omnidirect-cb-baseSupStmnt 2022

Information Collection Request (ICR)
Supporting Statement for the Standard for Omnidirectional CB Base Antennas
OMB Control Number 3041-0006

A. Justification
1.
Information to be collected and circumstances that make the
collection of information necessary
In 1982, the Consumer Product Safety Commission estimated that during
the period from 1979 to 1981, about 45 to 50 persons each year were
electrocuted when an omnidirectional citizens band base station antenna came
into contact with overhead electrical power lines while the antenna was being
erected or removed from its site. The Commission also estimated that during the
same period more than 25 persons each year sustained serious injuries when
omnidirectional citizens band base station antennas contacted overhead power
lines.
To address these risks of death and injury, the Commission issued the
Safety Standard for Omnidirectional Citizens Band Antennas in 1982. The
standard contains performance tests to demonstrate that an antenna will not
transmit a harmful electric current if it contacts an electric power line with a
voltage of 14,500 volts phase-to-ground. The standard is codified at 16 C.F.R.
Part 1204, Subpart A.
Certification regulations implementing the standard require manufacturers,
importers, and private labelers of antennas subject to the standard to perform
tests to demonstrate that those products comply with the standard, and to
maintain records of those tests. The certification regulations are codified at 16
C.F.R. Part 1204, Subpart B.
2.

Use and sharing of collected information

The Commission uses the information compiled and maintained by
manufacturers, importers, and private labelers of antennas subject to the
standard to determine whether the products they produce or import comply with
the requirements of the standard. The Commission also uses this information to
obtain corrective actions if omnidirectional citizens band base station antennas
fail to comply with the standard in a manner that creates a substantial risk of
injury to the public.

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3.

Use of information technology (IT) in information collection

Manufacturers, importers, and private labelers of antennas that are
subject to the standard may establish and maintain the records required by the
certification regulations by any appropriate means, including automated,
electronic, mechanical, or other forms of information technology. Those records
must be maintained for at least three years from the date of creation of the
records, and must be made available to any designated employee of the
Commission upon request.
4.

Efforts to identify duplication

Until the Commission issued the Safety Standard for Omnidirectional
Citizen Band Base Station Antennas, the information required by the certification
regulations did not exist. No source exists for the information required by the
certification regulations other than manufacturers, importers, and private labelers
of antennas subject to the standard.
5.

Impact on small businesses

In 1993, the Commission reviewed the Safety Standard for
Omnidirectional Citizens Band Base Station Antennas and certification
regulations in accordance with provisions of section 610 of the Regulatory
Flexibility Act (5 U.S.C. 610). The Commission concluded that the standard and
certification rules did not have a significant economic impact on a substantial
number of small businesses (March 24, 1993, 58 FR 15815).
6.
Consequences to Federal program or policy activities if collection is
not conducted or is conducted less frequently
When the Commission issued the standard, it estimated that its
requirements could be expected to prevent approximately eight deaths and eight
other injuries a year. If manufacturers, importers, and private labelers of
antennas subject to the standard did not perform the testing required by the
standard and certification regulations, the number and severity of injuries
resulting from accidental contact of omnidirectional citizens band base station
antennas with overhead powerlines could increase.
If manufacturers, importers, and private labelers did not establish and
maintain the records of testing required by the certification regulations, the
Commission could obtain that information only by collecting samples of antennas
and performing its own tests of those samples.
The certification regulations allow manufacturers, importers, or private
labelers to use either the tests in the standard or other reasonable test
procedures. Those regulations also allow the manufacturer to define production
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lots and sample from those production lots in any manner that provides a high
degree of assurance that all antennas manufactured during the applicable
production interval will pass the standard.
7.
Special circumstances requiring respondents to report information
more often than quarterly or to prepare responses in fewer than 30 days
The collection of information in the standard and certification regulations is
not conducted under any of the conditions described in item seven.
8.

Agency’s Federal Register Notice and related information

A Federal Register Notice was published May 11, 2022. 0 comments were
received.
9.

Decision to provide payment or gift

The Commission does not provide any payment or gift to firms which
perform the testing and maintain the records required by the standard and
certification regulations.
10.

Assurance of confidentiality

If the Commission collects any information from a manufacturer, importer,
or private labeler from records that are required by the certification regulations
and the firm claims that such information is trade secret or confidential business
information, that information is subject to the Commission’s procedures for
withholding confidential information from public disclosure. Those procedures
are codified at 16 C.F.R. Part 1015, Subpart B. If such information is requested
under the provisions of the Freedom of Information Act, the manufacturer,
importer, or private labeler is notified and given the opportunity to respond before
the Commission releases the information.
11.

Questions of a sensitive nature

The standard for omnidirectional citizens band base station antennas and
certification regulations does not require manufacturers, importers, or private
labelers to provide any information of a sensitive nature.
12.

Estimate of hour burden to respondents

The Commission staff has identified 10 firms that may be subject to the
testing and recordkeeping requirements of the certification regulations. The
Commission staff estimates further that the annual testing and recordkeeping
burden imposed by the regulations on each of these firms on average is
approximately 220 hours. Thus, the total annual burden imposed by the
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certification regulations on all manufacturers, importers and private labelers of
omnidirectional citizens band base station antennas is about 2,200 hours.
The Commission staff estimates that the average hourly cost to reporting
firms for the time required to perform the required testing and maintain the
required records is about $71.82, based on the reported total compensation for
management, professional, and related employees in goods-producing private
industries. 1 Total annual cost to the industry of is approximately $158,000
($71.82 times 2,200 hours).
13.

Estimates of other total annual cost burden to respondents or
recordkeepers

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 the federal government

Approximately 40 staff hours are needed for agency employees to
examine and evaluate the information, as needed, for compliance activities.
Estimated cost to the federal government is based on performance of this work
by employees paid at a GS-12 Step 5 pay rate of $101,813 per year. 2 According
to the most recent Employer Costs for Employee Compensation, this represents
approximately 68.4 percent of total compensation for management, professional
and related occupational groups. 3 Therefore, total compensation for an employee
at the GS-12 Step 5 pay rate will have an annual value of $148,849 and the
hourly compensation rate would be $71.56. The annual cost to the federal
government of the collection of information is therefore estimated to be about
$2,862 ($71.56 x 40 hours).
15.

Program changes or adjustments

No change has been made to the collection of information in the Safety
Standard for Omnidirectional Citizens Band Base Station Antennas and
certification regulations since it was last approved by OMB.
There is one change due to agency estimates of burden. CPSC estimates
that there are now 10 firms that may be subject to testing and recordkeeping
U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” September
2021, Table 4. Private industry workers by occupational and industry group:
https://www.bls.gov/news.release/ecec.t04.htm.
2
2022 General Schedule (GS) Locality Pay Tables for Washington-Baltimore-Northern Virginia,
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/pdf/2022/DCB.pdf.
3
U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” September
2021, Table 2, https://www.bls.gov/news.release/ecec.t02.htm.
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requirements, rather than seven. Therefore, CPSC estimates the total burden for
the collection has increased to 2,200 hours.
16.

Plans for tabulation and publication

The Commission will not publish the results of this collection of
information.
17.

Rationale for not displaying the expiration date for OMB approval

The Commission does not seek to avoid display of the expiration date for
the OMB approval of this collection of information.
18.

Exception to the certification statement
Not applicable.

B. Collections of Information Employing Statistical Methods
Not applicable.

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