Regulations (Preambles to Final Rules) - Table of Contents|
| Record Type:||Personal Protective Equipment for Shipyard Employment|
| Title:||Section 5 - Paperwork Reduction Act|
V. Paperwork Reduction Act
The Agency has estimated the paperwork burden of the shipyard PPE standard under the guidelines of the Paperwork Reduction Act of 1995. Under that Act, burden is defined as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal Agency. The Agency has concluded that the following elements of the shipyard PPE standard potentially could create a paperwork burden for the shipyard industry:
For hazard assessments: performing a hazard assessment for each trade; documenting the hazard assessment; For PPE training: developing training materials (or programs for PPE; training employees; documenting employee training. For personal fall arrest system training: developing a training program; training employees. For positioning device systems training: developing a training program; training employees.
For most of these potential sources of burden, shipyards are already performing these information collection or disclosure functions. For these elements, the final rule will not therefore require shipyards to expend additional resources on paperwork.
The Agency has concluded that only new burdens imposed specifically by new or revised provisions of a standard should be considered paperwork burdens attributable to that standard. In other words, it would be inappropriate to count as the burden actions that firms in the regulated community have already undertaken voluntarily.
The record shows that shipyards are already complying with all of the paperwork burden elements listed above, except for documenting hazard assessments, developing training for personal fall arrest systems (body harnesses), and providing training to employees for personal fall arrest systems. Among large shipyards, only Newport News Shipbuilding (NNS) reported that it relies primarily on body belts rather than body harnesses.
The hazard assessment documentation required by the standard consists of a record, either paper or on a computer or other storage medium, with the date of the hazard assessment, name of person performing the assessment, occupation or operations covered, and a list of the PPE required. Shipyards report that they already incorporate some of this information in their current training materials. The Agency has estimated that it would take each shipyard about an hour to develop a computer-based record format for this documentation and approximately five minutes to record the hazard assessment for each occupation covered. Table 6 summarizes this information for the PPE standard.
Development of training materials for the use of personal fall arrest systems (body harnesses) is the second potential burden element. All large shipyards report that they already use harnesses to some extent. Because training videos and written materials on the use of body harnesses are widely available, the Agency has concluded that the time required for establishing such a training program will be small. Table 6 presents the Agency's estimate of the time that firms will expend to develop training for the use of body harnesses; the estimate ranges from 8 hours for firms with more than 500 employees to 2 hours for the smallest employers.
Firms that do not currently use body harnesses must also train their employees as harnesses are substituted over time for body belts. The paperwork burden of this training consists of management or trainers' time to provide training to employees. The Agency estimates a training session will take approximately one hour and that as many as 10 to 20 employees can receive training in a single session. Table 6 presents the Agency's estimate of the number of sessions by firm size that will be necessary for training in body harnesses. The Agency estimates that a higher fraction (10 percent or more) of smaller firms' employees will have to be trained due to the nature of their business -- cleaning tanks, repairs over the ship's side, painting and maintenance -- which require the use of harnesses. Among large firms, only NNS reported that they used very few harnesses. The Agency estimates that all of NNS's body belts (4,700) will not have to be replaced with harnesses, since relatively less work at large shipyards and new ship construction require a body harness (rather than a body belt). The Agency has estimated that NNS will replace 3,000 body belts with harnesses. Data for the paperwork burden of providing training to employees are also presented in Table 6.
Table 6. -- Estimate of Burden Hours to Document Hazard Assessments, to Develop Training Programs for Body Harnesses, and to Train in Use of Body Harnesses for OSHA's page Standard on PPE in Shipyards. ____________________________________________________________________ | | | | | | Hazard assessment | Develop training | | | | for harnesses | | |___________________|_________________________| | Number | | | | | | Firm size | of | Number | Time of | Time | | | [number of | firms | of | document | develop |Number| Total | employees] | in | hazard | hazard | training| of | time | | size |assess- | assess- | per firm|firms | to | |category| ments | ment's | [hours] | who |develop | | |[occupa-| [hours] | |must |program | | | tions] | | |do so | | _____________|________|________|__________|_________|______|________| | | | | | | | 1000+........| 12 | 40 | 36 | ....... | 0 | 0 | 500-999......| 12 | 30 | 30 | 8 | 6 | 48 | 100-499......| 76 | 30 | 190 | 4 | 76 | 304 | 21-99........| 100 | 10 | 150 | 4 | 100 | 400 | 11-20........| 100 | 5 | 125 | 2 | 50 | 100 | 1-10.........| 200 | 5 | 250 | 2 | 100 | 200 | |________|________|__________|_________|______|________| | | | | | | | Subtotals | | | | | | | (hours)....| ...... | ...... | 781 | ....... | .... | 1052 | | | | | | | | |========|========|==========|=========|======|========| | | | | | | | Total | | | | | | | estimated | | | | | | | burden | | | | | | | (first-year,| | | | | | | one-time)..| ...... | ...... | ........ | ....... | .... | ...... | Estimated | | | | | | | annual | | | | | | | burden | | | | | | | 300 hours. | | | | | | | _____________|________|________|__________|_________|______|________| Table 6. -- Estimate of Burden Hours to Document Hazard Assessments, to Develop Training Programs for Body Harnesses, and to Train in Use of Body Harnesses for OSHA's page Standard on PPE in Shipyards. [Continued] _____________________________________________ | | | | | | | | Training | | |_____________________| | Number | | | Firm size | of | | | [number of | firms | | | employees] | in | Training | Time to | | size | sessions | train | |category| per | [hours] | | | firm | | | | | | _____________|________|__________|__________| | | | | 1000+........| 12 | 150 | 150 | 500-999......| 12 | 4 | 24 | 100-499......| 76 | 2 | 152 | 21-99........| 100 | 1 | 100 | 11-20........| 100 | 1 | 50 | 1-10.........| 200 | 1 | 100 | |________|__________|__________| | | | | Subtotals | | | | (hours)....| ...... | ........ | 576 | | | | | |========|==========|==========| | | | | Total | | | | estimated | | | | burden | | | | (first-year,| | | | one-time)..| ...... | ........ |(1) 2,409 | Estimated | | | | annual | | | | burden | | | | 300 hours. | | | | _____________|________|__________|__________| Source: OSHA's Office of Regulatory Analysis. Footnote(1) Hours.
The Agency estimates that the shipyard PPE standard will result in about 2,409 paperwork burden hours being imposed on the shipyard industry the first year, most of it due to developing training materials in the use of body harnesses. However, these 2,409 hours are only an estimate of the first-year burden, a one-time claim on resources, not an annual burden. The future annual burden beginning in the second year, is estimated to be approximately 300 hours per year, which represents managers' time to train new employees resulting from employee turnover in firms not currently training employees in the use of harnesses.
Collections of Information: Request for Comments
The Department of Labor, as part of its continuing effort to reduce paperwork and respondent burden, conducts a preclearance consultation program to provide the general public and Federal agencies with an opportunity to comment on proposed and/or continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA95)(44 U.S.C. 3506(c)(2)(A)). This program helps to ensure that requested data can be provided in the desired format, reporting burden (time and financial resources) is minimized, collection instruments are clearly understood, and the impact of collection requirements on respondents can be properly assessed. Currently, OSHA is soliciting comments concerning the proposed approval for the paperwork requirements of 29 CFR 1915, subpart I, Personal Protective Equipment for Shipyard Employment (PPE). Written comments should:
* Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;
* Evaluate the accuracy of the agency's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
* Enhance the quality, utility, and clarity of the information to be collected; and
* Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submissions of responses.
OSHA in its final rule for Personal Protective Equipment in Shipyard Employment is including two types of information collections. The first is a requirement for the employer to conduct a hazard assessment relative to PPE selection, and the second involves training requirements for PPE.
OSHA believes that the information collection and documentation of the hazard assessment as outlined in the final standard is necessary so that situations where PPE should be used for employee protection can be identified, and the proper PPE selected. In addition, OSHA believes that the training requirements and documentation in the final standard are essential in providing employees with the information and practical knowledge needed to effectively use PPE. Documentation can be used by the employer to ensure that all of its employees using PPE are properly trained.
This notice requests OMB approval of the paperwork requirements in Personal Protective Equipment for Shipyard Employment (29 CFR 1915, Subpart I).
Type of Review: New. Agency: Occupational Safety and Health Administration, U.S. Department of Labor. Title: Personal Protective Equipment for Shipyard Employment (29 CFR 1915, subpart I). OMB Number: 1218-AA74 Agency: Docket No. S-045. Frequency: On occasion. Affected Public: Business or other for-profit, Federal government, State and Local governments. Number of respondents: 500. Estimated Time Per Respondent: Varies. Total Estimated Cost: $72,270 (First year only), $9,000 annual. Total Burden Hours: 2,409 (First year only), 300 annual, recurring. Comments submitted in response to this notice will be summarized and/or included in the request for Office of Management and Budget approval of the information collection request: they will also become a matter of public record.
Regulations (Preambles to Final Rules) - Table of Contents|