1218-0244 2-5-09 (final)

SUPPORTING STATEMENT FOR THE INFORMATION COLLECTION
REQUIREMENTS FOR THE OSHA STRATEGIC PARTNERSHIP PROGRAM
(OSPP) FOR WORKER SAFETY AND HEALTH

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.
29 USC 651 Section 2.(b)(1) of the OSH Act authorizes the collection of information.
Over the past several years, OSHA has expanded on its already substantial experience
with voluntary programs by proposing and implementing various new cooperative
initiatives in the National, Regional, and Area Offices. These efforts are designed to
increase OSHA’s impact on worker safety and health while maximizing OSHA’s
resources. At the same time, these cooperative approaches allow willing employers and
employees to initiate a working relationship with OSHA that is outside the scope of
enforcement.
In 1998 the agency initiated the OSHA Strategic Partnership Program (OSPP) for Worker
Safety and Health. The program allows OSHA to enter into an extended, voluntary,
cooperative relationship with groups of employers, employees, and employee
representatives (sometimes including other stakeholders, and sometimes involving only
one employer) 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 (OSP) aims to have a measurable, positive impact on workplace safety and
health that goes beyond what historically has been achieved through traditional
enforcement methods. Additionally, OSPs allow OSHA to impact multiple worksites,
which help leverage agency resources.
OSHA Instruction TED 8-0.2 was published on November 9, 1998 to provide guidance
on partnership development and management. In 2001 the agency began a review of the
effectiveness of the OSPP. The review showed that partnership success is closely linked
to the development of safety and health management systems, as well as to the other core
elements required as part of a partnership. 1 On February 10, 2005 the agency issued
OSHA Instruction CSP 03-02 which provides further clarity for program policies and
procedures. The new Directive eliminates Comprehensive and Limited subclassifications and streamlines the core elements, which are now required for all OSPs.
Each partnership agreement sets goals and objectives to help guide partnership activity
and determine partnership success. Measurements are then defined, and agreed upon by

1

To view the directive, go to
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVE
S&p_id=3186

1

all the partners, that relate directly to those goals and objectives. By definition, the
measurements will require information collection on the part of the partners.
In the development of OSPP policy, OSHA considered the positive impact that OSPs can
have on worker safety and health and how the agency, by collecting information and
conducting ongoing evaluations, can ensure that these OSPs achieve the intended results.
The need to collect information is an integral part of OSHA’s strategic planning process,
and the OSPP, like other agency programs, is required to regularly provide information to
the agency. The agency uses this information to evaluate the effectiveness of its
programs, identify needed improvements, and ensure that resources are being used to
maximum effectiveness.
During the development stage of each OSP, the partners determine what information will
be needed. This process involves identifying the needed information, determining the
best collection method, and clarifying how the information will be used. Because the
participating private sector employers have strong input regarding information collection,
OSHA is confident that data collection efforts are prudent and do not create undue an
burden on the partners.
At a minimum, each OSP must identify baseline illness and injury data corresponding to
all summary line items on the OSHA 300 log, and must track changes at either the
worksite level or participant-aggregate level. No other specific measures are universally
required for all OSPs. An OSP may also include other measures of success, such as
training activity, self inspections, 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 evaluating
the effectiveness of safety and health management systems and other worker protection
measures.
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.
Information is collected by the partners directly, by a third party in association with the
partnership, or sometimes directly by OSHA (i.e., during onsite verification visits).
OSHA and its partners use the information to evaluate the impact of the partnership in
term of improvements to baselines measures, number of sites and employees affected,
and other successes. OSHA also uses this information to assess the agency’s progress in
meeting strategic management plan goals and strategies.
Over 1,437,146 employees and 27,104 employers have participated in the program since
its inception. Partnerships address the most serious workplace safety and health issues
and strive to reduce fatalities, injuries, and illnesses in a myriad of industries.
One of many success stories involves the Lowe’s Regional Distribution Center
Construction Project, which started in July 2006 and originated in the Aurora, Illinois

2

OSHA Area Office. The partnership called for the development and implementation of
comprehensive safety and health management systems at participating job sites. Ragnar
Benson LLC acted as the primary information collector, and provided data for both its
company and site subcontractors for activities conducted in conjunction with the
partnership. As a result of information gathered through the partnership, OSHA can
demonstrate that the total recordable case incident rate for the project was 1.4 (74
percent) below the national average. Achieving excellent safety and health was a key goal
for this partnership. Daily inspection and comprehensive monthly inspections were
conducted on a consistent basis. Training was also emphasized with over 225 employees
(including supervisors) receiving over 600 training hours.
OSHA’s ability to gather this information allows them to assess and promote the OSPP.
More importantly, the success experienced by these participants, when shared with other
companies, serves as a model to improving worker safety and health.
3. Describe whether, and to what extent, the collection of information involves the
use of automated, electronic, mechanical, or other technological collection
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 burdens.
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.
OSHA has developed electronic versions of the Annual Evaluation Form and an
electronic OSPP data entry Form for use by OSHA staff. These forms are available on
OSHA’s Intranet web pages. Additionally, OSHA is in the development stage for an
automated data system, which will eventually be available to OSHA staff online and will
further streamline reporting and evaluation tasks.

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 is unique, and the information needed is available only from that
partnership. OSHA generally requires existing data found in the OSHA 300 Log or
information that is required by current OSHA standards and regulations. As a partnership
is established, the participants will identify additional data that they determine is needed
to assess the effectiveness of the OSP.
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.

3

Members of each partnership determine what information collection is required to
measure its success or failure. Including employers and employees in this process helps
minimize the information collection burden. The only OSHA required burden on small
businesses is the reporting of OSHA 200/300 Log data.
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 frequency (on average once initially and again on an annual
basis) is minimal. To eliminate or reduce the submission requirements would effectively
cripple OSHA’s ability to measure success as required by the Government Performance
Results Act (GPRA) and OSHA’s Strategic Management Plan. There are no technical or
legal obstacles to reducing the burden.
7. Explain 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

4

instituted procedures to protect the information’s confidentiality to the extent
permitted by law.
There are no special circumstances that would require the information to be collected in a
manner that is inconsistent with the above guidelines.
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.
As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3506 (c)(2)(A)), OSHA
published a notice on November 14, 2008 (FR 73 67546, Docket No. OSHA-2008-0041)
requesting public comment on its extension of the information collection requirements
specified in the OSHA Strategic Partnership Program for Worker Safety and Health
(OSPP). This notice was part of a preclearance process intended to provide those
interested parties the opportunity to comment.
The Agency received one comment from Ms. Mallory Garth. We thank Ms. Garth for the
comment. Ms.Garth suggested that the Agency overestimated the burden hours based on
the increase in the number of partnerships and recommended doubling the burden hours.
The 303,493 burden hour increase results mainly from calculating the burden per
employer in each partnership, rather than previously calculating burden per partnership.
This is why we cannot simply double the burden hours.

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration 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

5

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.
OSPP participants are not subjected to questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The
statement should:
ƒ

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.

ƒ

If this request for approval covers more than one form, provide separate
hour burden estimates for each form.

ƒ

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.

Number of Partnerships
Estimates and summaries in this Supporting Statement are based on the information
collected since the beginning of the last approval period. There were 172 open
partnerships at the end of FY 2008. Based on program experience during the last
approval period, OSHA estimates that 58 new partnerships will be added to the program
each year, and approximately 62 partnerships will close each year due to expiration or
termination of the project. Therefore, the average number of partnerships per year for the
next three years will be 164.

6

Table 1

Fiscal
Year

Base (Open OSPs
on October 1st)

2006
2007
2008

182
146
149
Average
172
168
164

2009
2010
2011

New
Partnerships
(+)
35
60
80
58
58
58
58

Concluded
(-)
71
57
57
62
62
62
62
Average

Total

146
149
172
168
164
160
164

Number of Respondent Employers
Information received through initial estimates and each partnership’s annual evaluation
allows OSHA to track the number of participants in each partnership. Based on totals at
the end of each of the last three fiscal years, OSHA can estimate that each partnership has
an average of 148 participant employers, and that the program overall has an average of
23,119 active participants each year.
Table 2
Fiscal Year
2006
2007
2008
Average

Partnerships Open as of
September 30th
146
149
172
156

Total Participant
Employers
20,408
21,844
27,104
23,119

7

Average
Participants/
Partnership

148

Annual Burden Hours, Frequency, and Cost
Based on the averages gleaned from Tables 1 and 2, the following estimates can be established for burden hours and costs:
Table 3
Information
Collection

Frequency

Number
of
Partnersh
ips

Average
Number of
Participants
per Partnership

58

148

Hours per
Participant

Total Annual
Hour
Burden
Employer

Partnership Establishment2
Professional @ $33.74
OSHA GS13 (01) @ $39.88
Partnership Implementation3
Professional @ $33.74
Measurement and Evaluation4
Office Clerk @$17.49
OSHA GS13 (01) @ $39.88
Total

Once

Ongoing
Annual

164
164

11
2

94,424

8

194,176

3
3

72,816

OSHA

Estimated
Annual
Costs
Employer

OSHA

$3,185,866
116

$4,626

148
$6,551,498

148

361,416

2

$1,273,551
492
608

$11, 010,915

$19,620
$24,246

Partnership Establishment includes the time needed to develop the partnership requirements, craft agreement language, and conduct
an internal review process. OSHA estimates a total of 11burden hours per participant and 2 burden hours for OSHA for establishing
a partnership.
3
Partnership Implementation includes the development of management systems and/or specific programs and procedures to address
hazards. The amount of time needed for this task varies based on the status of existing programs and systems, and the level of
improvement needed.
4
Participating employers are required to gather information in the type and format agreed upon during the formation of the
partnership. OSHA is responsible for compiling the data into an annual evaluation as outlined in Appendix C of the OSPP Directive.
The total annual burden hours multiplied by a representative hourly wage. Base hourly wages were determined using the mean wage
rates from “May 2007 National Industry-Specific Occupational Employment and Wage Estimates,” U.S. Department of Labor,

8

Bureau of Labor Statistics http://www.bls.gov/oes/current/oessrci.htm#56. Total compensation for these occupational categories
includes an adjustment of 29.4 percent (Employer Costs for Employee Compensation, June 2008, pp.1) for fringe benefits; this figure
represents the average level of fringe benefits in the private sector. OSHA burden costs are based on the Office of Personnel
Management’s 2008 General Salary Schedule.

9

13. Provide an estimate of the total annual cost burden to respondents or record
keepers resulting from the collection of information. (Do not include the cost of
any hour burden shown in Items 12 and 14).
ƒ

The cost estimate should be split into two components: (a) a total capital and
start-up cost component (annualized over its 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.

ƒ

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.

ƒ

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) states 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, record keeping,
or disclosure activities needed to comply are usual and customary.” Any capital or startup 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 Program. Start-up costs are included in the cost of
preparing these submissions. The reporting costs to partners that may choose to have a
third party collect their data are included in the cost estimates in Section 12. This section
is therefore not applicable.

10

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.
Costs incurred by the Federal government include approximately two hours per each new
partnership in development and establishment, and three hours annually for evaluation.
The cost is computed using the hourly rate of a GS-13 ($39.88), for a total of $24,246.
The costs incurred in conducting onsite verification visits are part of the routine cost of
conducting OSHA compliance assistance and enforcement activity and not specific to the
OSPP.
15. Explain the reasons for any program changes or adjustments.
The agency is requesting an adjustment increase of 303,493 hours as a result of the
anticipated increase in the number of respondents. Also to better reflect the participant’s
burden, the agency changed the burden hour calculation methodology. Previously when
calculating burden hour for establishing Partnerships we took burden per partnership.
This package now takes burden per average partnership participant.
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.
Additionally, the agency is in the process of conducting an overall program evaluation for
the OSPP, which will be available internally to improve program performance and
increase impact on worker safety and health.
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 in ROCIS.
There are no exceptions to the certification statement identified in Item 19.

11