We continue to
disapprove questions 3 and 4 on this form. They shall be deleted.
Although the agency has requested that we reverse our earlier
disapproval of these questions, this submission is not responsive
to our concerns of 10/24/89. These concerns were: The Department
has not demonstrated that responses to these questions will in fact
allow the Department to assess "technological changes" and "future
product demand." Although the Department states that the
information is needed to "present an objective set of facts to OTAA
and ETA officials," answers to both questions require speculation
about the future and may be highly inaccurate. The Department does
not know how accurate these responses will be, and did not answer
our question, "What are the program consequences if they are in
fact inaccurate?" In addition, questions about technological change
and future product demand would appear to be answerable only by
looking at the industry as a whole, not at a random sample of one
firms customers. END OF EARLIER COMMENTS. On 12/27/89, we asked the
agency to provide information that would respond to these concerns.
As of this date, we have not received any response. Neither does
the agency's Note to Reviewer respond to these concerns. Hence, we
continue to disapprove these questions.
Inventory as of this Action
Requested
Previously Approved
10/31/1992
10/31/1992
10/31/1992
18,630
0
18,630
19,251
0
19,251
0
0
0
THE INFORMATION IS NEEDED SO THE
SECRETARY OF LABOR CAN MAKE DETERMINATIONS OF ELIGIBILITY OF
PETITIONING WORKERS TO APPLY FOR WORKER TRADE ADJUSTMENT ASSISTANCE
IN ACCORDANCE WITH SECTION 222, 223 AND 249 OF THE TRADE ACT OF
1974 AS AMENDED. AFFECTS MANUFACTURERS, WHOLESALERS, RETAILERS AND
DISTRIBUTORS.
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.