SS_ 1218-0020 (11-30-10)Final

SUPPORTING STATEMENT FOR THE
INFORMATION COLLECTION REQUIREMENTS OF THE
TRAINING GRANT APPLICATION
OFFICE OF MANAGEMENT AND BUDGET
(OMB) CONTROL NO. 1218-0020 (November 2010)

A. JUSTIFICATION
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.

Section 21 of the Occupational Safety and Health Act of 1970 (the “OSH Act”) (29 U.S.C. 670)
authorizes the Occupational Safety and Health Administration (“OSHA” or the “Agency”) to
conduct directly, or through grants and contracts, education and training courses. These courses
must ensure an adequate number of qualified personnel to fulfill the purposes of the Act, provide
them with short-term training, inform them of the importance and proper use of safety and health
equipment, and train employers and workers to recognize, avoid, and prevent unsafe and unhealthful
working conditions.
Consistent with the training mandate specified by Section 21, the Agency awards grants to nonprofit
organizations to provide part of the required training. To obtain such a grant, an organization must
complete the Training Grant Application (TGA). 1 The following list provides the title of each of the
12 information collection documents contained in the TGA, the information collected by the
document, the purpose for collecting this information, and the statutory and/or regulatory
requirement, if any, for the information:
1. Title: Application for Federal Assistance (Standard Form 424 (Rev. 10-05), Prescribed by OMB
Circular A-102) (OMB No. 4040-0004)
Information Collected: Identifier data (e.g., name, organizational DUNS number, address, and
taxpayer identification number), type of application and applicant organization, title and description
of project, congressional districts, proposed start date and end date, estimated funding and funding
sources, whether or not the application is subject to review by State Under Executive Order (EO)
12372 process, and whether or not the applicant organization is delinquent on any Federal debt.
Purpose: To obtain basic information about the applicant organization and application, as well as
certification by the applicant organization that States having established review and comment
procedures under EO 12372, and that the selected program for this process had an opportunity to
review the application.
Statutory/Regulatory Requirement: 29 CFR 95.12; Department of Labor (DOL)

1

This ICR refers to an organization that is completing the TGA as an “applicant organization.”

2. Title: Program Summary
Information Collected: Basic information about the applicant organization (including the applicant
organization’s full legal name, project director’s and authorized representative/certifying
representative’s name, title, address, and telephone number), requested Federal and non-Federal
funding, applicant organization’s background (e.g., its mission, a description of the membership (if
any)), and a summary of the proposed training program.
Purpose: Used by Agency officials to review and evaluate the highlights of the overall proposal.
Statutory/Regulatory Requirement: None
3. Title: Budget Information (Standard Form 424A (Rev. 7-97), Prescribed by OMB Circular A102)
Information Collected: A budget summary providing a brief description of program functions or
activities, Federal domestic assistance numbers, an estimate of Federal and non-Federal unobligated
funds, and a new budget for Federal, non-Federal, and total funding; data for budget categories (i.e.,
object-class categories (e.g., personnel, travel, supplies, indirect charges)) arranged by program
functions or activities, and funding totals for these budget elements; estimated income (if any)
generated from the proposed project; identifier and funding data on non-Federal resources that the
applicant organization will use to support the project; quarterly estimates of cash needs from Federal
and non-Federal resources; yearly estimates of Federal resources needed for the duration of project;
and a summary of direct and indirect charges.
Purpose: To determine the appropriateness of proposed costs, and to assist OSHA in allocating its
training grant resources.
Statutory/Regulatory Requirement: 29 CFR 95.12, DOL
4. Title: Detailed Budget Backup
Information Collected: Proposed allocation of Federal and non-Federal funds to programmatic and
administrative costs for the funding determinations made in Standard Form 424A; and a detailed
analysis of the estimated income (if any) generated from the proposed project (i.e., total income,
sources (e.g., classes, books, pamphlets), basis of the income (e.g., number of students taught, books
sold), and allocation of the income (to non-Federal resources contribution or to increase the total
grant amount).
Purpose: To determine if the budget information provided on Standard Form 424A is appropriate to
the proposed training activities.
Statutory/Regulatory Requirement: 29 CFR 95.25, DOL

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5. Title: Technical Proposal/Program Narrative
Information Collected: Describes the hazards addressed by the proposed training program, the
trainee population (in terms of geographic locations and the number of employers and workers), and
the applicant organization’s need for Federal funds and ability to manage the grant program (in
terms of managerial experience and organizational and staff experience). Also provides a work plan
that describes the training activities and tasks, quarterly training milestones, the training materials
produced, and how the applicant organization will evaluate training effectiveness.
Purpose: Used to evaluate the merit and competitiveness of the proposed project in terms of the
number of safety and health hazards addressed; the training needs and geographical distribution of
the trainee population; a recruitment plan for trainees; a training evaluation plan; the applicant
organization’s occupational safety and health background, including organizational and staff training
experience; organizational experience in managing a variety of programs and grants; and a budget
that is reasonable, appropriate, complies with Federal cost principles, and has an adequate matching
share, if required.
Statutory/Regulatory Requirement: None
6. Title: Assurances—Non-Construction Programs (Standard Form 424B (Rev. 7-97), Prescribed
by OMB Circular A-102)
Information Collected: Signature of the authorized certifying official, the title of this official, the
name of the applicant organization, and the date it submitted the form.
Purpose: To obtain legally-binding certification from the applicant organization that it: Has the
legal authority to apply for Federal assistance; has the managerial and financial capability to plan,
manage, and complete the proposed project; will give Federal officials access to, and the right to
examine, grant-related documents; will establish an appropriate accounting system; will develop
safeguards to prevent workers from using their positions in a manner that results in their personal
gain, places them or the applicant organization in a conflict of interest, or gives the appearance of
personal gain or a conflict of interest; will complete the proposed project as planned; and will
comply with the requirements of applicable Federal laws, executive orders, regulations, and policies,
including those requirements that govern personnel management, worker discrimination, displacedpersons relocation rights, political activities of workers funded by the Federal government, labor
standards for federally-assisted construction subagreements, the purchase of flood insurance,
environmental quality, preservation of historic property, protection of human and animal subjects,
use of lead-based paint, and financial auditing of Federally-supported projects.
Statutory/Regulatory Requirement: 29 CFR 95.12, DOL
7. Title: Certifications (Combined Assurance, OSHA Form ED 80-0013, 12/98 edition) consisting of:
Certification Regarding Drug-Free Workplace; Certification Regarding Debarment, Suspension and
Other Responsibility Matters; and Lobbying Certification.
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Information Collected: Mailing address of the worksite(s) funded by the grant (optional), signature of
the authorized representative, date of signature, name and title of the authorized representative, and the
name of the applicant organization.
Purpose: To obtain legally-binding certification from the applicant organization that it will comply
with 12 specified conditions for maintaining a drug-free workplace; is not under debarment,
suspension, proposed debarment, a declaration of ineligibility, or a voluntarily exclusion prohibiting
covered transactions with the Federal government; within the last three years, had no civil judgments
rendered against it for commission of fraud and no criminal convictions involving a public (Federal,
State, or local) transaction, violation of Federal or State antitrust statutes, embezzlement, theft,
forgery, bribery, falsification or destruction of records, making false statements, or receiving stolen
property, nor is it under indictment, nor are any civil or criminal charges pending against it, for these
offenses; and, within the last three years, had no public transactions terminated for cause or default.
Statutory/Regulatory Requirement: 29 CFR 98.630, DOL (drug-free workplace); 29 CFR 95.13,
DOL (debarment, suspension, etc.); and 29 CFR 93.110; DOL (lobbying certification).
8. Title: Organization Chart
Information Collected: An organizational chart for the applicant organization showing the location
of the project staff relative to other staff members and the total number of full- and part-time staff
employed by the organization.
Purpose: To ensure that adequate personnel resources are available to implement and complete the
proposed project.
Statutory/Regulatory Requirement: None
9. Title: Evidence of Nonprofit Status
Information Collected: A copy of an IRS letter granting the applicant organization nonprofit status.
Purpose: To ensure that the applicant organization meets the requirement that grant recipients be
nonprofit organizations.
Statutory/Regulatory Requirement: None
10. Title: Accounting System Certification
Information Collected: A statement signed by the certifying representative that the applicant
organization: Has a functioning accounting system that meets seven specified conditions; or is
designating a qualified entity by name and address that will maintain such a system.
Purpose: To prevent fraud and other misuse of grant funds by ensuring that the applicant
organization accounts for these funds using appropriate and accepted accounting practices.
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Statutory/Regulatory Requirement: None
11. Title: Survey on Ensuring Equal Opportunity for Applicants (OMB No. 1890-0014)
Information Collected: Nonprofit private organization voluntarily completes survey identifying if it
has 501(c)(3) status, number of workers, if it is a faith-based/religious organization or non-religious
community-based organization, if it will manage the grant on behalf of other organizations, has ever
received a government grant or contract, applicant’s annual budget, and whether or not it is a local
affiliate of a national organization.
Purpose: To ensure that all qualified applications have an equal opportunity to compete for Federal
funding.
Statutory /Regulatory Requirement: None
12. Title: Resumes of Key Personnel or Position Descriptions, Exhibits, Information on prior
government grants, and signed letters of commitment to the project
Information Collected: This information is collected from applicant organization and includes
resumes of current staff and position descriptions and minimum hiring qualifications for all
positions, whether filled or vacant, that may be assigned to work on the funded project. Work
history, education, and other qualifications such as Certified Safety Professional (CSP), Professional
Engineer (PE), or Certified Safety Hygienist (CIH). If applicable, the applicant is also asked to
include information on prior grants experience including, but not limited to, who issued the grant,
the award amount, the purpose of the grant and the number of years the grant was awarded. Signed
letters of commitment may also be submitted for consideration.
Purpose: Due to the competitive nature of the grant application process, the applicant may elect to
provide additional information for consideration. The Resumes of Key Personnel or Position
Descriptions may be used to evaluate program management and oversight and to obtain instructor
knowledge and experience with OSHA standards and their application to hazards and hazard
abatement. Prior grant experience will be used to establish whether the applicant has prior
managerial and financial capability to plan, manage, and complete the proposed project. The signed
letters of commitment identify support for the applicant’s proposed project.
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.

The list in Item 1 above describes the purpose served by each of the 12 information collection
documents contained in the TGA. In summary, the Agency uses this information to evaluate: the
applicant organization’s competence to provide the proposed training (including the qualifications of
the personnel who manage and implement the training); the goals and objectives of the proposed
training program; the program activities that the applicant organization proposes to implement to
meet these goals and objectives; the appropriateness of the proposed costs; and the applicant
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organization’s compliance with Federal statutes, laws, and regulations governing drug use in the
workplace, nonprocurement debarment, suspension, and related matters, and lobbying activities.
Also required is a program summary that Agency officials use to review and evaluate the highlights
of the overall proposal.
After awarding a training grant, OSHA uses the work plan and budget information provided in the
application to monitor the organization’s progress in meeting training goals and objectives, as well
as planned expenditures. The initial grant award is for one year.
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 adopting this means of collection. Also,
describe any consideration of using information technology to reduce burden.

Beginning in FY 2007, applicant organizations were required to submit their TGA electronically
through the http://www.Grants.gov website.
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.

The paperwork requirements of the TGA are specific to each applicant organization, and no other
source or agency duplicates these requirements or can make the required information available to
OSHA (i.e., the required information is available only from the applicant organization).
5. If the collection of information impacts small businesses or other small entities, describe any methods used to
minimize burden.

OSHA receives applications from various non-profit organizations, some large and some small.
Traditionally larger organizations apply for grants. This information collection does not have a
significant economic impact on small entities.
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.

If OSHA could not collect the information provided by the TGA, or obtain the information less
frequently (than annually), it would not have a record or data to use in evaluating: An applicant
organization’s competence to provide the proposed training; the appropriateness of the goals and
objectives of the proposed training program; the tasks that the applicant organization will implement
to meet these goals and objectives; the appropriateness of the proposed costs; and compliance with
Federal regulations governing nonprocurement debarment and suspension, maintaining a drug-free
workplace, and lobbying activities. Without this information, the Agency would be unable to
determine the extent to which an application meets OSHA’s overall training goals and objectives,
including the training mandate specified by Section 21 of the Act.
7. Explain any 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;

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 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, grantin-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 a 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 instituted procedures to protect the information's
confidentiality to the extent permitted by law.

The Agency began accepting grant applications submitted through the http://www.Grants.gov
electronic grants process in fiscal year 2007.
8. If applicable, provide a copy and identify the data 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 received 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 in the Federal Register on September 21, 2010 (75 FR 57503) soliciting comments on its
proposed extension of the information collection requirements contained in the Training Grant
Application. This notice was part of a preclearance consultation program intended to provide those
interested parties the opportunity to comment on OSHA’s request for an extension by the Office of
Management and Budget (OMB) of a previous approval of the information collection requirements
found in the above Application. The Agency did not receive any comments in response to this
notice.

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9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors
or grantees.

OSHA will not provide payments or gifts to any applicant organization, or any worker of such an
organization, to complete the TGA.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute,
regulation, or Agency policy.

The Agency provides no assurance of confidentiality regarding the information collected by the
TGA because it believes that none of this information is confidential.
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 form whom the information is requested, and any steps to be taken to obtain
their consent.

The Agency believes that none of the information collected by the TGA is sensitive.
12. Provide estimates of the hour burden of the collection of information. The statement should:
 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.
 If this request for approval covers more than one form, provide separate hour burden estimate for
estimates for each form and aggregate the hour burdens.
 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.

During the last three years, OSHA has received an average of 205 TGAs a year. The Agency
estimates that it takes staff members for each applicant organization 56 hours to complete an
application, including the narrative and budget components. OSHA divides the 56 hours per
application between professional staff and clerical staff as follows:

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Average Number of
Professional Staff
Clerical Staff
Combined Totals
Applications 2007-2009:
205
Burden Hours
38 2
18
56
3
Wage Rates
$55.85
$21.37
Cost
$2,122
$385
Total Burden Hours (x 205)
7,790
3,690
11,480
Total Cost ( Total Cost x
$435,010
$78,855
$513,865
205)
Therefore, the annual burden hours and cost of this paperwork requirement are:
Burden Hours: 11,480 hours
Cost: $513,865
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the
collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)
 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.
 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.
 Generally, estimates should not include purchases of equipment or services, or portions thereof, made:
(1) Prior to October 1, 1995; (2) to achieve 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.

Item 12 above provides the total cost of the information collection requirement associated with
completing the TGA.
2

One hour of the 38 hours is for each organization to obtain and provide resumes of key personnel, position
descriptions, exhibits, information on prior government grants and other documentation. Of the total burden 7,790
burden hours, 205 hours are attributed for organizations to obtain and provide this information to OSHA.
3

The Agency is using the same wage rates of certain workers employed under the Federal Government’s
General Schedule (see footnote 4).

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14. Provide estimates of the annualized cost 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 into
single table.

The Federal government would incur a cost whenever it reviews a TGA. As noted above under Item
12, OSHA determined that it receives an average of 205 applications each year. The Agency
estimates that it takes a professional, Program Analyst 4 , GS-13, at a wage rate of $55.85 per hour, 10
hours to review and analyze each application. In making this cost determination, OSHA does not
account for other occupational costs (e.g., equipment, overhead, and support staff expenses) since
these costs are normal expenses and would occur without this requirement. Therefore, the total
annual cost for the Federal government to review these reports is:
205 reports x 10 hours x $55.85 = $114,493
15. Explain the reasons for any program changes or adjustments.

The Agency is requesting an increase of 1,314 burden hours (from 10,166 hours to 11,480 hours).
An adjustment increase of 1,166 hours results from increasing the number of grant applications
received during the last three fiscal years (FY07-FY09) from 184 per year to an average of 205 per
year. There was also a small adjustment decrease of 57 hours as a result of decreasing the time for a
clerical person to compile and submit the application from 18.25 hours to 18 hours. A program
change increase of 205 hours resulted from the Agency adding one hour for each organization to
obtain resumes of key personnel or position descriptions, exhibits, information on prior government
grants, etc. in order to complete a TGA.
16. For collections of information whose results will be published, outline plans for tabulations 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 information, completion of the report, publication dates,
and other actions.

OSHA will not publish the information collected by the TGA.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain
the reasons that display would be inappropriate.

The expiration date will be displayed on the training grant application instructions.

4

Hourly wages for professional staff were based on the government pay scale for a Chicago area GS-13,
step 10 ($55.85). Usually applications are submitted by PhDs, certified safety professionals, certified Industrial
Hygienists, and other professional staff. Hourly wages for clerical staff were based on the government pay scale for
a Chicago area GS-5, step 10 ($21.37). Clerical elements are performed by secretaries and accounting staff.

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18. Explain each exception to the certification statement in ROCIS.

OSHA is not seeking an exception to the certification statement in ROCIS.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This Supporting Statement does not contain any collection of information requirements that employ
statistical methods.

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