SUPPORTING STATEMENT FOR THE INFORMATION COLLECTION
REQUIREMENTS FOR THE STRATEGIC PARTNERSHIPS
FOR WORKER SAFETY AND HEALTH (OSP)
Federal Register [08/11/1999] 64:43722
Submission for OMB Review; Comment Request.
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.
Over the past several years, OSHA has been expanding on its already substantial experience with voluntary programs by proposing and implementing various new cooperative initiatives in both the National Office and the field. These efforts have been designed to increase OSHA's impact on worker safety and health and, at the same time, to help OSHA change its way of conducting business from one of command and control to one that provides employers an opportunity to work cooperatively with OSHA. Employer groups, labor organizations, individual employers, and employees and their representatives committed to maintaining a safe and healthful workplace for all workers are finding OSHA to be a willing partner. Individual employers who fail to step up their efforts to protect their workers are continuing to face strong enforcement.
In the absence of clear agency policy on partnerships, however, program developers specified varying partnership requirements, qualifications, and OSHA incentives. Seeing a need to establish "boundaries" for partnership programs, OSHA formed an ad-hoc workgroup of agency staff. The workgroup's task was to develop a partnership framework that would ensure a basic level of consistency for these various cooperative efforts. The workgroup was particularly concerned to strike a balance between consistency and flexibility so that the established boundaries were not so rigid as to inhibit innovation. After several opportunities for review and comment by a group of senior National Office managers, Regional Administrators, State Programs, and agency stakeholders, the efforts of this ad-hoc workgroup evolved into OSHA's Strategic Partnerships for Worker Safety and Health (OSP). A comprehensive description of OSP can be found in OSHA Instruction TED 8-0.2, which was published on November 9, 1998. A copy of the Instruction is attached to this submission.
Strategic Partnerships for Worker Safety and Health (OSP)
The term OSHA Strategic Partnerships for Worker Safety and Health (OSP) denotes an OSHA strategy, available for all industries, whereby OSHA enters into an extended, voluntary, cooperative relationship with groups of employers, employees, and employee representatives (sometimes including other stakeholders, and sometimes involving only one employer) in order to encourage, assist, and recognize their efforts to eliminate serious hazards and achieve a high level of worker safety and health. An OSHA Strategic Partnership aims to have a measurable, positive impact on workplace safety and health that goes beyond what historically has been achievable through traditional enforcement methods and through a focus on individual worksites. Under the umbrella of OSHA Strategic Partnerships are two subclassifications: Comprehensive OSPs and Limited OSPs.
A Comprehensive OSHA Strategic Partnership contains all core elements described in the attached Instruction. The Comprehensive Partnership agreement must include each participating employer's commitment to implement in a timely manner an effective workplace safety and health program that provides for management leadership and employee involvement, hazard analysis, hazard prevention and control, safety and health training, evaluation, and compliance with applicable OSH Act requirements.
A Limited OSHA Strategic Partnership is not required to include all the core elements. For example, a Limited Partnership, rather than requiring establishment of comprehensive safety and health programs, might focus on eliminating a prevalent hazard in a particular industry.
Both types of partnerships will have information collections as part of their requirements. The ability to collect this information is essential if OSHA and its partners are to measure the concrete results of the partnerships' efforts and the effectiveness of this innovative method of improving worker protection. In the development of its Strategic Partnership policy, OSHA has paid careful heed to the requirements and spirit of the Government Performance and Results Act (GPRA) of 1993, by considering in what ways OSPs can make a difference in the lives of workers and how the agency, by collecting information and conducting ongoing evaluations, can ensure that these programs are achieving the intended results. The need to collect information in order to gauge program success is an integral part of OSHA's strategic planning process, and OSPs, like other agency activities, are required to regularly provide information to the agency. The agency uses this information to gauge the effectiveness of its programs, identify needed improvements, and ensure that its resources are being used to good and effective purpose.
Each partnership will determine during its development stage what information collections will be needed. This process will involve identifying the needed information, determining the best method to collect it, and setting forth the uses to which the information will be put. Because the private sector worksites that combine to develop each partnership will have strong input into the partnership development, including decisions about information collection, OSHA is confident that data collection efforts will be prudent and will not create undue burden on the partners. Information not needed to gauge the results of the partnership effort will be excluded from the data collection, and existing information will be used whenever possible.
OSP information collections fall into three categories: Measurement, Safety and Health Program, and Hazard Specific.
Measurement collections apply to all partnerships and will, at a minimum, include OSHA-200 Log data, required recordkeeping for all employers with 10 or more employees. A partnership also may include other measures of success, such as productivity, absenteeism, employee turnover, and/or workers' compensation data. OSHA's experience in its Voluntary Protection Programs, Consultation Program, and various enforcement activities has shown that all of these measures can be useful in measuring the results of implementing safety and health programs and other worker protection measures.
Safety and Health Program information collections will be limited to the approximately 30 percent of partnerships that OSHA expects will be comprehensive. This information collection will be part of the verification process, which will consist primarily of OSHA onsite visits to about five percent of partners each year to ensure that partnering employers are indeed establishing effective safety and health programs. The information will not be submitted to OSHA but, rather, made available during agency visits.
Hazard Specific information collections for limited partnerships will require employers to perform a site survey of hazards and to track hazards identified and abated. OSHA has long recognized that identifying worksite hazards and developing the means to eliminate and/or control them is essential to protecting workers. Many existing OSHA standards and regulations currently mandate hazard identification and recordkeeping, and therefore OSHA does not view this requirement as creating a significant additional burden for partnership employers beyond what they already must do to comply with existing rules. OSHA intends to verify employer compliance with the partnership requirements primarily via onsite visits, and not through the collection of data from all participating sites. OSHA expects that the data that is collected will be primarily information the sites already maintain by mandate of law or custom.
Generic PRA Request
OSHA is requesting in this submission that a generic approval be granted for OSHA's Strategic Partnerships for Worker Safety and Health. OSHA anticipates the establishment of no more than 25 partnerships per year. The agency believes a generic PRA approval is appropriate for the following reasons:
1. The information collected for each partnership can be estimated and categorized.
2. The life of an OSP, including development and implementation, must occur within a specified and limited time period. Obtaining individual PRA approvals for each partnership will delay implementation and reduce the period of time the partnership has to obtain intended results.
3. OSHA will reap significant savings if it does not have to repeatedly devote resources to individual PRA approval applications for very similar activities.
It has been OSHA's experience that, in order to maintain the enthusiasm and willingness of employers to engage in such voluntary cooperative efforts, it is important that the partnerships get up and running as quickly as possible. Employers and employees need to see tangible results as soon as possible. Moreover, and certainly as important, the sooner the partnership can begin functioning, the sooner this activity can begin saving lives and preventing injuries and illnesses. The agency believes that this compelling need to better protect workers is a strong argument in favor of a generic approval. OSHA understands that it will be expected to keep OMB informed as new partnerships are established which make use of a generic approval. OSHA will be happy to comply, because it is the agency's view that, without a generic approval process, OSHA cannot effectively administer this important new program.
OSHA proposes to use the same format as the Department's generic Customer Satisfaction Survey Supplemental Supporting Statement. OSHA will complete the Supplementary Supporting Statement and attach a copy of the partnership agreement for DOL and OMB approval.
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.
The information will be collected by the partnerships directly or by a third party in association with the partnership or sometimes directly by OSHA (especially when OSHA is on-site verifying program implementation and/or hazard protection). OSHA and Partnership members will use the information to evaluate their effectiveness in achieving the partnerships' goals. OSHA will use the information collected from the partnerships to perform its own evaluation of the effectiveness of the partnerships in meeting OSHA's goal of reduced workplace injuries and illnesses through cooperative partnership arrangements. OSHA also will use the information to help fulfill its obligations under the Government Performance Results Act (GPRA), including meeting the goals established in its Strategic Plan.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques, or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adapting this means of collection. Also describe any consideration of using information technology to reduce burden.
Partnership participants may use improved information technology whenever appropriate when making, keeping, and preserving the required records. OSHA is only interested in what is collected, not how it is collected. Where the technology exists, OSHA welcomes the use of information technology to reduce the burden. However, OSHA does not require the use of technology for reporting so as not to disqualify the less technically advanced.
OSHA is establishing an automated Partnership database and will explore opportunities to provide for electronic data submission to reduce the burden on participants.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
Each partnership will be unique with information needed that is available only from the partnership in question. OSHA is only requiring existing data found in the 200 Logs or information that is already required to be kept to be in compliance with all OSH Act regulations. As OSP is established, the participants will identify additional data that they determine is needed to assess the effectiveness of the OSP.
For measurement collections, OSHA is only requiring information that the sites are required by law or custom to collect. Additional data that OSHA may collect (productivity, absenteeism, employee turnover, and/or workers' compensation) will only include that which the partnerships themselves determine they need to properly evaluate their impact.
For Hazard Specific collections, OSHA will only be requiring that the partners establish hazard baseline and abatement data that they are required to develop and maintain elsewhere under law or custom. Partners will be expected to submit some information limited to the number of hazards identified and abated. OSHA will only be reviewing the Hazard Specific program when it conducts onsite visits to about five percent of the partners each year.
For Safety and Health Program development collections, OSHA is requiring data that the sites must develop and maintain to establish that they have developed an effective program. When OSHA's Safety and Health Program Management Standard is adopted, this information will be required nationwide. Again, OSHA will only be reviewing this information when it conducts onsite visits to about five percent of the partners each year.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 81-I), describe any methods used to minimize burden.
The collection of information does not significantly impact small business or other small entities.
6. Describe the consequence 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.
The information collection frequencies are minimal. To eliminate the submission would effectively cripple OSHA's ability to form partnerships and to measure success as required in GPRA and OSHA's Strategic Plan.
There are no technical or legal obstacles to reducing the burden.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
- requiring respondents to report information to the agency more often than quarterly;
- requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
- requiring respondents to submit more than an original and two copies of any document;
- requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
- 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;
- requiring the use of statistical data classification that has not been reviewed and approved by OMB;
- 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
- requiring respondents to submit proprietary trade secret, 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.
8. If applicable, provide a copy and identify the date and page number of publication 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 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 instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 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.
A copy of the Strategic Partnership for Worker Safety and Health Information Collection Request that was published in Federal Register #: 64:22652 on 04/27/1999 is attached. No comments were received in the comment period ending on June 28, 1999, or subsequently.
Each partnership will establish the information collection needs required to evaluate the effectiveness of the partnership. Therefore the views of employers, employees, and their representatives will be paramount in establishing information collection requirements. Partnership groups will meet on a regular basis (generally quarterly) and therefore will be consulted on a regular basis to ensure the burdens of data collection are minimized.
9. Explain any decision to provide any payment or gift to respondents, other than renumeration to contractors or grantees.
No payments or gifts are provided to the respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis of the assurance in statute, regulation, or agency policy.
Data collected regarding partnerships is considered public information. Therefore there is no assurance of confidentiality provided to respondents through statute, regulation, or agency policy.
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.
There are no questions of such a sensitive nature to answer; therefore, this question is not applicable.
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 in Item 13 of OMB Form 83-I.
- Provide estimates of annualized cost to respondents for the hour burdens for collection 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 14.
The burden hours and other estimated numbers contained in this information collection request are based on 28 years of experience with OSHA 200 information collection and time required to develop overall safety and health programs and hazard specific programs, standard average pay rates as described below, and, when necessary, best professional judgement. OSHA expects to seek approval for 25 new partnerships each year with an average of 20 worksites per partnership. All partnerships will be required to submit Measurement data, i.e., OSHA 200 data. Seven partnerships are expected to be Comprehensive in nature, thereby requiring, in addition, the full development of safety and health programs. Eighteen of the partnerships are expected to be limited in nature to a specific hazard, thereby also requiring a site hazard survey and plan to control or eliminate the hazard (information already required by law). Comprehensive or Limited Partnerships will only be required to submit OSHA 200 information and other data, if any, required by the partnership. Some limited Hazard Specific data will be collected, i.e., the number of hazards identified and abated. Safety and Health Program information will not be collected but will be reviewed by OSHA onsite (about 5 percent of the partners per year).
SUMMARY OF ANNUAL BURDEN HOURS AND COSTS
|Number of Partnerships/ Respondents||Burden Hours/ Respondent||Frequency of Response||Annual Hour Burden||Estimated Annualized Costs||Federal Govt Review Costs|
|Safety & Health Program||7||140||40||Annual||5,600||$114,177||0|
Establishing the Partnership
Based upon its experience with partnerships to date, OSHA estimates that it will require approximately 100 hours of professional time to establish and evaluate the effectiveness of each partnership. This includes the time needed develop the partnership requirements, the language of the agreement, and the measures of effectiveness and the time to conduct the annual evaluation of the partnership in a manner that meets the requirements of section XI. of OSHA's OSP Instruction (TED 8-0.2).
100 hours at $24.02 per hour times 25 partnerships = $60,050
Approximately 2 hours of clerical time per respondent will be needed to collect and submit comprehensive measurement data for the 500 respondents who are members of the 25 partnerships. The burden estimate assumes measurements will be collected for all categories (OSHA 200, productivity, absenteeism, employee turnover, and workers' compensation data), thereby overestimating the probable burden because most partnerships will be required only to collect and submit OSHA 200 Log data.
1000 hours at $11.52 per hour = $11,520
Comprehensive Partnerships - Safety and Health Program
OSHA expects that most respondents in a Comprehensive Partnership will have some parts of a program already in place with a range from full programs requiring some enhancing to no program at all. Assuming each respondent has, on average, 50 percent of a comprehensive program in place, OSHA's experience indicates that 15 professional and 25 employee hours will be needed per respondent to complete program development and evaluation in a manner that meets the requirements of section IX. of OSHA's OSP Instruction (TED 8-0.2).
Professional - 140 x 15 x $24.02 = $50,442
Employee - 140 x 25 x $18.21 = $63,735
Total - $114,177
Limited Partnerships - Hazard Specific
OSHA expects that respondents in a Limited Partnership will require approximately 4 hours of professional and 12 hours of employee time to survey, abate, and report on the results of the hazard specific program developed in a manner that also meets the requirements of section IX. of OSHA's OSP Instruction (TED 8-0.2).
Professional - 360 x 4 x $24.02 = $34,589
Employee - 360 x 12 x $18.21 = $78,667
Total = $113,256
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers 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 it's 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 purchasing or 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 a 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.
Section 1320.7(b)(2) indicates that "The time, effort, and financial resources necessary to comply with a collection of information that would be incurred by persons in the normal course of their activities (e.g., in compiling and maintaining business records) will be excluded from the "burden" if the agency demonstrates that the reporting, recordkeeping, or disclosure activities needed to comply are usual and customary." Any capital or start-up costs and operating costs associated with this data collection are customary and usual business practices attributable to achieving legal and regulatory requirements or to developing voluntarily an effective safety and health program, not to the collection of this data for OSHA's Strategic Partnership Programs. Start-up costs are included in the costs of preparing these submissions. The reporting costs to partnerships that may choose to have a third party collect their data are included in the cost estimates in 12. above. Therefore this section is not applicable.
14. Provide estimates of annualized costs 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 also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
There is no cost to the Federal Government to collect this information. The costs of reviewing the measurement data submitted to OSHA from the 25 partnerships is an average of one hour per partnership by a GS-13 ($39.89) is: 1 hour x 25 x $39.89 = $997. The costs incurred in random onsite validation visits are part of the routine cost of conducting OSHA compliance activity and not specific to the Strategic Partnership Program.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
OSHA is requesting 14,860 hours as a program addition because it has just established the Strategic Partnership Program.
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 the information, completion of report, publication dates, and other actions.
Information on Partnerships will be used both internally and externally by the agency to gauge its conformance with the goals and objectives outlined in OSHA's Strategic Plan. There are no plans, however, to formally publish this information.
17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
OSHA is not seeking such approval.
18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
There are no exceptions to the certification statement identified in Item 19.
DEPARTMENT OF LABOR
Occupational Safety and Health Administration
Strategic Partnership for Worker Safety and Health
Docket No. ICR-99-2
AGENCY: Occupational Safety and Health Administration, Labor.
ACTION:Notice; proposed information collection request; submitted for public comment and recommendations.
SUMMARY: The Department of Labor, as part of its continuing effort to reduce paperwork and respondent burdens, is conducting a preclearance consultation program to provide the general public and Federal agencies with an opportunity to comment on proposed and continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA 95) (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 impact of collection requirements on respondents can be properly assessed. Currently, the Occupational Safety and Health Administration is soliciting comments concerning the approval for the paperwork requirements for participation in OSHA Strategic Partnerships for Worker Safety and Health.
DATES: Written comments must be submitted on or before June 28, 1999.
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 their 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 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.
ADDRESSES: Comments are to be submitted to the Docket Office, Docket ICR-99-2, U.S. Department of Labor, Room N-2625, 200 Constitution Avenue, NW, Washington, DC 20210, (202) 693-2350. Written comments limited to 10 pages or less may be transmitted by facsimile to (202) 693-1648.
FOR FURTHER INFORMATION CONTACT:
Ms. Cathy Oliver, Directorate of Federal-State Operations, Occupational Safety and Health Administration, U.S. Department of Labor, Room N3700, 200 Constitution Avenue, NW., Washington, DC 20210, (202) 693-2208. Copies of the referenced information collection requests are available for inspection and copying in the Docket Office and will be mailed immediately to persons who request copies by telephoning Ms. Oliver at (202) 693-2213 or B. Bielaski at (202) 693-2444. For electronic copies of the information collection request on Strategic Partnerships for Worker Safety and Health, contact OSHA's Web Page on Internet at http://www.osha.gov and click on "Regulations and Compliance."
The Occupational Safety and Health Administration (OSHA) will be requesting approval from the Office of Management and Budget (OMB) for certain information collection requirements contained in the Strategic Partnerships for Worker Safety and Health. This notice initiates the process for OSHA to request an OMB approval.
As part of OMB's and OSHA's continuing paperwork reduction effort, OSHA seeks to reduce that paperwork burden hours in the Strategic Partnerships for Worker Safety and Health based on input from parties interested in the regulatory scope of that regulation. The purpose of this notice is to solicit public comment on OSHA's paperwork burden estimates from those interested parties and to seek public response to several questions related to the development of OSHA's estimates. Interested parties are requested to review OSHA's estimates, which are based on information from historical data, to comment on their accuracy or appropriateness in today's workplace situation. OSHA bases its existing estimates upon information from 28 years of experience and best professional judgement and is interested in learning whether they are outdated.
This notice requests a PRA approval from OMB for the paperwork required for participation in the Strategic Partnerships for Worker Safety and Health.
Burden: 14,860 hours per year
Type of Review: New Approval.
Agency: Occupational Safety and Health Administration, U.S. Department of Labor.
Title: Strategic Partnerships for Worker Safety and Health.
OMB Number: No number assigned
Agency Number: Docket No. ICR-99-2.
Frequency: Twice per year.
Affected Public: Business.
Number of Respondents: 500 per year
Estimated Time Per Respondent: 29.72 hours per year
Total Burden Hours: 14,860 per year
Comments submitted in response to this notice will be summarized and 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.
Signed this 21st Day of April, 1999
Charles N. Jeffress