SS_1218-0220-Shipyard Employment Standards_ 05-11-2018_ROCIS

THE SHIPYARD EMPLOYMENT STANDARDS (29 CFR part 1915, subparts G and K)

1218-0220

June 2018

SUPPORTING STATEMENT FOR

THE INFORMATION COLLECTION REQUIREMENTS IN

THE SHIPYARD EMPLOYMENT STANDARDS (29 CFR part 1915, subparts G and K)¹

OFFICE OF MANAGEMENT AND BUDGET (OMB)

CONTROL NO. 1218-0220 (May 2018)

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).

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 standards for the shipyard employment industry regulating manila rope and manila rope slings (29 CFR 1915.112(a)(1)), wire rope and wire rope slings (29 CFR 1915.112(b)(1)), chain and chain slings (29 CFR 1915.112(c)(1)), hooks and shackles (29 CFR 1915.113(b)(1)) and portable air receivers and other unfired pressure vessels (29 CFR 1915.172(d)) in shipyards (i.e., “the Standards"). The paperwork provisions of the Standards specify requirements for developing and maintaining records of tests. Items 2 and 12 below describe in detail the specific information collection requirements of the Standards.

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 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 reduce employees’ risk of death or serious injury by ensuring that equipment has been tested and is in safe operating condition.

§1915.112 Ropes, chains, and slings:

Manila rope and manila-rope slings (paragraph (a)(1)). The employer must ensure that manila rope and manila-rope slings have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one.

Wire rope and wire-rope slings (paragraph (b)(1)). The employer must ensure that wire rope and wire-rope slings have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one.

Chain and chain slings (paragraph (c)(1)). The employer must ensure that chain and chain slings have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one.

Chain and chain slings (paragraph 1915.112(c)(2)) – the employer shall visually inspect all sling chains, including end fastenings, before being used on the job, as well as every 3 months. The inspection shall include inspection for wear, defective welds, deformation and increase in length or stretch. Each chain shall bear an indication of the month in which it was thoroughly inspected.

§1915.113 Shackles and hooks:

Shackles (paragraph (a)(1)). The employer must ensure that shackles have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load

Test Records for Hooks (paragraph (b)(1)). This paragraph requires that the manufacturer’s recommendations be followed in determining the safe working loads of the various sizes and types of hooks. If the manufacturer’s recommendations are not available, the hook must be tested to twice the intended safe working load before it is initially put into use. The employer must maintain and keep readily available a certification record which includes the date of such test, the signature of the person who performed the test, and the identifier for the hook which was tested.

The records are used to assure that equipment has been properly tested. The records also provide the most efficient means for the compliance officers to determine that an employer is complying with the Standard.

§1915.114 Chain falls and pull-lifts:

The provisions of this section shall apply to ship repairing, shipbuilding and shipbreaking. (a) Chain falls and pull-lifts shall be clearly marked to show the capacity and the capacity shall not be exceeded.

The employer must ensure that the chain falls and pull-lifts are properly mark by the manufacturer and the markings are clear. It is usual and customary practice for employers to make sure that these markings are on the equipment. And therefore, the burden for this collection of information requirements is zero.

§1915.115 Hoisting and Hauling Equipment:

Mobile Crawler or Truck Cranes Used on a Vessel (paragraph 1915.115(c)) – This paragraph requires that the maximum manufacturer's rated safe working loads for the various working radii of the boom and the maximum and minimum radii at which the boom may be safely used with and without outriggers shall be conspicuously posted near the controls and shall be visible to the operator.

§1915.131   General precautions.

The provisions of this section shall apply to ship repairing, shipbuilding and shipbreaking. (g) Headers, manifolds and widely spaced hose connections on compressed air lines shall bear the word “air” in letters at least 1-inch high, which shall be painted either on the manifolds or separate hose connections, or on signs permanently attached to the manifolds or connections. Grouped air connections may be marked in one location.

The employer must ensure that the headers, manifolds and widely spaced hose connections on compressed air lines are properly mark by the manufacturer and the markings are clear. It is usual and customary practice for employers to make sure that these markings are on the equipment. And therefore, the burden for this collection of information requirements is zero.

§1915.172 Portable air receivers and other unfired pressure vessels.

Examination and Test Records for Unfired Pressure Vessels (paragraph (d)). This paragraph requires that portable, unfired pressure vessels not built to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section VIII, Rules for Construction of Unfired Pressure Vessels, 1963 be examined quarterly by a competent person and subjected to a yearly hydrostatic pressure test. A certification record of such examinations and tests shall be maintained.

The records are used to assure that equipment has been properly tested. The records also provide the most efficient means for OSHA compliance officers to determine that an employer is complying with the Standard. OSHA does not believe that there are any unfired pressure vessels not built to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section VIII, Rules for Construction of Unfired Pressure Vessels, 1963 currently in use. However, for purposes of completing this ICR, the Agency is calculating burden hours and costs for this provision.

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 employee 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 Standards 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 Standards are the minimum frequencies necessary to effectively regulate equipment, 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, employees may inadvertently use equipment that is unsafe to use, thus increasing their risk of death and serious injury.

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.

As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3506(c)(2)(A)), OSHA published a notice on April 11, 2018 in the Federal Register (83 FR 15639) requesting public comment on its proposal to extend the Office of Management and Budget’s (OMB) approval of the information collection requirements contained in its Shipyard Employment Standards (“the Standard”; Docket No. OSHA-2011-0190). This notice is part of a preclearance consultation program intended to provide those interested parties with an opportunity to comment on OSHA’s request for an extension by the Office of Management and Budget (OMB) 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 Standards 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 Standards 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 than10) 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.

Respondent Burden-Hour and Cost Determinations

Estimating the number of shipyard firms and establishments, shipyard employers, and shipyard employees

The number of shipyard firms and establishments, shipyard employers and shipyard employees used in this ICR are based on the Final Economic Analysis of 29 CFR part 1915, subpart F, which was prepared by OSHA’s Office of Regulatory Analysis. The Agency estimates that there are 2,759 establishments affected by this ICR.

Wage Rates

The wage rates below, which include fringe benefits, are based on data from the Bureau of Labor Statistics website. This data was updated and provided by the Office of Regulatory Analysis.²

Table A -- Wage Rates with Fringe Benefits of 0.696

	Supervisors	Authorized Employees	Affected Employees	Secretary	Shipyard Worker
Shipyard	46.62	35.59	32.41	28.02	29.28
	First-Line Supervisors of Production and Operating Workers	Electrician Pipelayers, Plumbers, Pipefitters, and Steamfitters Electrical and Electronic Equipment Mechanics, Installers, and Repairers Machinist Boilermaker	Construction Trades Workers Maintenance and Repair Workers, General Miscellaneous Production Workers	Secretaries and Administrative Assistants, Except Legal, Medical, and Executive	Maintenance and Repair workers, general
SIC Codes	51-1011	47-2111 47-2150 49-2000 51-4041 47-2011	47-2000 49-9071 51-9190	43-6014	49-9071
Commercial Fishing	33.72	21.24	21.24	28.02
	First-Line Supervisors of Farming, Fishing, and Forestry Workers	Fishers and Related Fishing Workers	Fishers and Related Fishing Workers	Secretaries and Administrative Assistants, Except Legal, Medical, and Executive
SIC Codes	45-1011	45-3011	45-3011	43-6014
Fish Processing	32.90	37.95	32.92	28.02
	First-Line Supervisors of Production and Operating Workers	Electricians Plant and System Operators	Construction Trades Workers Electrical and Electronic Equipment Mechanics, Installers, and Repairers Miscellaneous Production Workers	Secretaries and Administrative Assistants, Except Legal, Medical, and Executive
SIC Codes	51-1011	47-2111 51-8000	47-2000 49-2000 51-9190	43-6014
Water Transportation	41.82	41.44	27.50	28.02
	Supervisors of Transportation and Material Moving Workers	Electricians Marine Engineers and Naval Architects	Electrical and Electronic Equipment Mechanics, Installers, and Repairers Miscellaneous Production Workers	Secretaries and Administrative Assistants, Except Legal, Medical, and Executive
SIC Codes	53-1000	47-2111 17-2121	49-2000 51-9190	43-6014

(A) Slings in Shipyards and Non-Shipyards Industries:

Identification of Safe Working Loads Under Paragraphs 1915.112(a) and (b)

Shipyards:

Manila rope and manila-rope slings (paragraph 1915.112 (a)(1)) -- The employer must ensure that manila-rope and manila rope slings have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one.

On average, OSHA estimates that there are 4 slings per shipyard in use and that there are 674 establishments affected in shipyard employment (4 slings/shipyard x 674 establishments = 2,696 slings). The Agency estimates that 1% of the shackles will be required to have the labels replaced in accordance with the manufacturer’s specifications. OSHA estimates that it will take 30 minutes (0.5 hour) for a shipyard worker to acquire and affix the label according to the manufacturer’s specifications.

Burden hours: 2,696 slings x 1% slings to be repaired x .5 hour = 13 hours

Cost: 13 hours x $29.28= $381

Wire rope and wire-rope slings (paragraph 1915.112 (b)(1)) -- The employer must ensure that wire rope and wire-rope slings have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one.

On average, OSHA estimates that there are 4 slings per shipyard in use and that there are 674 establishments affected in shipyard employment (4 slings/shipyard x 674 establishments = 2,696 slings). It is estimated that only 1% of the shackles will need to the labels replaced in accordance with the manufacturer’s specifications. It is estimated to take 30 minutes (0.5 hours) for a shipyard worker to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 2,696 slings x 1% slings to be repaired x .5 hour = 13 hours

Cost: 13 hours x $29.28 = $381

Chain and chain slings (paragraph 1915.112 (c)(1)) -- The employer must ensure that chain and chain slings have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load for the type(s) of hitch(es) used, the angle upon which it is based, and the number of legs if more than one.

On average, OSHA estimates that there are 4 slings per shipyard in use and that there are 674 establishments affected in shipyard employment (4 slings/shipyard x 674 establishments = 2,696 slings). The Agency estimates that 1% of the slings will need to have the labels replaced according to the manufacturer’s specifications. OSHA estimates that it will take a shipyard worker 30 minutes (0.5 hours) to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 2,696 slings x 1% slings to be repaired x .5 hour = 13 hours

Cost: 13 hours x $29.28 = $381

Table 1 -- Summary of Burden Hours and Cost in the Shipyard Industries

Type of Sling Shipyard	Affected Establishments	Slings	Percent Repaired	Time to Repair	Total Hours	Affected Employee	Cost
Manila	674	2,696	1%	0.5 hours	13	$29.28	$381
Wire Rope	674	2,696	1%	0.5 hours	13	$29.28	$381
Chain	674	2,696	1%	0.5 hours	13	$29.28	$381
Total		8,088			39		$1,143

Non-Shipyards:

On average, OSHA estimates that only one third of establishments will require slings in use for commercial fishing and that there are 2,343 establishments affected in shipyard employment (1/3 x 2,343 establishments = 781 slings). The Agency estimates that 1% of the shackles will be required to have the labels replaced in accordance with the manufacturer’s specifications. OSHA estimates that it will take 30 minutes (0.5 hour) for an affected worker to acquire and affix the label according to the manufacturer’s specifications.

Burden hours: 781 slings x 1% slings to be repaired x .5 hour = 4 hours

Cost: 4 hours x $21.24 = $85

On average, OSHA estimates that only one third of establishments will require slings in use for fish processing and that there are 618 establishments affected in shipyard employment (1/3 x 618 establishments = 206 slings). The Agency estimates that 1% of the shackles will be required to have the labels replaced in accordance with the manufacturer’s specifications. OSHA estimates that it will take 30 minutes (0.5 hour) for an affected worker to acquire and affix the label according to the manufacturer’s specifications.

Burden hours: 206 slings x 1% slings to be repaired x .5 hour = 1 hour

Cost: 1 hour x $32.92= $33

On average, OSHA estimates that only one third of establishments will require slings in use for tug and towing service and that there are 889 establishments affected in shipyard employment (1/3 x 889 establishments = 296 slings). The Agency estimates that 1% of the shackles will be required to have the labels replaced in accordance with the manufacturer’s specifications. OSHA estimates that it will take 30 minutes (0.5 hour) for a shipyard worker to acquire and affix the label according to the manufacturer’s specifications.

Burden hours: 296 slings x 1% slings to be repaired x .5 hour = 1 hour

Cost: 1 hour x $27.50 = $28

On average, OSHA estimates that only one third of establishments will require slings in use for passenger vessels and that there are 347 establishments affected in shipyard employment (1/3 x 347 establishments = 116 slings). The Agency estimates that 1% of the shackles will be required to have the labels replaced in accordance with the manufacturer’s specifications. OSHA estimates that it will take 30 minutes (0.5 hour) for a shipyard worker to acquire and affix the label according to the manufacturer’s specifications.

Burden hours: 116 slings x 1% slings to be repaired x .5 hour = 1 hour (rounded up)

Cost: 1 hour x $27.50 = $28

Table 2 --- Summary Burden Hours and Cost in the Non-Shipyard Industries for Slings

Industry	Affected Establishments	Slings	Percent Repaired	Time to Repair	Total Hours	Affected Employee Wages	Cost
Commercial Fishing	2,343	781	1%	0.5 hour	4	$21.24	$85
Fish Processing	618	206	1%	0.5 hour	1	$32.92	$33
Tug & Towing Services	889	296	1%	0.5 hour	1	$27.50	$28
Passenger Vessels	347	116	1%	0.5 hour	1	$27.50	$28
Total		1,399			7		$174

Sling Inspections Under Paragraph 1915.112(c):

Shipyards:

Chain and chain slings (paragraph 1915.112(c)(2)) – In paragraph 1915.112(c)(2), the employer must visually inspect all sling chains, including end fastenings, before being used on the job, as well as every 3 months. The inspection shall include inspection for wear, defective welds, deformation and increase in length or stretch. Each chain shall bear an indication of the month in which it was thoroughly inspected.

On average, OSHA estimates that there are 4 slings per shipyard in use and that there are 674 establishments affected in shipyard employment. (4 slings/shipyard x 674 establishments = 2,696 slings). All sling chains in use must be inspected and labeled with the date of inspection, which has been estimated to take 30 minutes (0.5 hours) for a shipyard authorized employee to inspect each sling and affix a label containing the date of inspection.

Burden hours: 2,696 slings x 4 inspections/ year x .5 hour = 5,392 hours

Cost: 5,392 hours x $35.59 = $191,901

Non-Shipyards:

OSHA estimates additional man hours and cost associated with the inspection and application of the date of inspection, four times annually, for the number of chain slings used by the above estimated establishments for commercial fishing. On average, it will take approximately 30 minutes (0.5 hour) for an authorized worker to inspect and affix a label indicating the date of inspection.

Burden hours: 781 slings x 4 inspections/ year x .5 hour = 1,562 hours

Cost: 1,562 hours x $21.24 = $33,177

OSHA estimates additional man hours and cost associated with the inspection and application of the date of inspection, four times annually, for the number of chain slings used by the above estimated establishments for fish processing. On average, it will take approximately 30 minutes (0.5 hour) for an authorized worker to inspect and affix a label indicating the date of inspection.

Burden hours: 206 slings x 4 inspections/ year x .5 hour = 412 hours

Cost: 412 hours x $37.95 = $15,635

OSHA estimates additional man hours and cost associated with the inspection and application of the date of inspection, four times annually, for the number of chain slings used by the above estimated establishments for tug and towing service. On average, it will take approximately 30 minutes (0.5 hour) for an authorized worker to inspect and affix a label indicating the date of inspection.

Burden hours: 296 slings x 4 inspections/ year x .5 hour = 592 hours

Cost: 592 hours x $41.44 = $24,532

OSHA estimates additional man hours and cost associated with the inspection and application of the date of inspection, four times annually, for the number of chain slings used by the above estimated establishments for passenger vessels. On average, it will take approximately 30 minutes (0.5 hour) for an authorized worker to inspect and affix a label indicating the date of inspection.

Burden hours: 116 slings x 4 inspections/year x .5 hour = 232 hours

Cost: 232 hours x $41.44 = $9,614

Table 3 --- Summary Burden Hours and Cost in the Shipyard and Non-Shipyard Industries for Sling Inspections

Industry	Affected Establishments	Sling inspections	Time to Inspect	Total Hours	Authorized Employee Wages	Cost
Shipyards	674	10,784	0.5 hours	5,392	$35.59	$191,901
Commercial Fishing	2,343	3,124	0.5 hours	1,562	$21.24	$33,177
Fish Processing	618	824	0.5 hours	412	$37.95	$15,635
Tug & Towing Services	889	1,184	0.5 hours	592	$41.44	$24,532
Passenger Vessels	347	464	0.5 hours	232	$41.44	$9,614
Total	4,871	16,380		8,190		$274,859

(B) Shackles and Hooks in Shipyards and Non-Shipyards Industries:

Shipyards:

Shackles (paragraph 1915.113 (a)(1)) -- The employer must ensure that shackles have permanently affixed and legible identification markings as prescribed by the manufacturer that indicate the recommended safe working load.

On an average, OSHA estimates that there are 2 shackles per shipyard in use and there are 674 establishments affected in shipyard employment (2 shackles/shipyard x 674 establishments = 1,348 shackles). It is estimated that 1% of the shackles will need to be replaced to have the labels replaced according to the manufacturer’s specifications. It will take 30 minutes (0.5 hours) for a shipyard worker to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 1,348 shackles x 1% shackles to be repaired x .5 hour = 7 hours

Cost: 7 hours x $29.28 = $205

Non-Shipyards:

On an average, OSHA estimates that there are half as many shackles used in non-shipyard industries and only one third of the establishments (2,343) will be affected in Commercial Fishing (1 shackles/shipyard x 2,343 establishments = 2,343 shackles). It is estimated that 1% of the shackles will need to be replaced to have the labels replaced according to the manufacturer’s specifications. It will take 30 minutes (0.5 hours) for a shipyard worker to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 2,343 shackles x 1% shackles to be repaired x .5 hour = 12 hours

Cost: 12 hours x $21.24 = $255

On an average, OSHA estimates that there are half as many shackles used in non-shipyard industries and only one third of the establishments (618) will be affected in Fish Processing (1 shackles/shipyard x 618 establishments = 618 shackles). It is estimated that 1% of the shackles will need to be replaced to have the labels replaced according to the manufacturer’s specifications. It will take 30 minutes (0.5 hours) for a shipyard worker to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 618 shackles x 1% shackles to be repaired x .5 hour = 3 hour

Cost: 3 hour x $32.92 = $99

On an average, OSHA estimates that there are half as many shackles used in non-shipyard industries and only one third of the establishments (889) will be affected in Tug & Towing Services (1 shackles/shipyard x 889 establishments = 889 shackles). It is estimated that 1% of the shackles will need to be replaced to have the labels replaced according to the manufacturer’s specifications. It will take 30 minutes (0.5 hours) for a shipyard worker to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 889 shackles x 1% shackles to be repaired x .5 hour = 4 hour

Cost: 4 hour x $27.50 = $110

On an average, OSHA estimates that there are half as many shackles used in non-shipyard industries and only one third of the establishments (347) will be affected in Passenger Vessels (1 shackles/shipyard x 347 establishments = 347 shackles). It is estimated that 1% of the shackles will need to be replaced to have the labels replaced according to the manufacturer’s specifications. It will take 30 minutes (0.5 hours) for a shipyard worker to acquire and affix the label according to manufacturer’s specifications.

Burden hours: 347 shackles x 1% shackles to be repaired x .5 hour = 2 hour (rounded up)

Cost: 2 hour x $27.50 = $55

Shipyards:

Examination and Test of Hooks (paragraph 1915.113(b)(1))

This paragraph specifies that where the manufacturer’s recommendations are not followed, employers must test each hook to twice its working load. The employer must prepare a certification record for each test, providing the date the test was performed, the name of the person who performed the test and an identifier of the hook tested. The certification record must be maintained and disclosed upon request to OSHA.

OSHA estimates that the manufacturer’s recommendations will be available and followed for 90% of all the hooks, leaving only 10% of the hooks without manufacturer’s recommendations to follow. In those situations, the shipyard will either have to call the manufacturer and get the information or test the hook to obtain the information. OSHA bases this assumption on previous conversations with a representative of the Crosby Group (the largest manufacturer of hooks and other rigging equipment). The Crosby Group confirmed that the manufacturer’s recommendations are provided at the time of sale, but a small percentage of the users lose those recommendations and must contact the manufacturer (whose ID is on the hook) to establish the working load of the hook. OSHA assumes that some of the users will choose to test the hook to twice its intended working load rather than call the manufacturer to obtain the information. Therefore, OSHA estimates that it will take about 20 minutes (.33 hour) per hook for a shipyard production worker/competent person to conduct the test to determine the working load and an additional 3 minutes (.05 hour) to develop and maintain the certification record for a total of 23 minutes (.38 hour). If the user elects to obtain the information from the manufacturer instead of performing the test, it will take about 35 minutes per hook to make the necessary phone calls and get the information, according to the Crosby Group. The time, thus, is averaged at 28 minutes (.47 hour). A shipyard production worker will make the phones call or conduct the test.

Burden hours: 674 establishments x 4 hooks/shipyard x 10% x .47 hour = 127 hours

Cost: 127 burden hours x $29.28 = $3,719

Non-Shipyards:

Also, OSHA estimates in Commercial Fishing that the manufacturer’s recommendations are available to the 90% for all to follow and leaving only 10% of the hooks without manufacturer’s recommendations to follow. And on average, only one third of those establishments will have to make the phones call or conduct the test.

Table 4 – Summary of the Burden Hours and Cost for Hooks

Industry	Affected Establishments	Hooks	Percent Repaired	Time to Repair	Total Hours	Affected Employee Wages	Cost
Commercial Fishing	2,343	1	10%	0.47 hour	110	$21.24	$2,336
Fish Processing	618	1	10%	0.47 hour	29	$32.92	$955
Tug & Towing Services	889	1	10%	0.47 hour	42	$27.50	$1,155
Passenger Vessels	347	1	10%	0.47 hour	16	$27.50	$440
Total	4,197				197		$4,886

(C) Hoisting and Hauling Equipment in shipyards

Shipyards:

Mobile crawler or truck cranes used on a vessel (paragraph 1915.115(c)(1)) -- Employers must conspicuously post the maximum manufacturer's rated safe working loads for the various working radii of the boom and the maximum and minimum radii at which the boom may be safely used with and without outriggers. The location of placement must be near the controls and visible to the operator.

On average, OSHA estimates that there is one mobile crawler or truck crane per shipyard, and that this type of equipment would not be used in non-shipyards. Therefore, out of the approximate 4,871 establishments included in the scope of 29 CFR part 1915, only about 177 are in service for the use of ship repair, shipbuilding, shipbreaking, and other related shipyard employment. Further, it is estimated that it will take 15 minutes (0.25 hours) for a shipyard worker to acquire and affix a label indicating the maximum manufacturer's rated safe working loads.

Burden hours: 177 mobile crane x .25 hour = 44 hours

Cost: 44 hours x $29.28 = $1,288

(D) Examination and Test Records of Unfired Pressure Vessels (paragraph 1915.172(d))

As discussed under Item 2, OSHA does not believe that there are any unfired pressure vessels not built to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section VIII, Rules for Construction of Unfired Pressure Vessels, 1963 currently in use; therefore, there would be no burden hours and costs for this paragraph.

However, for purposes of this ICR, OSHA maintains that each shipyard will have, on average, four portable, unfired pressure vessels (UPVs) and that it will take 13 minutes (.22 hour) for a competent person to conduct the quarterly examination of the vessel and to generate and maintain a certification record of the examination. In addition, OSHA estimates that it will take 18 minutes (.3 hour) per vessel for a competent person to conduct the yearly hydrostatic pressure test of the vessels and to generate and maintain a certification record of the results of the test.

Burden hours: Quarterly: 674 establishments x 4 vessels x 4 tests/year x .22 hour = 2,372 hours

Cost: 2,372 burden hours x $32.41 = $76,877

Burden hours: Yearly: 674 establishments x 4 vessels x .3 hour = 809 hours

Cost: 809 burden hours x $32.41 = $26,220

Table – 5

Shipyard Employment Standard Burden Hours and Cost Per Response

		ICR Requirements	Responses	Time per Response	Burden Hours	Wage Rate	Estimated Cost
1	Shipyards – Slings to be repaired
2		§1915.112(a)(1) Manila rope and manila rope slings	27	.5 hours	13	$29.28	$381
3		§1915.112(b)(1) Wire rope and wire rope slings	27	.5 hours	13	$29.28	$381
4		§1915.112(c)(1) Chain and chain slings	27	.5 hours	13	$29.28	$381
5	Non-Shipyards – Slings to be repaired
6		Commercial Fishing	8	.5 hours	4	$21.24	$85
7		Fish Processing	2	.5 hours	1	$32.92	$33
8		Tug & Towing Services	3	.5 hours	1	$27.50	$28
9		Passenger Vessels	1	.5 hours	1	$27.50	$28
10	Shipyards and Non-Shipyards – Sling inspections
11		§1915.112(c)(2) Chain and chain –Shipyards	10,784	.5 hours	5,392	$35.59	$191,901
12		Commercial Fishing	3,124	.5 hours	1,562	$21.24	$33,177
13		Fish Processing	824	.5 hours	412	$37.95	$15,635
14		Tug & Towing Services	1,184	.5 hours	592	$41.44	$24,532
15		Passenger Vessels	464	.5 hours	232	$41.44	$9,614
16	Shipyards – Shackles
17		§1915.113(a)(1) Shackles	13	.5 hours	7	$29.28	$205
18	Non-Shipyards – Shackles
19		Commercial Fishing	23	.5 hours	12	$21.24	$255
20		Fish Processing	6	.5 hours	3	$32.92	$99
21		Tug & Towing Services	9	.5 hours	4	$27.50	$110
22		Passenger Vessels	3	.5 hours	2	$27.50	$55
23	Shipyards – Hooks
24		§1915.113(b)(1) Examination and test of hooks	270	.47 hours	127	$29.28	$3,719
25	Non-Shipyards – Hooks
26		Commercial Fishing	234	.47 hours	110	$21.24	$2,336
27		Fish Processing	62	.47 hours	29	$32.92	$955
28		Tug & Towing Services	89	.47 hours	42	$27.50	$1,155
29		Passenger Vessels	35	.47 hours	16	$27.50	$440
30	Shipyards – Hoisting and Hauling
31		Mobile crawler or truck cranes used on a vessel (paragraph 1915.115(c)(1))	177	.25 hours	44	$29.28	$1,288
32		§1915.172(d) Examination and test records of unfired pressure vessels. (quarterly)	10,784	.22 hours	2,372	$32.41	$76,877
33		§1915.172 Examination and test records of unfired pressure vessels (yearly)	2,696	.3 hours	809	$32.41	$26,220
36	Total		30,876		11,813		$389,890

All numbers in the chart have been rounded up to the nearest whole number.

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 Standards.

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 are no costs to the Federal Government.

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

OSHA is requesting an increase adjustment in the number of burden hours from 9,773 hours to 11,813, a total increase of 2,040 burden hours. This increase is due the increase in the number of establishments. In this ICR, the scope of the maritime standards, 29 CFR part 1915 for slings, shackles, and hooks, are based on the Final Economic Analysis for the final rule revising subpart F of 29 CFR part 1915 prepared by OSHA’s Office of Regulatory Analysis. The revision of the standard applies to all shipyard employment, which is defined in 1915.4(i) as ship repairing, shipbuilding, shipbreaking, and related employment. See below in Table 6.

Table 6 – Current and Requested Burden Hours

		ICR Requirements	Current Burden Hours	Requested Burden Hours	Adjustment	Comments
1	Shipyards – Slings to be repaired
2		§1915.112(a)(1) Manila rope and manila rope slings	13	13	0	There was an increase in the number of slings due to the increase in the number of establishment.
3		§1915.112(b)(1) Wire rope and wire rope slings	13	13	0	There was an increase in the number of slings due to the increase in the number of establishment.
4		§1915.112(c)(1) Chain and chain slings	13	13	0	There was an increase in the number of slings due to the increase in the number of establishment.
5	Non-Shipyards – Slings to be repaired
6		Commercial Fishing	2	4	2	There was an increase in the number of slings repaired due to the increase in the number of establishment.
7		Fish Processing	1	1	0	There was an increase in the number of slings due to the increase in the number of establishment.
8		Tug & Towing Services	1	1	0	There was an increase in the number of slings due to the increase in the number of establishment.
9		Passenger Vessels	1	1	0	There was an increase in the number of slings due to the increase in the number of establishment.
10	Shipyards and Non-Shipyards – Sling inspections
11		§1915.112(c)(2) Chain and chain –Shipyards	5,112	5,392	280	There was an increase in the number of slings inspected due to the increase in the number of establishment.
12		Commercial Fishing	760	1,562	802	There was an increase in the number of slings inspected due to the increase in the number of establishment.
13		Fish Processing	142	412	270	There was an increase in the number of slings inspected due to the increase in the number of establishment.
14		Tug & Towing Services	426	592	166	There was an increase in the number of slings inspected due to the increase in the number of establishment.
15		Passenger Vessels	84	232	148	There was an increase in the number of slings inspected due to the increase in the number of establishment.
16	Shipyards – Shackles
17		§1915.113(a)(1) Shackles	6	7	1	There was an increase in the number of shackles due to the increase in the number of establishment.
18	Non-Shipyards – Shackles
19		Commercial Fishing	2	12	10	There was an increase in the number of shackles due to the increase in the number of establishment.
20		Fish Processing	1	3	2	There was an increase in the number of shackles due to the increase in the number of establishment.
21		Tug & Towing Services	1	4	3	There was an increase in the number of shackles due to the increase in the number of establishment.
22		Passenger Vessels	1	2	1	There was an increase in the number of shackles due to the increase in the number of establishment.
23	Shipyards – Hooks
24		§1915.113(b)(1) Examination and test of hooks	120	127	7	There was an increase in the number of hooks due to the increase in the number of establishment.
25	Non-Shipyards – Hooks
26		Commercial Fishing	18	110	92	There was an increase in the number of hooks due to the increase in the number of establishment.
27		Fish Processing	3	29	26	There was an increase in the number of hooks due to the increase in the number of establishment.
28		Tug & Towing Services	10	42	32	There was an increase in the number of hooks due to the increase in the number of establishment.
29		Passenger Vessels	2	16	14	There was an increase in the number of hooks due to the increase in the number of establishment.
30	Shipyards
31		Mobile crawler or truck cranes used on a vessel (paragraph 1915.115(c)(1))	25	44	19	There was an increase due to the increase in the number of establishment.
32		§1915.172(d) Examination and test records of unfired pressure vessels. (quarterly)	2,249	2,372	123	There was an increase due to the increase in the number of establishment.
33		§1915.172 Examination and test records of unfired pressure vessels (yearly)	767	809	42	There was an increase due to the increase in the number of establishment.
36	Total		9,773	11,813	2,040

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.

OSHA is not seeking an exception to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

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

1The purpose of this Supporting Statement is to analyze and describe the burden hours and costs 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.

2 The prior ICR used the amounts from the FEA and inflated them to calculate the loaded wage rates. However, based on the FEA discussion, as well as recent ICR’s, the methodology for calculating wage rates has been updated to use BLS data instead. The ICR lists out shipyards, water transportation, fish processing, commercial fishing, shipbuilding and repair shipyard workers, and secretary/ administrative staff.  While these job classifications do not align with OES profiles, close approximations of the occupational data have been used. This same methodology was carried forward throughout where possible. For the occupation groups, employment was multiplied with the wage and an overall average was calculated. From there, the loaded wage rate was calculated using the updated OES and ECEC data. In instances where the employment estimate was not published, a straight average was calculated. Occupation groupings were pulled from the original Subpart F cost spreadsheet.

28