OMB0130_multi-purpose_lighters_2020

Supporting Statement
Safety Standard for Multi-Purpose Lighters
A.

Justification

1. Information to be collected and circumstance that make the collection of information
necessary
Section 14(a)(1) of the Consumer Product Safety Act (CPSA) (15 U.S.C. 2063(a))
requires manufacturers, importers, and private labelers of a consumer product subject to a
consumer product safety standard under the CPSA or similar rule, ban, standard, or
regulation under any other act enforced by the Commission to issue a certificate stating
that the product complies with all applicable rules, bans, standards or regulations.
Section 14(b) of the CPSA (15 U.S.C. 2063(b)) authorizes the Commission to issue
regulations to prescribe a reasonable testing program to support certificates of
compliance with a consumer product safety standard under the CPSA or similar rule, ban,
standard or regulation under any other act enforced by the Commission. Section 16(b) of
the CPSA (15 U.S.C. 2065(b)) authorizes the Commission to issue rules to require that
firms establish and maintain records to permit the Commission to determine compliance
with rules issued under the authority of the CPSA.
The Commission has issued regulations prescribing requirements for a reasonable testing
program to support certificates of compliance with the standard for multi-purpose
lighters. These regulations require manufacturers and importers to submit a description
of each model of lighter, results of prototype qualification tests for compliance with the
standard, and other information before the introduction of each model of lighter into
commerce. These regulations also require manufacturers, importers, and private labelers
of multi-purpose lighters to establish and maintain records to demonstrate successful
completion of all required tests to support the certificates of compliance that they issue.
16 CFR part 1212, subpart B.
The Commission uses the information compiled and maintained by manufacturers,
importers, and private labelers of multi-purpose lighters to protect consumers from risks
of accidental deaths and burn injuries associated with those lighters. More specifically,
the Commission uses this information to determine whether lighters comply with the
standard by resisting operation by young children. The Commission also uses this
information to obtain corrective actions if multi-purpose lighters fail to comply with the
standard in a manner that creates a substantial risk of injury to the public.
2. Use and sharing of collected information and impact on privacy
The Standard has recordkeeping and reporting requirements that will allow the staff to
ensure that lighters comply. The Standard also requires manufacturers and importers to
provide a certificate of compliance to any distributor or retailer to whom the lighters are
delivered. Records must be kept in the U.S. and be available for inspection by the

Commission’s staff within 48 hours. Commission staff will use this information to
identify products that either do not comply with the Standard or that have not been
properly certified.
Based on a review of the proposed information collection activities, staff has found that
the Privacy Act does not apply because no electronic information system or records
subject to the Privacy Act will be created. No system of records is created because no
information about customer sales will be retrieved by the Commission from firms.
3. Use of information technology (IT) in information collection
Consideration has been given to the use of improved information technology. The
records must be kept on paper, microfiche, or similar media that can be directly
examined. Production records, on the other hand, may be kept on these media or on
computer tape or other retrievable media.
4. Efforts to identify duplication
Every manufacturer’s and importer’s responsibilities under the rule relate to their
products. In some instances, the manufacturer may sell the same product to numerous
importers. The manufacturer may pay for and conduct testing and provide the test data
and results to the importers who are their customers. The importer may elect to rely on
the data and file it with their report. Since the information collected applies to specific
lighter models, this eliminates the need for duplicate testing and test report preparation.
5. Impact on small businesses
The methods used to minimize the burdens on small businesses are described in the Final
Regulatory Flexibility Analysis, 64 FR 71864, dated December 22, 1999.
6. Consequences to Federal program or policy activities if collection is not conducted or
is conducted less frequently
The collection of information and reporting requirements apply only to specific occasions
relating to each individual lighter model. Therefore, collecting information less
frequently would either omit certain importers or lighter models, or supply insufficient
information concerning particular models.
7. Special circumstances requiring respondents to report information more often than
quarterly or to prepare responses in fewer than 30 days
Except as necessary to comply with 15 U.S.C. § 2063, the reporting is not required more
often than quarterly. Records are kept for 3 years after the events to which they relate.
Thus, qualification test records and lighter specifications need to be kept until 3 years
after the production of the model has ceased.

8. Agency’s Federal Register Notice and related information
A Federal Register notice announcing CPSC’s intent to request an extension of approval
of information collection requirements was published on July 23, 2020. No comments
were received.
9. Decision to provide payment or gift
No payments or gifts are made to any respondents.
10. Assurance of confidentiality
Any information required to be submitted that the manufacturer or importer claims to be
confidential is subject to procedures for withholding confidential information from public
disclosure set forth at 16 C.F.R. Part 1015, subpart B. See 16 C.F.R. § 1212.17(c).
11. Questions of a sensitive nature
Other than trade secret or other confidential business information, these requirements do
not involve information of a sensitive nature.
12. Estimate of hour burden to respondents
Firms subject to Commission rules may incur costs associated with various kinds of
activities, depending on the requirements of each rule. Firms may conduct tests, maintain
and retrieve records, provide written reports or certificates, prepare correspondence in
response to Commission inquiries, or perform other tasks in order to establish
compliance. Varying proportions of professional and clerical time may be spent in the
performance of these tasks. Costs attributable specifically to activities related only to
Commission rules are difficult to identify, since many of the relevant activities, such as
testing and recordkeeping, occur during a firm’s normal course of business. However, an
average cost range can be applied to the estimated numbers of hours needed to complete
the necessary tasks. This yields a very rough approximation of the dollar costs to industry
(excluding such factors as destructive product testing and potential product-line
diversion).
The cost of the rule’s testing, reporting, recordkeeping, and other certification-related
provisions is comprised of time spent by testing organizations on behalf of manufacturers
and importers, and time spent by firms to prepare, maintain, and submit records to
CPSC. There are currently an estimated 62 firms that import, distribute and/or sell multipurpose lighters in the United States, which is a subset of the approximately 145 firms
total that may import lighters in the future. With a few exceptions, most manufacturers
and importers have more than one model, currently ranging from 1 to 130 models for
each firm. Based on past experience, an estimate of two models per firm is a reasonable
number to use for calculating burden. Each manufacturer would spend approximately 50
hours per model. The average annual burden estimate of 50 hours is based on the

following assumptions, which are based, among other things, on staff’s experience with
testing requirements and staff’s review of records that have been filed with the
Commission:
Recordkeeping
• Estimated Annual Testing Time per Firm – 30 hours for testing per model.
• Data maintenance – 10 hours to create, record, and enter test data into a
computerized dataset; 5 hours for annual review/removal of records for a total of
15 hours per model.
Reporting
• Respond to CPSC records request, 5 hours per year per model.
Therefore, the total annual estimate of complying with the requirements of the rule is
approximately 6,200 hours (62 firms x 2 models x 50 hours = 6,200 total hours
requested). The annualized cost to respondents for the information collection is $435,426
(6,200 hours x $70.23/hr), as estimated from total compensation data available from the
U.S. Bureau of Labor Statistics (Employer Costs for Employee Compensation, March
2020, total compensation of all management, professional, and related occupations in
goods-producting industries).
13. Estimate of total annual cost burden to respondents
There are no costs to respondents beyond those presented in Section A.12. There are no
operating, maintenance, or capital costs associated with the collection.
14. Estimate of annualized costs to Federal government
The estimated annual cost of the information collection requirements to the Federal
government is approximately $340,712. This sum includes 24 staff months (two fulltime-equivalent [FTE] staff years) including agency enforcement, field and travel costs
expended to administer the rule annually. This estimate uses an annual wage of $116,353
(the equivalent of a GS-13 Step 5 employee) which comprises 68.3 percent of the costs of
compensation, with the remaining 31.7 percent added for benefits (U.S. Bureau of Labor
Statistics, “Employer Costs for Employee Compensation,” March 2020, Table 2,
percentage of wages and salaries for all civilian management, professional, and related
employees) for total annual compensation of $170,356 FTE.
15. Program changes or adjustments
More U.S. importers are buying from foreign manufacturers rather than developing and
testing their own lighters, each U.S. importer is still required to report to CPSC. The
foreign manufacturers are paying for the child-testing to entice companies to buy from
them.
16. Plans for tabulation and publication

Not applicable, there are no plans to tabulate or publish the information. Because CPSC
does not plan to disseminate the data collected, the requirements of the OMB and the
CPSC Information Quality Guidelines do not apply.
17. Rationale for not displaying the expiration date for OMB approval
Not applicable.
18. Exception to the certification statement
Not applicable.
B. Collection of information will not employ statistical methods.