This information
collection is approved for 18 months. OSHA's interpretation of the
LOTO Standard appears to have changed significantly since the
standard was promulgated in 1989, with serious implications for the
information collection requirements and burden estimate. In the
1999 approval of this ICR, OMB stated that "The burden hours for
creating machine-specific procedures are not included, based upon
the DOL contention that firms will not be cited if they have
generic site procedures rather than machine-specific procedures".
However, OSHA now concedes that it does require specific procedures
for types of machines that require different energy controls. In
July 2002, OSHA resubmitted this ICR requesting a burden increase
of 745,351 hours for the energy control procedure requirement to
"better reflect the fact that larger establishments, with more
varied types of equipment, will have a substantially greater burden
in assuring that their general procedures meet all of the
requirements of the Standard." This is not consistent with the
original regulatory impact analysis, which assumed one generic
procedure per worksite. Further, commenters argue that OSHA
continues to underestimate the burden. To address this issue, OSHA
shall conduct an economic analysis of this Standard, and any
subsequent guidance, to look at the regulatory impact of the
standard as currently interpreted and enforced (compared to
industry practice before the Standard was promulgated in 1989).
OSHA shall examine the question of whether employers with
lockout/tagout procedures in place prior to 1989 had to take any
additional action upon promulgation of the standard. OSHA shall
report to OMB the results of this analysis upon resubmission of
this ICR in May 2004. Further, OSHA will provide OMB with written
descriptions of particular equipment (with multiple energy sources)
and controls at one or more manufacturing facilities subject to
this Standard, as well as the minimally acceptable written energy
control procedure or procedures that would satisfy OSHA's current
interpretation of the Standard. OSHA will also provide examples of
procedures that do not satisfy the standard because they are too
general ( such material will not be made part of the public
docket).
Inventory as of this Action
Requested
Previously Approved
05/31/2004
05/31/2004
11/30/2002
94,561,759
0
94,561,759
2,462,279
0
2,450,698
0
0
0
The collections of information
contained in the standard are needed to reduce injuries and deaths
in the workplace that occur when employees are engaged in
maintenance, repair, and other service related activities requiring
the control of potentially hazardous energy.
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.
Standard on the Control of Hazardous Energy Sources (Lockout/Tagout) (29 CFR 1910.147)