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UNITED STATES
DEPARTMENT OF LABOR

OSHA Instruction ADM 7.3B April 4, 1988 Office of Management Systems and Organization

Subject: OSHA Forms Management Program

A. Purpose. This instruction revises the OSHA Forms Management Program.

B. Scope. This instruction applies OSHA-wide

C. Cancellation. OSHA Instruction ADM 7.3A is cancelled.

D. Action. All OSHA managers and others possessing forms management responsibilities shall follow the policies and procedures set forth in this directive to introduce new forms, revise existing forms or reprint existing forms without change.

E. References.

1. The Federal Records Act of 1950, as amended.

2. The Paperwork Reduction Act of 1980.

3. 41 CFR 201, Federal Information Resources Management Regulation.

F. Objectives. The objectives of the OSHA Forms Management Program are to:

1. Increase the usefulness of forms through proper design resulting in forms that are simple to fill in and easier for the originator and others to use.

2. Reduce costs incident to completing and using forms.

3. Achieve savings in the design, printing, storage and distribution of forms.

4. Eliminate unnecessary and duplicate forms and to consolidate existing related forms.

OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

5. Prevent the use of unauthorized forms and to assure that forms are designed when data collection requires them.

G. Definitions.

1. Forms. A form is any printed or otherwise reproduced document with space for insertion of information, descriptive material or addresses. This includes all forms originated in OSHA for use by the public, other Federal agencies, State or local government agencies or OSHA offices. This definition does not include pattern letters. Some types of forms are:

a. Completely pre-printed memoranda, letters and post cards.

b. Form letters.

c. One-time or temporary forms.

d. Logs.

e. Printed items without fill in space such as instruction sheets, notices, tags, labels, and posters and other similar items when their identification and control will facilitate printing, stocking and distribution.

2. Form Letter. A form letter is a pre-drafted letter or memoranda prepared and stocked in advance of actual use. They usually contain, at a minimum, fill in space for the name and address of the addressee.

3. Pattern Letter. A pattern (or guide) letter is a pre-drafted letter or memo where the entire letter (standard letter) or several standard paragraphs, addresses, etc. are maintained in an electronic typewriter, word processor, or other electronic retrieval system. The entire standard letter or memoranda may be printed as needed.

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OSHA Instruction 7.3B APR 4, 1988 Office of Management Systems and Organization

H. Authorities.

1. The Director, Office of Management Systems and Organization, or designee, serves as the OSHA Forms Management Officer.

2. The Director, Directorate of Policy, or designee, is the OSHA Public Reports Officer.

3. The Director, Office of Administrative Services serves as the Forms Printing and Supply Officer.

4. The Director, Office of Management Data Systems serves as the OSHA ADP Forms Officer.

5. Each directorate and independent office director shall designate a Program Forms Officer. The designee serves as the directorate or office forms officer. Provide the name of the Program Forms Officer to the OSHA Forms Management Officer.

6. Each Regional Office Management Officer is designated as the Regional Forms Officer for the appropriate region.

I. Responsibilities.

1. OSHA Forms Management Officer. The OSHA Forms Management Officer shall: a. Administer and manage the OSHA Forms Management Program.

b. Review and approve all new or revised OSHA or regional forms. Perform an analysis in accordance with accepted forms management practices.

c. Coordinate the clearance of the forms of other agencies within OSHA.

d. Obtain the clearance of OSHA interagency report forms through the Department and the General Services Administration.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

e. Coordinate the clearance of internal OSHA forms with other agencies.

f. Compile and distribute a forms catalog annually. The catalog contains a current listing of all OSHA forms which are active as well as those which have become obsolete since the issuance of the last version of the OSHA Forms Catalog.

g. Act as liaison to the DOL Forms Management Officer.

h. Advise the DOL Forms Management Officer of the addition, revision or cancellation of OSHA forms.

i. Conduct forms analysis reviews of individual OSHA forms or groups of forms including their printing, stocking and distribution.

j. Conducts periodic analyses and reviews of the OSHA Forms Management Program.

k. Conducts periodic reviews of regional forms and regional forms programs.

2. OSHA Public Reports Officer. The OSHA Public Reports Officer shall obtain clearance from the Department and OMB for OSHA public use report forms.

3. OSHA Forms Printing and Supply Officer. The OSHA Forms Printing and Supply Officer shall:

a. Approve reprints (without change) of existing forms.

b. Ensure that no new or revised national form is printed without the approval of the OSHA Forms Management Officer.

c. Arrange for the printing, stocking, and distribution of approved OSHA forms.

d. Exercise inventory control over OSHA forms.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

e. Establish standards and procedures to determine the costs of creating, printing, stocking, and distributing forms. Provide the information to forms originators, forms officers and the OSHA Forms Management Officer.

4. OSHA ADP Forms Officer. The OSHA ADP Forms Officer shall:

a. Initiate and coordinate internal OSHA clearance of ADP-related forms, such as ADP input and output forms.

b. Submit all proposed new or revised forms for approval to the OSHA Forms Management Officer.

c. Provide a complete forms clearance package when submitting new or revised forms for approval. Refer to Paragraph N.2. on page 11.)

5. Forms Officers. Program and Regional Forms Officers shall:

a. Submit all proposed new or revised forms, including internal regional, directorate or office forms, for clearance to the OSHA Forms Management Officer. Regions shall submit their forms through the Program Forms Officer of the Office of Field Programs. Field local-use forms will be submitted for information only; not for clearance.

b. Provide a complete clearance package when submitting new or revised forms for approval. (Refer to Paragraph N.2. on Page 11.)

c. Coordinate forms management activities within their organizations and with other forms officers, the OSHA Forms Printing and Supply Officer and the OSHA Forms Management Officer.

6. Originators of New or Revised Forms.

a. The originator will develop the form, prepare the instructions, and forward a clearance package to the appropriate forms officer.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

b. Any individual may act as a forms originator, but they should have access to, and knowledge of, the principles of forms management.

J. Forms Creation. An appropriate form shall be developed when an office:

1. Requires data collection or recordkeeping of others.

2. Needs to maintain information not otherwise available or where existing forms do not contain all the needed information.

K. Forms Clearance Criteria. The following criteria should be kept in mind during the clearance process. Forms which do not meet these requirements must either be amended to meet the standards or they will not be approved.

1. Is the form necessary? Only forms utilizing essential information will be approved.

a. Is the information to be collected current information?

b. Is the proposed form the only source available for collecting the information?

c. Does the value of the information to be collected exceed the cost of gathering and preparing the form?

d. Is the proposed form the best way to collect the information?

2. Can each item on the form be justified?

3. Can each completed copy of the form be justified?

4. Can the form be combined with other forms?

5. Can forms used in different work steps of the same process or procedure be combined?

6. Can the form be filled in at one writing?

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

7. Can information filled in on several forms at different times be captured on one form thereby consolidating several forms?

8. Does the form concentrate too much information on one form?

9. Does the form seem too crowded with information to function properly as an information gathering tool?

a. Does the form concentrate too many functions or processes?

b. Is there missing information?

c. Is another form, another copy, or additional items needed?

10. Consider the impact other areas such as reports, directives, printing and supply may have on the form and the impact the form may have on those other areas.

11. Analyze the Procedures that will be affected by the form and determine if they would be more or less efficient if the form was implemented.

12. Can the form be printed, distributed and replenished economically?

13. All forms must meet the design standards set forth in GSA forms management handbooks, and the DOL Graphics Communication Standards Manual. Copies of GSA booklets on forms management can be obtained from a GSA store Some of these handbooks are:

Title National Stock Number

a. Forms Management 7610-00-142-9363

         b.    Form and Guide           7610-00-117-8777
                 Letters

         c.    Forms Analysis           7610-00-753-4771
                and Design

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OSHA Instruction ADM 7.3A APR 4, 1988 Office of Management Systems and Organization

14. Personnel who originate or manage forms should attend a training course on the subject.

L. Internal OSHA Clearance.

1. All OSHA forms must be cleared internally within OSHA and by the OSHA Forms Management Officer prior to being made a part of the forms system. Figure 1 on page 12 contains a flow chart outlining OSHA's forms clearance and reprint procedures.

2. Reclear with the OSHA Forms Management Officer any proposed new or revised form that has been approved but was subsequently changed during the directives clearance process or during either submission to OMB or to any agency having a review and/or approval responsibility. If the form was changed during such a subsequent approval process, the altered form is NOT an approved forms. The altered form must be approved by the OSHA Forms Management Officer.

3. Consultation with the OSHA Forms Management Officer before and during the formal directives clearance process, including OMB clearances, is encouraged to prevent delays in approving forms.

M. Forms Preparation.

1. Notification.

a. The originator of a form shall advise the appropriate forms officer when developing or revising a form.

b. The forms officer shall notify the OSHA Forms Management Officer when developing a national form.

2. Develop the form.

a. Consider carefully exactly what the form is to accomplish.

b. Determine what information is essential to achieve that purpose.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

c. Keep it simple.

d. Seek assistance, if necessary, from either the appropriate forms officer or from the OSHA Forms Management Officer.

e. Consult:

(1) The Office of Management Data Systems if the form affects IMIS or other automated information systems.

(2) The Directorate of Compliance Programs if the form affects either field procedures or the Field Operations Manual.

(3) The Office of Field Programs if the form is to be completed by the field.

3. Preparing the Instructions.

a. All proposed forms shall be implemented by a directive which will explain how, when, where and by whom the form is to be used, how many copies need to be completed, their distribution and source of supply. Instructions on how to complete the form need not be repeated on a separate page of the directive if they are included in the text or on the back of the form.

b. The instructions for the form shall indicate which items, if any, on the form are regularly protected under the Privacy Act, or which are exempt from disclosure under the Freedom of Information Act. Questions concerning which items on the form may or may not be disclosable should be referred to the OSHA Freedom of Information Act Coordinator in the Office of Information and Consumer Affairs.

c. Instructions for regional forms will be implemented by regional and area office directives.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

4. Statement of Justification. Prepare the statement on Form DL-1-86, Request for New or Revised Form. If additional space is needed, use a separate sheet of paper and fasten it to the DL-1-86. Be sure to answer each item on the form fully and completely. The statement of justification should answer these questions:

a. Why is the form needed?

b. Who will fill out the form?

c. Who will use the information?

d. What is the purpose of the information?

e. What is the estimated frequency of use?

5. Forwarding Forms Packages.

a. Forward the package for clearance to the forms officer. The forms officer will forward the package to the OSHA Forms Management Officer.

b. The OSHA Forms Management Officer should be consulted on forms clearance procedures before submission of public-use forms to the OSHA Public Reports Officer to obtain an Office of Management and Budget (OMB) clearance. The form MUST be cleared by the OSHA Forms Management Officer before submission to OMB.

N. Clearance Process.

1. Any OSHA form which is modified in any manner, including changing edition dates, shifting the positions of items, adding or changing OMB or GSA clearance numbers and expiration dates, and the like MUST be cleared and approved by the OSHA Forms Management Officer prior to use of the new or revised form. Figure 1 on page 12 consists of a flow chart summarizing the forms clearance process.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization 2. It is the responsibility of the appropriate forms officer to assemble a complete forms clearance package for all new or revised forms or provide all the information mentioned or needed in Paragraph O below before reprinting forms. Appendix A contains detailed instructions for clearing new or revised OSHA forms.

O. Reprinting Forms. Figure 1 on page 12 contains a flow chart of OSHA's forms clearance and reprint procedures.

1. The Forms Printing and Supply Officer shall notify the appropriate forms officer when the volume of a particular form stocked in the DOL Warehouse reaches the reorder point.

2. When the originator of the form is also the stocking point for the form, the originator is responsible for determining the reorder point and notifying the appropriate forms officer.

3. The originator and the forms officer determine if the form needs to be revised.

a. If the form needs to be revised, the originator and the forms officer follow the procedures contained in Paragraphs K., M. and N. on pages 6, 8 and 10, respectively, and in Appendix A and submits a revised form package to the OSHA Forms Management Officer.

b. If the form is to be reprinted only:

(1) The forms officer shall inform the Forms Printing and Supply Officer of the quantity of forms to be reprinted and provide a print order and other necessary materials such as distribution lists and mailing labels.

(2) The Forms Printing and Supply Officer shall review the forms reprint information and determine if the form will be reprinted as requested.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

Figure 1

FORMS CLEARANCE AND REPRINT PROCEDURES FLOW CHART

** FOR FIGURE 1 REFER TO PRINTED COPY OF ADM 7.3B.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

FIGURE 2

DL FORM 1-86, REQUEST FOR NEW OR REVISED FORM

** FOR FIGURE 2 REFER TO PRINTED COPY OF ADM 7.3B

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

P. Obsolete Forms. Originating offices shall promptly notify the appropriate forms officer when a form is obsolete or is cancelled. The forms officer shall notify the OSHA Forms Management Officer. Notification shall be in the form of a memorandum canceling the form. If the form was mandated or implemented by or had instructions printed in an instruction, include a copy of the change canceling the form.

David C. Zeigler Director Administrative Programs

Distribution: National, Regional and Area Offices OASAM's

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

Appendix A

NEW AND REVISED FORMS CLEARANCE PROCEDURES

A. Introduction. This appendix is an easily accessed, readily identifiable outline of OSHA's new and revised forms clearance procedures. Figure 1 on page 12 contains a flow chart summary of those procedures.

B. Originator.

1. Clearance Package. The originator will prepare and forward to the appropriate forms officer a clearance package consisting of the following. (Refer to Paragraph G. on page A-5 for external clearance requirements.)

a. A completed copy of DL Form 1-86, "Request for New or Revised Form." (Refer to Figure 2 on page 13.)

b. The proposed form.

c. A draft directive implementing the form including instructions for completing the form.

d. Copies of comments received from other offices or organizations as well as any other information of use in approving the proposed new or revised form.

e. The forms officer may require a completed print order including any needed address listings or mailing labels for distribution of blank forms.

2. Clearance Submission. The clearance package should be submitted by the originator to the forms officer in sufficient time to allow 10 weeks before receipt of the blank forms at the forms stocking points (2 weeks for the forms officer, 2 weeks for the OSHA Forms Management officer and 6 weeks for the Forms Printing and Supply Officer).

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

3. Shipment Notification. The originator will notify the Regional Forms Officers and the Regional OASAM by memo of the expected shipment date and quantity of the blank forms to be shipped after the form has been approved.

C. Forms Officer. The Program Forms Officer (including the OSHA ADP Forms Officer) or Regional Forms Officer will accomplish the following:

1. Review and Consultation. The Program or Regional Forms Officer will review the forms clearance package and work with the originator to resolve any problems.

2. Program Forms Officer. The Program Forms Officer will ensure that the form is cleared with all affected offices. (Refer to OSHA Instruction ADM 8.1A, OSHA Directives System.) Be sure the following is done:

a. Request a decision by the OSHA Labor-Management Officer if consultation with either Local 12 or the NCFLL is necessary. Give the Labor-Management Officer the following information:

(1) One copy of the form.

(2) A justification showing the purpose of the form.

(3) A statement showing if the form is new or if it is a major or minor revision of an existing form.

(4) A listing and description of the groups of employees which are expected to complete the form.

b. IMIS reporting forms must be cleared with the Office of Management Data Systems.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

c. Forms affecting field operations procedures, annual field compliance program planning, field performance analysis and the Field Operations Manual must be cleared with the Directorate of Compliance Programs.

d. The Program Forms Officer for the Office of Field Programs shall be responsible for the clearance of field originated national interest forms. The Forms Officer shall follow the requirements of Paragraphs C.1. and 2. on page A-2.

e. Forward the clearance package, including comments received, and the like, to the OSHA Forms Management Officer.

3. Field. The regional forms officer will:

a. Ensure that regional interest forms are reviewed by interested offices.

b. Consult with the NCFLL before implementing regional forms.

c. Forward all Proposed forms having national significance to the Office of Field Programs for submission to the OSHA Forms Management Officer.

d. Send all proposed regional forms which do NOT have national significance to the OSHA Forms Management Officer through the Program Forms Officer of the Office of Field Programs for informational purposes only. Formal approval of the regional or local use form by the OSHA Forms Management Officer is not necessary.

4. Printing and Distribution. The Program or Regional Forms Officer will complete a print order for the form including any needed address listings or mailing labels for distribution of blank forms.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

D. OSHA Public Reports Officer. The OSHA Public Reports Officer:

1. Obtains clearance from OMB for public-use report forms.

2. Sends a copy of the OMB clearance and the approved form to the OSHA Forms Management Officer.

3. Obtains the approval of the OSHA Forms Management Officer for any OMB-mandated changes to OSHA public-use forms.

E. OSHA Forms Printing and Supply Officer. The OSHA Forms Printing and Supply Officer:

1. In conjunction with the appropriate forms officer, coordinates the printing, stocking, and distribution of the form.

2. Shall not print or otherwise reproduce any new or revised forms without the approval of the OSHA Forms Management Officer.

F. OSHA Forms Management Officer. The OSHA Forms Management Officer will:

1. Review the proposed form and supporting documents.

2. Indicate approval or disapproval of the package and return the DL 1-86 to the forms officer who will then advise the originator of the action. Any changes the OSHA Forms Management Officer requires to be made will be indicated on the DL 1-86 or on the proposed form.

3. After approval, the OSHA Forms Management Officer will:

a. Assign a form number and edition date.

b. Secure external clearance when necessary for interagency reports.

c. Forward agency form approvals involving public-use reports to the OSHA Public Reports Officer.

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OSHA Instruction ADM 7.3B APR 4, 1988 Office of Management Systems and Organization

d. Provide the forms officer a copy of the OMB clearance so the OMB approval number and expiration date may be included on the new or revised form.

e. Enter the appropriate information into the numerical and functional files and the OSHA form listings and catalog.

f. Forward a copy of the DL-1-86, the printing requisition and related papers, and the camera-ready copy of the approved form to the Forms Printing and Supply Officer for printing.

G. External Forms Clearances.

1. The OSHA Forms Management Officer secures external forms clearances for forms used to collect information from other Federal agencies and other clearances not included in the paragraphs below.

2. The OSHA Public Reports Officer secures external forms clearances for public use forms, subject to the approval of the OSHA Forms Management Officer.

3. Originators secure external clearances from other DOL agencies, when necessary.

4. Originators are responsible for preparing external clearance documents and providing necessary justifications and clarifications for all external clearances.

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