OSHA OUTREACH TRAINING PROGRAM AND OSHA TRAINING INSTITUTE EDUCATION
CENTERS PROGRAM FORMS
OMB Control Number: 1218-0262
Expiration Date: March 31, 2024
SUPPORTING STATEMENT FOR
THE INFORMATION COLLECTION
REQUIREMENTS IN THE
OSHA OUTREACH TRAINING PROGRAM AND
OSHA TRAINING INSTITUTE EDUCATION
CENTERS PROGRAM FORMS
OFFICE OF MANAGEMENT AND BUDGET (OMB)
CONTROL NO. 1218-0262 (March 2024)
This is an extension request for a currently approved data collection.
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.
Section 21 of the Occupational Safety and Health Act of 1970 (OSH Act or Act) authorizes the Occupational Safety and Health Administration (OSHA or agency) to conduct education and training courses directly or through grants and contracts. These courses must ensure an adequate number of qualified personnel to fulfill the purpose of the Act; provide them with short-term training; inform them of the importance and proper use of safety and health equipment; and train employers and employees to recognize, avoid, and prevent unsafe and unhealthful working conditions.
Consistent with this authority, the agency created two educational programs: the OSHA Outreach Training Program and the OSHA Training Institute (OTI) Education Centers Program.
Since 1971, the OSHA Outreach Training Program has rapidly disseminated basic safety and health information to workers. Today, the Outreach Training Program provides awareness training to workers on recognizing, controlling, and preventing occupational safety and health hazards. Trainers who successfully complete an OSHA Trainer course are authorized to conduct 10- and 30-hour outreach training courses on occupational safety and health hazards. Students who complete these voluntary courses receive a student course completion card from the agency.
During the 1980s, the number of requests for training from private sector personnel and non-OSHA Federal personnel increased substantially, and the demand eventually exceeded the capacity of the OSHA Training Institute. To meet the increased demand in October 1992, OSHA began partnering with nonprofit training and educational institutions, thus establishing the OSHA Training Institute (OTI) Education Centers Program. Partnering organizations were selected through a series of national competitions. The program currently has 26 OTI Education Centers comprised of 37 separate member organizations.
To be a participant in one of the educational programs, an individual or organization must provide the Division of Training Programs and Administration (DTPA), located within the Office of Training and Education (OTE), with specific information regarding organizational or individual experiences and program data.
The Office of Training and Education is responsible for policy guidance, management, and administration of the OSHA Outreach Training Program and the OTI Education Centers Program. OTE collects and reports student training information monthly.
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.
OSHA Training Institute Education Center – Information Collection
A. Application to become an OSHA Training Institute Education Center (OTI Education Center)
Information Collected: Identifying data such as name; organization; address; consortium partners, if applicable; consortium partner address(es), if applicable; authority to apply; evidence of nonprofit status; status as a training organization; relevant occupational safety and health training experience; relevant curriculum development experience; administrative and occupational safety and health staff qualifications; ability to deliver OSHA OTI Education Center courses; description of training and testing facilities; description of training experience; copies of catalogues and other recruiting materials; description of systems to administer and monitor the OSHA Outreach Training Program; description of the applicant’s recruitment, marketing, and registration plans; description of training facility’s accessibility to transportation and lodging accommodation, and pricing of those services; information on host site locations; description of organization’s ability to provide off-site courses; description of administrative capabilities to manage an OTI Education Center; ability to complete required reporting requirements; description of organizations ability to conduct course evaluations; and copies of the organization's non-discrimination policies for staff and students. (See Attachment A, copy of Federal Register Notice - OSHA Training Institute Education Center; Notice of Competition and Request for Applications; April 18, 2022.)
Purpose: This information is collected to obtain basic information about the applicant organization and application, to evaluate the qualifications of the applicants and their ability to serve the regional population, and to determine their ability to conduct OSHA courses for private and public sector personnel and federal personnel from agencies other than OSHA. To evaluate the applicant organization’s competence to provide the proposed training (including the qualifications of the personnel to manage and implement the training).
B. OTI Education Centers Monthly Summary Report for the OTI Education Centers and Outreach Training Program Monthly Summary Report (Attachment B)
B1. Information Collected for OTI Education Center Courses conducted within the OTI Education Center’s OSHA Region: OTI Education Centers must submit monthly information to the Office of Training and Education, Division of Training Programs and Administration, on the OTI Education Center’s activities including: course numbers/titles, OTI Education Center name, dates and locations of training courses (training location, city, state, or country if outside the U.S.), class start and end dates, number of students trained, student contact hours, course lead instructor, instructional staff, number of students attempting exam, number of students taking re-test, number of students passing exam, average test score, and demographic student breakdown (Federal OSHA Personnel, Other Federal Agency Personnel, State OSHA Personnel, Other State Personnel, Private Sector Personnel, and Foreign Students).
B2. Information Collected for the Outreach Training Program classes: OTI Education Centers receive requests from Outreach trainers for cards to provide to their students who have successfully completed one of the OSHA Outreach Training Program courses (see item D, Outreach Training Program Report Forms). With this information, the OTI Education Centers report monthly the number of classes conducted and the number of students trained for each Outreach Training Program (Construction, General Industry, Maritime, and Disaster Site Worker) class. OTI Education Centers process requests and print Outreach Training Program trainer and student course completion cards.
B3. Information Collected for the Outreach Training Program Monitoring: OTI Education Centers are required to perform record and activity audits on Outreach trainers. The OTI Education Centers report monthly the date the monitoring activity was initiated and completed, the basis and type of monitoring activity, the number of classes included in the records audit, the type of training class observed, training hours observed, trainer information (name and address), audit results and follow-up actions. OSHA uses this information to monitor Outreach Training Program activity and deter fraud.
B4. Information Collected for OTI Education Center Courses conducted out of the OTI Education Center’s OSHA Region: OTI Education Centers must submit monthly information on the OTI Education Center’s upcoming activities outside of the OSHA Region in which they are located, including course numbers/titles, OTI Education Center name, dates and locations of training courses (training location city, state, or country, if outside the U.S.), number of students projected to be trained, student contact hours, course lead instructor, other instructor name(s), point-of-contact at OTI Education Center, the submission date, and comments.
B5. Information Collected for Outreach Training Program Exception Requests: Authorized Outreach trainers may request an exception to the Outreach Training Program Requirements and Procedures to the OTI Education Centers. The OTI Education Center’s monthly summary report reports these exception requests to OTE. Information collected includes date of request, trainer name, organization, Outreach Training Program course, course state and end date, type of exception (class time extension, class size, alternative training method, and out of OSHA’s geographic jurisdiction), OTI Education Center’s decision, date of decision, and additional comments.
Purpose: These collections are rooted in program management, oversight, and reporting. To monitor training activity and evaluate training conducted versus established goals and objectives of the Agency. To submit data for the annual workload summary for comparison with projected milestones. To monitor the implementation of new performance measures; track performance outcomes and efficiency measures; measure monthly, established annual and long-term performance targets, and information to prepare annual reports to Congress.
C. Attendance Documentation for OTI Education Centers
Information Collected: The following information is collected for each class: daily sign-in sheets (student first name, middle initial, and last name; course name and number; date; location (city and state the course was conducted); instructor name and signature, the name of the OTI Education Center who sponsored or conducted the training, and course prerequisite information (student employment history, copy of current Outreach trainer card or copy of official transcript), if applicable.
OSHA believes the daily sign-in sheet is not within the definition of “information” under 5 CFR 1320.3(h)(1). The daily training sign-in sheet does not entail additional burden other than to identify the student, the date, and the course name and signature of the trainer. However, OTI Education Centers must also submit the prerequisite information completed and submitted by the student to the OTI Education Center, if applicable, which does require a burden on the part of the OTI Education Center.
Purpose: These collections are additionally used for program management and oversight. To verify student attendance as reflected in monthly summary reports.
D. Statement of Compliance with Outreach Training Program
Requirements
(Attachment C)
Information Collected: Trainer signature, date, typed or printed name, name of OSHA Outreach Training Program course and course dates (to be completed by OTI Education Center), and name of OTI Education Center (completed by the OTI Education Center) (Attachment C, Statement of Compliance with Outreach Training Program Requirements).
Purpose: Execution of the Statement of Compliance serves as a self-certification of the authorized Outreach trainer’s knowledge of and compliance with the Outreach Training Program Requirements and procedures and improves processing efficiency while maintaining program integrity and deterring fraud.
E. Outreach Training Program Authorized Trainer List (Attachment D)
Information Collected: Authorizing OTI Education Center, OTI Education Center identifying prefix number, authorized Outreach trainer name, mailing address, phone number, email address, opt-in to be listed on OSHA’s website, languages offered, website address, trainer industry program authorization card number and date issued.
Purpose: This information is collected to maintain a list of authorized Outreach trainers. This list is maintained for investigation purposes and to assist individuals who are searching for Outreach Training Program courses available in their vicinity. The OTI Education Centers provide this list monthly to OTE.
F. Instructor and Staff Resumes
Note: This requirement includes anyone who may be assigned to conduct OSHA classes, contractor, subcontractor, employee, adjunct professor, etc.
Information Collected: This information is collected from the OTI Education Centers and includes résumés of current staff and position descriptions and minimum hiring qualifications for all positions, whether filled or vacant, that may be assigned to conduct OSHA classes. Work history, education, and other qualifications such as Certified Safety Professional (CSP), Professional Engineer (PE), or Certified Industrial Hygienist (CIH).
Purpose: This information is collected for program management and oversight and to obtain the instructors’ knowledge and experience with OSHA standards and their application to hazards and hazard abatement.
G. Course Curriculum upon Request by OSHA from OTI Education Centers
Information Collected: Curriculum-related content, manuals, and test questions.
Purpose: This information is collected to monitor the program content and ensure quality and consistency. The materials are helpful in developing future curricula and meeting the needs of the agency’s product/service users.
OSHA OUTREACH TRAINING PROGRAM
H. Outreach Training Program Report Forms
Note:
This requirement includes Construction, General Industry, Maritime,
and Disaster Site Workers. (For more information, see the attached
Outreach Training Report for Construction (Attachment E), the
Outreach Training Report for General Industry (Attachment F), the
Outreach Training Report for Maritime Industry (Attachment G), and
the Outreach Training Program Report for Disaster Site Worker
(Attachment H).
Information Collected: Trainer information (name, ID number, address, phone, email), Authorizing Training Organization, most recent trainer course, trainer card expiration date, type of course conducted (i.e., 10- or 30-hour construction; 10- or 30-hour general industry; 10- or 30-hour maritime; or disaster site worker); course information (indicate whether the course was offered in Spanish, to Youth [age 18 or less], indicate the language if other than English or Spanish, training location and/or whether training conducted was related to an OSHA Alliance or Partnership); number of students, training site information (address, type of location); course duration (start and end times and dates), sponsoring organization, first and last name of students, trainer signature and date signed.
The following information is additionally requested to determine where student cards should be sent:1 company name/department; address; city; state; zip; phone number; extension; email; copy of trainer card; topic list and time spent on each required, and whether it was a required, elective, or optional topic.
Each Outreach training (i.e., the 10- and 30-hour construction, 10‑ and 30-hour general industry, 10- and 30-hour maritime, and disaster site worker) has a set of required, elective, and optional course topics. Because training topics covered and the length of time for each topic area may vary, the Outreach Training Program Report must be completed following each course conducted.
To maintain program integrity and deter fraud, OSHA Outreach trainers are required to maintain records which include student sign-in sheets, student addresses, and a copy of the documentation sent in to request student completion cards, including a list of the topics taught and the amount of time spent on each topic; a copy of the student course completion cards, a list of guest trainers and additional authorized Outreach trainers that instructed in the course.
Purpose: To monitor training activity and evaluate training conducted versus established goals and objectives of the agency. These forms are necessary to review compliance with the Outreach Training Program Requirements and to request student course completion cards from the authorized Outreach trainer(s). In addition, this information is needed to improve processing efficiency while maintaining program integrity and deterring fraud.
I. Online Outreach Training Program Report (Attachment I)
Information Collected: Trainer information (name, ID number, address, phone, email), Authorizing Training Organization, most recent trainer course, trainer card expiration date, course information (indicate whether the course was offered in Spanish, to Youth [age 18 or less], indicate the language if other than English or Spanish, training location and/or whether training conducted was related to an OSHA Alliance or Partnership); the number of students, type of course conducted (i.e., 10- or 30-hour construction; 10- or 30-hour general industry); course duration (start and end times and dates), trainer signature and date signed. The following information is requested to determine where student cards should be sent:2 company name/department; address; city; state; zip; phone number; extension; email; copy of trainer card; topic list and time spent on each required, elective, or optional topic.
Purpose: To monitor online training activity and evaluate training conducted versus established goals and objectives of the agency. This document is necessary to review compliance with the Outreach Training Program Requirements and procedures and to request student course completion cards by the authorized Outreach trainer(s).
J. Outreach Online Training Certification Statement
Information Collected: Online organization and type of Outreach Training Program and changes made since the last certification that their online program was current.
Purpose: To ensure the program is periodically reviewed and updated to reflect current OSHA Outreach Training Program Requirements and procedures.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
OSHA has endeavored to make collection of the above-referenced information easy for program participants to complete and submit. Whenever possible, the agency makes efforts to allow electronic submissions, to increase efficiency and consistency while minimizing participant burden.
Currently, program participants have the option to complete and submit the following data electronically:
A. OTI Education Center Monthly Summary Report for OTI Education Centers and Outreach Training Program Monthly Summary Report
B. Statement of Compliance with Outreach Training Program Requirements
C. Outreach Training Program Report Forms (includes Construction, General Industry, Maritime and Disaster Site Worker Outreach Programs)
D. Online Outreach Training Program Report
E. Outreach Trainer Lists
F. Outreach Online Training Certification Statement
G. Instructor and Staff Résumés
H. Course Materials upon requests from OTI Education Centers
Due to the nature of the material requested, program participants are required to manually submit the following:
Application to become an OTI Education Center
Attendance Documentation for OTI Education Centers (including student signatures)
OTI Education Center Course Curriculum
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use of the purposes described in Item A.2 above.
The information collection requirements in these regulations are specific to each student, trainer, or OTI Education Center involved, and no other source or agency duplicates these requirements. The required information is available only from these Centers. Currently, there is no indication that any alternate source is available.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The collection of this information does not have a significant economic impact on a substantial number of small entities.
6. Describe the consequences to Federal Program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Without this information, the agency would be unable to determine the extent to which OSHA’s overall training goals and objectives are being met.
Additionally, the number of workers receiving safety and health training via the OSHA Outreach Training Program may decline and the rate of worker accidents, injuries, and even death will likely increase. Without monitoring and reporting requirements, the Program may experience additional fraudulent activity.
7. Explain any special circumstance(s) that would cause information collection to be conducted in a manner:
(1) Requiring respondents to report information to the agency more often than quarterly;
(2) Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
(3) Requiring respondents to submit more than an original and two copies of any document;
(4) Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
(5) 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;
(6) Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
(7) That includes a pledge of confidentiality 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
(8) Requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.
There are several instances in which information collections would be conducted more than quarterly. Data collected monthly from OTI Education Centers provide appropriate levels of program oversight and an opportunity to reconcile reporting discrepancies in a timely manner. Additionally, trainer data is collected as courses are delivered to verify course information and ensure timely dissemination of student completion cards to course attendees. Finally, outreach trainer lists are required to ensure workers are informed where they can obtain safety and health training and to conduct investigations into alleged fraudulent activity.
OTI Education Centers’ record retention practices are based on their organizations’ policies. Outreach Training Program records are retained by OSHA, the OTI Education Centers, and the authorized Outreach trainers for five years to ensure the identification of students and records associated with a trainer during the trainer’s authorization period. This also ensures students can obtain replacement cards when they are lost, damaged, or misplaced.
8. If applicable, provide a copy and identify the date and page number of publications in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instruction and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
As required by the Paperwork Reduction Act (44 U.S.C. 3506(c)(2)(A)), OSHA published a notice in the Federal Register on December 28, 2023 (88 FR 89730), soliciting comments from the public and other interested parties on its proposed revision of the collection of information requirements specified in OSHA Training Institute Education Centers Program and the OSHA Outreach Training Program under Docket No. OSHA-2009-0022. This notice is requesting public comments from the public and other interested parties on its proposed extension of this collection of information. The notice was part of a preclearance consultation program that provides interested parties with the opportunity to comment on OSHA’s request for an extension by the Office of Management and Budget (OMB) of a previous approval of the collections of information found in the standard.
The agency did receive one public comment on February 6, 2024, from an Anonymous public commenter under Docket ID number OSHA-2009-0022-0029 in response to this notice. The commenter stated:
“The issue(s) with outreach training that I have experienced is due to online training for OSHA 10/30 hour. The online training is so inexpensive that employers and education programs like apprenticeships struggle to pay for in-person instruction when online on-demand training is a fraction of the cost. It has also resulted in less trainers as we have to jump through hoops to give a training online or with less than 3 individuals, but on-demand trainings are not limited to this. The issue with the training is not the lack of documentation of the trainers but the way they are being trained. These online companies offering the training simply funnel people through a canned training rather than adjust the training to the audience or to solicit participation and engage the students. The students get very little if anything from the training if it is even them taking the training. These are all issues that normal instructors struggle with. Employers/programs have ensured the individuals have received their cards and that's where things end. It can be a checklist type of thing. The only way to truly change that is to change the way training is offered. Remove the on-demand options for training and require all training to be in-person with exceptions requiring the same for all.”
The agency created two educational programs the OSHA Outreach Training Program and the OSHA Training Institute (OTI) Education Centers Program. During the 1980s, the number of requests for training from private sector personnel and non-OSHA Federal personnel increased substantially, and the demand eventually exceeded the capacity of the OSHA Training Institute. To meet the increased demand in October 1992, OSHA began partnering with nonprofit training and educational institutions, thus establishing the OSHA Training Institute (OTI) Education Centers Program. Partnering organizations were selected through a series of national competitions. The program currently has 26 OTI Education Centers comprised of 37 separate member organizations.
Through its national network of OSHA Training Institute (OTI) Education Centers, qualified individuals can become authorized OSHA Outreach trainers. Authorized OSHA Outreach Trainers deliver 10- and 30-hour outreach classes to workers in construction, general industry, maritime, and 15-hour classes for disaster site workers. To become an Authorized Outreach Trainer, interested individuals must meet industry safety experience requirements and complete a training course in the applicable OSHA standards and a trainer course to become authorized.
The purpose of collecting this information is to determine whether the trainer is authorized and whether the training was properly completed. This information is provided to the Division of Training Programs and Administration (DTPA), located within the Office of Training and Education (OTE), with specific information regarding organizational or individual experiences and program data. The agency monitors the training activities and evaluates the training that is conducted whether it is in-person or online.
OSHA appreciates your comment regarding your experience with the online outreach training and your suggestion on ways of improving on how the program is offered. However, introducing new policies and procedures for this data collection is outside of the scope of this notice, which is meant to extend the existing collections of information for another three years.
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 may preclude consultation in a specific situation. These circumstances should be explained.
OSHA’s Office of Training and Education OTE) is responsible for policy guidance, management, and administration of the OSHA Outreach Training Program and the OTI Education Centers Program. OTE collects and reports student training information monthly. OTE allows the opportunity for the respondents of both programs to provide feedback as needed.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration 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, regulations, or agency policy.
The agency provides no assurance of confidentiality regarding the information that is collected from OTI Education Center applicants or data received from the OTI Education Centers.
Participants understand that if approved to participate in the OSHA Training Institute Education Center or the OSHA Outreach Training Program, their application/information becomes public record. Information collected in the application concerning financial disclosures remains confidential and is not available to the public.
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 these regulations require the collection of 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 and aggregate the hour burdens.
Provide estimates of annualized costs 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.
Wage Rates
The agency determined the wage rate from mean hourly wage earnings to represent the cost of employee time. For the relevant standard occupational classification category, OSHA used the wage rates reported in the Bureau of Labor Statistics (BLS), U.S. Department of Labor, Occupational Employment and Wage Statistics (OEWS), May 2022 [last accessed: November 9, 2023]. (OEWS data is available at https://www.bls.gov/oes/tables.htm. To access a wage rate, select the year, “Occupation Profiles,” and the Standard Occupational Classification [SOC] Code).
To derive the loaded hourly wage rate presented in the table below, the agency used data from the OEWS, as described in the paragraph above. Then, the agency applied to the wage rate a fringe benefit markup from the following BLS release: Employer Costs for Compensation News Release text; released 10:00 AM (EDT), September 12, 2023 (https://www.bls.gov/news.release/archives/ecec_09122023.htm). BLS reported that for private industry workers, fringe benefits accounted for 29.4% of total compensation, and wages accounted for the remaining 70.6%. To calculate the loaded hourly wage for each occupation, the agency divided the mean hourly wage rate by 1 minus the fringe benefits.
Table 1, below, summarizes of how the wage rate estimate was derived for the information collection requirements specified in the standard.
Table 1 – Estimated Wage Rate |
||||
Occupational Title |
SOC Code |
Mean Hour Wage Rate (A) |
Fringe |
Loaded Hourly Wage Rate |
Director |
11-1021 |
$59.07 |
.294 |
$83.67 |
Training Coordinator |
25-0000 |
$30.41 |
.294 |
$43.07 |
Admin Asst. |
43-9061 |
$19.78 |
.294 |
$28.02 |
Burden Hour and Cost Summaries
OSHA Training Institute Education Center
A. Application to become an OSHA Training Institute Education Center
OSHA regularly publishes a notice announcing the opportunity for interested nonprofit organizations to become an OTI Education Center. Contracted Centers may extend their authorization with OSHA one time, for an additional five years, without submitting a new application if they met or exceeded all performance criteria in the previous five years.
In 2022, OTE received 18 applications, including four from new organizations. Fourteen existing OTI Education Centers applied based on their performance or changes in consortium partners. As OSHA only publishes notices every five years, for purposes of the burden calculation, the agency annualized the number of applications to four (18 divided by 5 years, rounded).
The agency estimates that one Director, one Training Coordinator, and two Administrative Assistants will review each application, with the Director and Training Coordinator spending 10 hours on each application and the Administrative Assistants spending 40 hours reviewing each application. Therefore, the burden calculations are as follows:
Burden hours: 4 applications x 10 hours = 40 hours
Cost: 40 hours x $83.67 = $3,346.80
Burden hours: 4 applications x 40 hours = 160 hours
Cost: 160 hours x $43.07 = $6,891.20
Burden hours: 4 applications x 10 hours = 40 hours
Cost: 40 hours x $28.02 = $1,120.80
Subtotal Burden hours: 40 hours + 160 hours + 40 hours = 240 hours
Subtotal Cost: $3,346.80 + $6,891.20 + $1,20.80 = $11,358.80
B. OTI Education Center Monthly Summary Report for the OTI Education Centers and Outreach Training Program Activities.
B1. OSHA Training Institute Education Centers Reporting
OTI Education Centers must submit monthly information to the Division of Training Programs and Administration.
The agency estimates that each OTI Education Center spends approximately two hours per month preparing and submitting a summary report. One hour is allocated to a general employee earning $43.07 per hour, and the other hour is allocated to a member of the clerical staff, earning approximately $28.02. Thus, the burden calculations are as follows:
Burden hours: 26 centers x 12 reports x 1 hour = 312 hours
Cost: 312 hours x $43.07 = $13,437.84
Burden hours: 26 centers x 12 reports x 1 hour = 312 hours
Cost: 312 hours x $28.02 = $8,742.24
Subtotal Burden hours: 312 hours + 312 hours = 624 hours
Subtotal Cost: $13,437.84 + $8,742.24 = $22,180.08
B2. OSHA Outreach Training Program Reporting
OTI Education Centers collect Outreach trainer data (see item B, Outreach Training Program Reports) and process these requests. Outreach trainer requests for student cards are processed by the OTI Education Center where the Outreach trainer received training. This is reported to OTE each month by the OTI Education Center.
The agency estimates that each OTI Education Center spends approximately two hours per month preparing and submitting a summary report. One hour is allocated to a general employee earning $43.07 per hour, and the other hour is allocated to a member of the clerical staff, earning approximately $28.02. Thus, the burden calculations are as follows:
Burden hours: 26 centers x 12 reports x 1 hour = 312 hours
Cost: 312 hours x $43.07 = $13,437.84
Burden hours: 26 centers x 12 reports x 1 hour = 312 hours
Cost: 312 hours x $28.02 = $8,742.24
Subtotal Burden hours: 312 hours + 312 hours = 624 hours
Subtotal Cost: $13,437.84 + $8,742.24 = $22,180.08
B3. Information Collected for the Outreach Training Program Monitoring
OTI Education Centers are required to perform record and activity audits on authorized Outreach trainers and report the results monthly to the Directorate of Training and Education, Division of Training Programs and Administration.
The agency estimates that each OTI Education Center spends approximately one hour per month preparing and submitting a summary report. Thirty minutes (30/60 hour) is allocated to a general employee earning $43.07 per hour, and the other thirty minutes (30/60 hour) is allocated to a member of the clerical staff, earning approximately $28.02. Thus, the burden calculations are as follows:
Burden hours: 26 centers x 12 reports x 30/60 hour = 156 hours
Cost: 156 hours x $43.07 = $6,718.92
Burden hours: 26 centers x 12 reports x 30/60 hour = 156 hours
Cost: 156 hours x $28.02 = $4,371.12
Subtotal Burden hours: 156 hours + 156 hours = 312 hours
Subtotal Cost: $6,718.92 + $4,371.12 = $11,090.04
B4. Information Collected for OTI Education Center Courses conducted out of the OTI Education Center’s OSHA Region
OTI Education Centers are required to inform the Office of Training and Education’s Division of Training Programs and Administration of any class they plan to conduct out-of-region to provide OSHA advanced notice, which OSHA can use to answer questions from other OTI Education Centers and the public.
The agency estimates that each OTI Education Center spends approximately thirty minutes (30/60 hour) per month preparing and submitting a summary report. Fifteen minutes (30/60 hour) is allocated to a general employee earning $43.07 per hour, and the other fifteen minutes (15/60 hour) is allocated to a member of the clerical staff, earning approximately $28.02. Thus, the burden calculations are as follows:
Burden hours: 26 centers x 12 reports x 15/60 hour = 78 hours
Cost: 78 hours x $43.07 = $3,359.46
Burden hours: 26 centers x 12 reports x 15/60 hour = 78 hours
Cost: 156 hours x $28.02 = $2,185.56
Subtotal Burden hours: 78 hours + 78 hours = 156 hours
Subtotal Cost: $3,359.46 + $2,185.56 = $5,545.02
B.5 Information Collected for Outreach Training Program Exception Requests
OTI Education Centers are required to inform the Office of Training and Education’s Division of Training Programs and Administration of any exceptions requested submitted by authorized Outreach Training Program trainers for a change in Outreach classes including the OTI Education Center’s decision regarding each exception request.
The agency estimates that each OTI Education Center spends approximately thirty minutes (30/60 hour) per month preparing and submitting a summary report. Fifteen minutes (30/60 hour) is allocated to a general employee earning $43.07 per hour, and the other fifteen minutes (15/60 hour) is allocated to a member of the clerical staff, earning approximately $28.02. Thus, the burden calculations are as follows:
Burden hours: 26 centers x 12 reports x 15/60 hour = 78 hours
Cost: 78 hours x $43.07 = $3,359.46
Burden hours: 26 centers x 12 reports x 15/60 hour = 78 hours
Cost: 156 hours x $28.02 = $2,185.56
Subtotal Burden hours: 78 hours + 78 hours = 156 hours
Subtotal Cost: $3,359.46 + $2,185.56 = $5,545.02
C. Attendance Documentation for OTI Education Centers
The agency requires the OTI Education Centers to collect daily student sign-in sheets for each course conducted, and the agency requests this information on a quarterly basis for a random number and type of classes. On average, five classes from each OTI Education Center are audited quarterly.
Each student is required to sign their name next to their printed name on a daily sign-in sheet. OSHA also requires the instructor to sign the sign-in sheet to certify the attendance documentation is accurate. Since all OTI Education Centers have electronic registration, the printed name of registered students is readily available.
OSHA believes the daily sign-in sheet is not within the definition of “information” under 5 CFR 1320.3(h)(1). The daily training sign-in sheet does not entail additional burden other than to identify the student, course date, and course name and signature of the trainer. However, OTI Education Centers must also submit the prerequisite information completed and submitted by the student to the OTI Education Center, if applicable, which does require a burden on the part of the OTI Education Center.
OSHA assumes it will take a clerk approximately 30 minutes (30/60 hour) for the OTI Education Centers to provide the daily sign-in sheet and associated information to the agency.
Burden hours: 130 courses x 4 reports x 30/60 hour = 260 hours
Cost: 260 hours x $28.02 = $7,285.20
D. Statement of Compliance with Outreach Training Program Requirements
OTI Education Centers are the primary administrators of the OSHA Outreach Training Program. As a heightened measure to address concerns regarding Outreach trainer misconduct or fraudulent activity with the Outreach Training Program, OSHA requests each OTI Education Center to gather a Statement of Compliance from each student who completes any of the train-the-trainer courses.3 At the end of each trainer course, each student signs and returns the Statement of Compliance to the OTI Education Center and the OTI Education Center retains the Statement of Compliance as part of the Outreach trainer’s permanent file.
OSHA believes the Statement of Compliance is not within the definition of “information” under 5 CFR 1320.3(h)(1). This statement does not entail an additional burden other than that necessary to identify the respondent, the date, and the nature of the instruction (training course information). Therefore, the agency has provided no burden hours as the Statement of Compliance is not within the definition of “information” and/or generally includes customary and usual business practices.
E. Outreach Trainer List
The OTI Education Center collects information regarding all authorized Outreach trainers. All necessary information is already provided upon successful completion of the trainer or update course.
Since this information is readily available, OSHA assumes it will take a training coordinator, earning $43.07 hourly, approximately one hour per month to prepare and submit this report electronically, for each OTI Education Center.
Burden hours: 26 centers x 12 reports x 1 hour = 312 hours
Cost: 312 hours x $43.07 = $13,437.84
F.
Instructor and Staff Resumes
During the
application process for new OTI Education Centers and as staffing
changes occur, the agency requires OTI Education Centers to provide
OSHA with selected candidates’ resumes. The agency encourages
submission of the resumes in an electronic format, generally via
email. OSHA assumes the Center receives candidate resumes
electronically during the interview process, so it takes no burden
for time that may have otherwise been associated with scanning and
uploading materials.
As such, OSHA estimates it will take
a training coordinator, earning $43.07 hourly, approximately 3
minutes (3/60 hour) to submit the required information.
Note:
This section includes resumes of anyone who may be assigned to
conduct OSHA classes, whether they are classified as a contractor,
subcontractor, employee, adjunct professor, etc.
Burden
hours: 37 individuals x 1 resume x 3/60 hour = 2 hours (rounded)
Cost: 2 hours x $43.07 = $86.14
G. Course Curriculum Upon Requests from OTI Education Centers
As needed, the OTE’s Division of Training Programs and Administration requests the Centers provide course curriculum-related content, manuals, and test questions to monitor program content and ensure quality and consistency. The agency estimates that a Center manager, earning $83.67 hourly, spends three hours providing this information annually. Thus, the calculated burden is:
Burden hours: 37 individuals x 1 response x 3 hours = 111 hours
Cost: 111 hours x $83.67 = $9,287.37
OSHA OUTREACH TRAINING PROGRAMs COLLECTIONS OF INFORMATION
H. Outreach Training Program Report Forms
After completing
each Outreach course, the trainer must submit information as stated
under Item 2, B2. OSHA estimates that a trainer will take 15 minutes
(15/60 hour) to obtain, document, and submit the required information
for each course.
For burden calculations, the agency
estimates that an Outreach trainer earns approximately $43.07 per
hour and that 53,502 courses are completed annually, an averaged
number of courses over a three-year period, 2020 through 2023,
representing the most recently available dataset.
Note: This section includes Construction, General Industry, Maritime, and Disaster Site Worker Outreach Programs.
Burden hours: 53,502 courses x 1 form x 15/60 hour = 13,376 hours (rounded)
Cost: 13,376 hours x $43.07 = $576,104.32
I. Outreach Reporting Required for Online Trainer
After completing each Outreach course, the online provider must collect information as stated under Item 2, E. The online provider provides a report no more than twice per month to the OTE’s Division of Training Programs and Administration or their authorizing OTI Education Center.
For burden calculations, OSHA estimates that a worker making $43.07 hourly will take approximately 15 minutes (15/60 hour) to obtain, document, and submit the required information. Additionally, the agency estimates that 686 reports will be completed, an averaged number of courses over a three-year period, 2020 through 2023, representing the most recently available dataset.
Burden hours: 686 reports x 15/60 hour = 172 hours (rounded)
Cost: 172 hours x $43.07 = $7,408.04
J. Online Training Program Statement of Certification
An Outreach training partner is required to sign a Statement of Certification, confirming that the online OSHA training courses they provide are in line with current OSHA requirements and procedures. The training partner must also immediately report any significant changes made to an online Outreach training program. Where no changes have been made, the training partner must provide a semi-annual report confirming the same. At a minimum, two reports must be submitted annually.
The agency has accepted eight outreach training programs. The agency estimates that each organization will submit two reports and that a worker making $43.07 hourly will require two hours per accepted program to obtain, document, and submit the required information.
Burden hours: 8 programs x 2 reports x 2 hours = 32 hours
Cost: 32 hours x $43.07 = $1,378.24
Table 2 -- Estimated Annualized Respondent Hour and Cost Burden Table |
||||||||
Information Collection Requirement |
Type of Respondent |
No. of Respondents |
No. of Responses per Respondent |
Total No. of Responses |
Avg. Burden per Response (In Hrs.) |
Total Burden Hours |
Avg. Hourly Wage Rate |
Total Burden Costs |
OSHA Training Institute Education Center |
||||||||
A. Application to become an OSHA Training Institute Education Center |
||||||||
|
Director |
4 |
1 |
4 |
10 |
40 |
$83.67 |
$3,346.80 |
|
Training Coordinator |
4 |
1 |
4 |
40 |
160 |
$43.07 |
$6,891.20 |
|
Admin Asst. |
4 |
1 |
4 |
10 |
40 |
$28.02 |
$1,120.80 |
B. OTI Education Center Monthly Summary Report for Education Centers and Outreach Training Programs |
||||||||
B1. OSHA Training Institute Education Centers Reporting |
||||||||
|
Training Coordinator |
26 |
12 |
312 |
1 |
312 |
$43.07 |
$13,437.84 |
|
Admin Asst. |
26 |
12 |
312 |
1 |
312 |
$28.02 |
$8,742.24 |
B2. OSHA Outreach Training Program Reporting |
||||||||
|
Training Coordinator |
26 |
12 |
312 |
1 |
312 |
$43.07 |
$13,437.84 |
|
Admin Asst. |
26 |
12 |
312 |
1 |
312 |
$28.02 |
$8,742.24 |
B3. Information Collected for the Outreach Training Program Mentoring |
||||||||
|
Training Coordinator |
26 |
12 |
312 |
30/60 |
156 |
$43.07 |
$6,718.92 |
|
Admin Asst. |
26 |
12 |
312 |
30/60 |
156 |
$28.02 |
$4,371.12 |
B4. Information Collected for OTI Education Center Courses Conducted out of the OTI Education Center's OSHA Region |
||||||||
|
Training Coordinator |
26 |
12 |
312 |
15/60 |
78 |
$43.07 |
$3,359.46 |
|
Admin Asst. |
26 |
12 |
312 |
15/60 |
78 |
$28.02 |
$2,185.56 |
B5. Information Collected for Outreach Training Program Exception Requests |
||||||||
|
Training Coordinator |
26 |
12 |
312 |
15/60 |
78 |
$43.07 |
$3,359.46 |
|
Admin Asst. |
26 |
12 |
312 |
15/60 |
78 |
$28.02 |
$2,185.56 |
C. Attendance Documentation for OTI Education Centers |
||||||||
|
Admin Asst. |
130 |
4 |
520 |
30/60 |
260 |
$28.02 |
$7,285.20 |
E. Outreach Trainer List |
||||||||
|
Training Coordinator |
26 |
12 |
312 |
1 |
312 |
$43.07 |
$13,437.84 |
F. Instructor and Staff Resumes |
||||||||
|
Training Coordinator |
37 |
1 |
37 |
3/60 |
2 |
$43.07 |
$86.14 |
G. Course Curriculum, Upon Request from OTI Education Centers |
||||||||
|
Director |
37 |
1 |
37 |
3 |
111 |
$83.67 |
$9,287.37 |
Section Subtotal |
--- |
--- |
4,038 |
--- |
2,677 |
--- |
$102,316.19 |
|
OSHA Outreach Training Program |
||||||||
H. Outreach Training Program Report Forms |
||||||||
|
Training Coordinator |
53,502 |
1 |
53,502 |
15/60 |
13376 |
$43.07 |
$576,104.32 |
I. Outreach Reporting Required for Online Trainer |
||||||||
|
Training Coordinator |
686 |
1 |
686 |
15/60 |
172 |
$43.07 |
$7,408.04 |
J. Online Training Program Statement of Certification |
||||||||
|
Training Coordinator |
8 |
2 |
16 |
2 |
32 |
$43.07 |
$1,378.24 |
Section Subtotal |
--- |
--- |
54,204 |
--- |
13,700 |
--- |
$590,570 |
|
|
-- |
-- |
58,242 |
-- |
16,377 |
-- |
$692,886 |
|
13. Provide an estimate of the total annual cost burden to respondents or record keepers 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 services 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 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 respondents (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.
There are no additional costs to the respondents other than their time.
14. Provide estimates of 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), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
OSHA estimates that the total annual cost to the Federal government of collecting and maintaining the information gathered on these forms is about $89,305 ($1,211.70 + $88,093.38, rounded).
Storage Costs
On average, the government spends $34.62 per square foot for storage. In line with the most recently approved ICR, the agency continues to assume that 35 square feet of storage is necessary.
Cost: 35 square feet x $34.62 per square foot = $1,211.70
Federal Employee Wage Rates
For each collection, several government employees at differing grades may be involved in processing, analyzing, and, if necessary, preparing reports. OSHA estimates that 1,758 hours, fully detailed below, are spent on the collection of information requirements contained in the OSHA Training Institute Education Center Program, and the Outreach Training Program. The agency has also determined that a GS-12, Step 54 (making $50.11 hourly) represents the average wage rate for the government staff working on these collections of information requirements.
A. Application to become an OSHA Training Institute Education Center
The agency estimates that a worker will spend nine hours reviewing an application submitted by an organization to become an OSHA Training Institute Education Center, and that the employee will review four applications annually.
Burden hours: 4 applications x 9 hours = 36 hours
Cost: 36 hours x $50.11 = $1803.96
B. OTI Education Center Monthly Summary Report, including Outreach Reporting
The agency estimates that a worker will spend one hour reviewing a Center monthly report, and that each of the 26 Centers will submit 2 reports each month.
Burden hours: 26
Centers x 2 reports x 12 months x 1 hour = 624 hours
Cost:
624 hours x $50.11 = $31,268.64
C. Statement of Compliance with Outreach Training Program Requirements
All burden-inducing activities under this item are taken by the individual Centers and accounted for under Item 12 of this supporting statement. No burden is taken for the federal government as a result.
D. Outreach Training Program Report Forms (includes Construction, General Industry, Maritime and Disaster Site Worker Outreach Programs)
All burden-inducing activities under this item are taken by the individual Centers and accounted for under Item 12 of this supporting statement. No burden is taken for the federal government as a result.
E. Outreach Reporting Required for Online Trainers
The agency assumes that a worker will spend thirty minutes (30/60 hour) reviewing, processing, and reporting on student completion cards, and that 686 completion cards will be submitted annually.
Burden hours: 686
completion cards x 30/60 hour = 343 hours
Cost: 343 hours x
$50.11 = $17,187.73
F. Outreach Trainer List
The agency assumes that a worker will spend one hour verifying and uploading monthly reports from each of the 26 Centers.
Burden hours: 26
Centers x 1 report x 12 months x 1 hour = 312 hours
Cost:
312 hours x $50.11 = $15,634.32
G. Attendance Documentation for OTI Education Centers
The agency assumes that a worker will spend four hours requesting, reviewing, and documenting quarterly attendance verification reports from each Center.
Burden hours: 26
Centers x 4 quarterly reports x 4 hours = 416 hours
Cost:
416 hours x $50.11 = $20,845.76
H. Outreach Online Training Program Report Forms
The agency assumes a worker will spend 30 minutes (30/60 hour) analyzing online training certifications, and that they will receive 16 certifications annually.
Burden hours: 16
certifications x 30/60 hour = 8 hours
Cost: 8 hours x $50.11
= $400.88
I. Instructor and Staff Resumes
The agency assumes that a worker will spend 30 minutes (30/60 hour) reviewing resumes and onboarding documents for instructor and staff applicants, and that they will process 37 applicants annually.
Burden hours: 37
certifications x 30/60 hour = 19 hours (rounded)
Cost: 19
hours x $50.11 = $952.09
J. Outreach Online Training Certification Statement
The time and cost burden for this requirement is taken under Item J of this section.
Table 3 – Burden Hours for Federal Government |
||||
Information
|
No. of |
Time per Response |
Total Hours |
Total Cost |
A. Application to become an OSHA Training Institute Education Center |
4 |
9 |
36 |
$1,803.96 |
B. OTI Education Center Monthly Summary Report, including Outreach Reporting |
624 |
1 |
624 |
$31,268.64 |
E. Outreach Reporting Required for Online Trainers |
686 |
30/60 |
343 |
$17,187.73 |
F. Outreach Trainer List |
312 |
1 |
312 |
$15,634.32 |
G. Attendance Documentation for OTI Education Centers |
104 |
4
|
416 |
$20,845.76 |
H. Outreach Online Training Program Report Forms
|
16 |
30/60 |
8 |
$400.88 |
I. Instructor and Staff Resumes
|
37 |
30/60 |
19 |
$952.09 |
TOTAL
|
1,783 |
--- |
1,758 |
$88,093 |
15. Explain the reasons for any program changes or adjustments.
OSHA is requesting that OMB extend the paperwork package for Requirements of the Training Institute Education Centers Program Data Collection and OSHA Outreach Training Program. There are no adjustments or program changes for this ICR, and the agency is requesting that the burden of 16,377 hours remains the same. The number of responses increased due to the correction of a math error that occurred during the last extension request.
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 of information, completion of the report, publication dates, and other actions.
Not applicable.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The expiration date will be displayed on the data collected.
18. Explain each exception to the certification statement.
There are no exceptions to the certification statement.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This Supporting Statement does not contain any collection of information requirements that employ statistical methods.
1 If the Outreach trainer already has an ID number and the address where student cards should be sent has not changed since the last request for students’ cards, the trainer may leave this section blank.
2 If the Outreach trainer already has an ID number and the address where student cards should be sent has not changed since the last request for students’ cards, the trainer may leave this section blank.
3 The train-the-trainer courses currently include the following: #500 - Trainer Course in Occupational Safety and Health Standards for the Construction Industry; #501- Trainer Course in Occupational Safety and Health Standards for General Industry; #502- Update for Construction Industry Outreach Trainers; and #503 - Update for General Industry Outreach Trainers; #5400 - Trainer Course in OSHA Standards for the Maritime Industry; 5402 Update for Maritime Industry Outreach Trainers; #5600 - Disaster Site Worker Train-the-Trainer Course; and #5602 - Update for Disaster Site Worker Trainer Course.
4 Office of Personnel Management, 2023 General Schedule, CHICAGO-NAPERVILLE, IL-INWI https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/CHI_h.pdf
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