Letter to Sharon Block from Robert Shriver

Sharon Block
Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear Ms. Block:
Pursuant to Office of Management and Budget (OMB) procedures established at 5 C.F.R. Part
1320, Controlling Paperwork Burdens on the Public, I request that the proposed information
collection, the Certification of Vaccination Common Form, OMB Control No. 3206-NEW, be
processed as an Emergency Clearance Request in accordance with 5 C.F.R. §1320.13,
Emergency Processing.
I have determined that this information must be collected prior to the time periods established
under Part 1320 of the regulations and that this information is essential to implement agencies’
health and safety measures included within recent Centers for Disease Control and Prevention
and Safer Federal Workforce Task Force Guidance. 1 Government agencies have an urgent need
to request attestation of vaccination status from individuals entering Federal buildings and
workspaces. Applying regular Paperwork Reduction Act clearance procedures is likely to cause
harm because of the threat of COVID-19 exposure and transmission. 2
Therefore, the Office of Personnel Management requests a 180-day emergency clearance to
establish the Certification of Vaccination Common Form allowing individuals to attest to their
vaccination status in advance of or upon entry to Federal buildings and workplaces. During the
180-day approval, OPM and the Safer Federal Workforce Task Force will work to establish a
See generally Executive Order 13991: Protecting the Federal Workforce and Requiring
Mask-Wearing (January 20, 2021); Executive Order 13994: Ensuring a Data-Driven Response to
COVID-19 and Future High-Consequence Public Health Threats (January 21, 2021). See also
Executive Order 12196: Occupational Safety and Health Programs for Federal Employees, as
amended (February 26, 1980) (“The head of each agency shall . . . [f]urnish to employees places
and conditions of employment that are free from recognized hazards that are causing or are likely
to cause death or serious physical harm”).
2
Moreover, I have determined that because of the nature of the public health emergency
and the urgent need for this collection, it is impracticable for OPM to consult in advance with
interested agencies and members of the public in order to minimize the burden of the collection
of information pursuant to 5 C.F.R. 1320.13(c). OPM estimates that this collection will entail
minimal public burden (two minutes per response). OPM will consult with other agencies
through the Safer Federal Workforce Task Force.
1

regular clearance submission of this information collection request under the Paperwork
Reduction Act procedures. As this request for approval concerns an urgent safety need, OPM is
also seeking OMB’s approval to waive the need for the Federal Register Notices otherwise
required by 5 C.F.R. 1320.5(a)(1)(iv) and 1320.8(d)(1) prior to publication and implementation
of this disclosure.
We would appreciate if you could please provide an approval/disapproval determination of
this request to collect information under an emergency clearance by close of business on
Friday, August 6, 2021.
Sincerely,

Robert H.
Shriver, III

Digitally signed by Robert H.
Shriver, III
Date: 2021.08.05 10:20:09
-04'00'

Robert H. Shriver, III
Associate Director
Employee Services
Enclosures