costs for Employee Compensation – December 2014, Employer Costs for Employee Compensation News Release (March 2015), Bureau of Labor Statistics, U.S. Department of Labor (http://www.bls.gov/schedule/archives/ecec_nr.htm).



13

File Typeapplication/msword
File TitleSUPPORTING STATEMENT FOR
AuthorTKenney
Last Modified ByKenney, Theda - OSHA
File Modified2015-03-30
File Created2015-03-30

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