We are filing
the following comments on these proposed information collections.
Pursuant to 1320.13(e), the agency shall explain in the final rule
how it has responded to these comments. First, the agency has not
demonstrated that the training requirements at (l)(3)(i)(A)(1) have
practical utility, particularly when added to the general
requirements at (l)(3)(i)(A). The agency has cited no data
supporting the need for 24 hours annual training, monthly training
sessions, or quarterly competency demonstrations. Also, the agency
has estimated identical training burdens for the interim final and
proposed rules, despite considerable differences between them.
Final estimates shall explicitly consider those differences.
Second, the final rule shall explain why similar EPA or other
Federal paperwork requirements cannot fulfill the purpose of this
rule, and shall eliminate any duplicative paperwork. Third, each
element of the safety and health program shall be separately
justified in terms of its contribution to employee safet and
health. Fourth, the practical utility of (h)(3)(v) is unclear,
given (h)(3)(i)-(iv). Fifth, the health benefit and practical
utility of annual medical surveillance has not been
demonstrated.
Inventory as of this Action
Requested
Previously Approved
03/31/1988
03/31/1988
1
0
0
1
0
0
0
0
0
THIS INFORMATION IS NEEDED BY
EMPLOYERS AND EMPLOYEES INVOLVED IN HAZARDOUS WASTE OPERATIONS AND
EMERGENCY RESPONSES TO PREVENT ILLNESS AND INJURY DUE TO EXPOSURE
TO HAZARDOUS WASTES.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.