Supporting_Statement_HM-Access_Pilot_Part B_062414

Office of the Chief Information Officer

Department of Transportation

Supporting Statement—Part B

Hazardous Materials Shipping Papers and Emergency Response Information

(Expiration Date: October 31, 2015)

Part B. Collections of Information Employing Statistical Methods:

This information collection is a qualitative research study that does not employ statistical methods. PHMSA is not selecting a random sample from the entire HM community; rather, PHMSA will select pilot test participants from volunteers who have previously expressed an interest in participating by submitting a “I wish to volunteer” comment either to the 60-Day Notice or to the April 2013 HM-ACCESS website inbox. These volunteers have knowledge and experience with HM transport and shipping paper requirements.

PHMSA is required to provide pilot test data in a report to Congress by October 1, 2014, including a recommendation on whether a regulatory change allowing for companies who can provide HM shipping paper information electronically should be allowed. PHMSA is conducting a qualitative study rather than a statistically significant survey because it needs to obtain a general understanding of how electronic systems (e-systems) already being used by the HM community could also potentially be used to provide HM shipping paper information electronically, and to include this information in the October 2014 report. This electronic data must be capable of being successfully transferred among HM stakeholders (shippers, carriers, inspectors, and emergency responders) at least as quickly and safely as offered by the current hardcopy requirement. PHMSA realizes that the nonprobability data obtained during the pilot test will only provide limited preliminary, non-generalizable information. PHMSA views this pilot test as a preliminary step in gathering nonprobability data to include in the October 2014 report, and anticipates that future additional studies involving larger HM community samples may be performed.

Pilot test information will be collected via online question sets designed to represent observations of a very small, nonprobability sample of HM stakeholder volunteers (i.e., convenience sample) for a finite pilot test period (8 to 12 weeks). As such, the pilot tests can be considered a type of pilot “case study,” where direct observation of the transfer and receipt of HM shipping paper information is studied within the actual HM transport environment and recorded in the question sets by pilot test participants; these observations will then be reviewed by PHMSA to develop non-statistical qualitative results information. The question sets will serve as the “snapshot in time” data collection method of observations as to whether e-systems can be used at this moment in time by the volunteer stakeholders included in the pilot test to successfully communicate HM shipping paper information among the volunteer shippers, carriers, inspectors, and emergency responders in all four transportation modes (air, maritime, rail, and roadway). Online collection offers an easy way for volunteers to provide their observations in a standardized format, and uses yes/no, multiple choice, and checkbox answers as much as possible.

1. Describe potential respondent universe and any sampling selection method to be used.

1. Respondent Universe

As described in the 30-Day Notice, the respondent universe includes 73 of the total 83 entities who either responded to the April 2013 PHMSA website announcement or commented to the 60-Day Notice indicating they wish to participate in the pilot tests. These 73 entities include ten (10) emergency response organizations, three (3) Federal government agencies, three (3) state/local government agencies, five (5) law enforcement agencies (one Federal agency, three state agencies, and one port authority), one (1) university, thirteen (13) carriers, five (5) shippers, nine (9) companies that are both shippers and carriers, one (1) association, one (1), union, eleven (11) consultants, two (2) technology vendors, five (5) companies that function as both vendors and consultants, and four (4) unknowns. The four (4) unknowns only provided a message indicating they want to participate. Based on location information provided by some in their comments and from a cursory Internet search performed by PHMSA, these 73 entities are primarily located in the eastern half of the U.S. and in the South, with a few located in the Southwest, Northwest, and at international locations. Many of the entities have locations in multiple U.S. areas. Since posting of the 30-Day Notice in the Federal Register on November 25, 2013, four (4) additional entities posted comments indicating their desire to participate in the pilot tests to the www.regulations.gov website: one (1) shipper/carrier company, one (1) emergency response organization, and two (2) entities who posted only their names located in Washington D.C. and Port Saint Lucie, FL. These 77 entities form the “universe” of potential pilot test participants from which PHMSA will select actual pilot test participants. PHMSA may seek additional volunteers, such as inspectors and emergency responders, if, following the evaluation and selection of participants, it is determined that additional participants are needed to satisfy the goals of the pilot tests.

For purposes of estimating the number of shippers and carriers who may participate in the pilot tests, PHMSA added the thirteen (13) carriers, five (5) shippers, nine (9) companies that are both shippers and carriers, four (4) unknowns, one (1) shipper/carrier who commented after the 30-Day Notice was posted, and the two (2) names only “unknowns” who also commented after the 30-Day Notice was posted, for a total of 34. PHMSA added an additional 21 as a safety factor (to account for single companies with multiple shipper/carrier locations and to provide for other entities who may have been categorized differently), resulting in the maximum number of 55 shippers and carriers who may potentially participate in the pilot tests.

In estimating the number of inspection agencies/organizations who may participate in the pilot tests, PHMSA added the three (3) Federal government agencies, three (3) state/local government agencies, five (5) law enforcement agencies, four (4) unknowns, and the two (2) names only “unknowns” who commented after the 30-Day Notice was posted, for a total of 16 agencies/companies spread throughout the U.S. These agencies have multiple inspectors who are responsible for conducting HM inspections at fixed sites and while the HM is in transport, for both pre-planned (i.e., at a checkpoint, waystation, etc.) and impromptu (i.e., based on potential safety risk posed by an observed transportation conveyance) activities. PHMSA estimates a maximum of 260 inspection simulations conducted by these inspectors, based on conducting up to 65 inspection simulations in each of three to four regions during the pilot tests. PHMSA also assumes that approximately 50% of the inspectors (130 inspectors) will conduct multiple (i.e., two, for estimation purposes) pilot test inspection simulations.

In estimating the number of emergency response companies/organizations who may participate in the pilot tests, PHMSA added the ten (10) emergency response organizations, four (4) unknowns, one (1) emergency response organization who commented after the 30-Day Notice was posted, and the two (2) names only “unknowns” who also commented after the 30-Day Notice was posted, for a total of 17. PHMSA rounded the estimation to 18, and assumes that 25% of the emergency responders (six (6) emergency responders) will conduct multiple (i.e., two, for estimation purposes) simulations, bringing the maximum total number of emergency response simulations to 24. Emergency responders expected to participate in the pilot tests include first responders (fire personnel, police officers, etc.) and public safety answering point (PSAP) dispatch personnel.

Once PHMSA selects the pilot test participants, it will hold pilot test orientation meetings via webinars for all pilot test participants. PHMSA plans on holding a separate orientation meeting for each of the three or four pilot test regions; each meeting will last approximately 2 hours. Prior to these webinars, PHMSA will identify regional pilot test participant agencies/companies/organizations and describe the logistics (dates, times, modes, marine terminals, airports, etc.) associated with each regional pilot test; this information will be provided to participants prior to the webinar. PHMSA will prepare a preliminary regional schedule, including potential locations for conducting the inspections and emergency response simulations; this draft schedule will be discussed and fine-tuned during each regional webinar. PHMSA is assuming that approximately 203 representatives from the volunteering agencies/companies/organizations (55 shipper/carrier companies, 18 emergency response agencies, 130 inspection organizations) will participate via webinar in these orientation meetings.

The Impact Analysis Question Set will be offered to the HM community members (including, but not limited to, shippers, carriers, emergency responders, and inspectors who participate in the pilot tests) and will run concurrent with the pilot tests. This question set is designed to collect nonprobability HM stakeholder information to aid in the assessment of potential impacts, including cost-benefit information, associated with using e-systems. Because this question set is intended to be distributed to a limited HM audience (i.e., pilot test participants and other HM stakeholders who communicated with PHMSA during the past two years regarding this program, with 250 maximum estimated respondents), the questions can be vetted first by this limited distribution group to identify any needed question modifications, in anticipation of PHMSA potentially sending a revised question set to the larger HM community in a later information collection package to further obtain e-system impact information.

The following are the respondent estimates and burden hours (maximums) associated with completing the four question sets described in the 30-Day Notice, participating in the orientation webinar meetings, and participating in the pilot tests:

Activity	Maximum Total Number of Estimated Respondents/Participants	Number of Respondents Who May Complete Multiple Simulations	Burden Hours (per question set/activity)	Total Burden Hours
Shipper and Carrier Participant Question Set	55	N/A	0.5	27.5
Inspection Simulation Question Set	260	130	1.0	260
Emergency Response Simulation Question Set	24	6	1.0	24
Impact Analysis Question Set	250	N/A	1.0	250
Total Number of Estimated Respondents and Total Burden Hours for Completing All Question Sets	589	--	--	561.5
Participation in Webinar Pilot Test Orientation Meetings	203	--	2	406
Pilot Test Participation
Shipper and Carrier Pilot Test Participation and Information (includes participating in the pilot tests and providing information to the inspectors and emergency responders, if requested)	55	N/A	3	165
Inspector Pilot Test Participation	260	--	0.1	26
Emergency Responder Pilot Test Participation	24	--	0.5	12
Total Burden Hours				1,170.5

2. Sampling Methods

PHMSA will email the Shipper and Carrier Participant Question Set to each of the 55 shipper and carrier companies/organizations who expressed an interest in participating in the pilot tests (by either emailing PHMSA’s HM-ACCESS web account and/or responding to the 60-Day Notice), with a request for each entity to a) confirm it is still interested in participating in the pilot tests and b) complete the question set by a closing date (to be determined). Each shipper and carrier company/organization will be requested to complete an Informed Consent Form and one Shipper and Carrier Participant Question Set. PHMSA will review completed question sets, verify that shippers and carriers possess the necessary qualifications and capabilities for pilot test participation, and select those who meet the following minimum criteria for inclusion in the pilot tests:

• Offer HM for transportation and/or transport HM by a variety of modes;

• Interact with other intermodal carriers for HM transfers;

• Ship and/or transport HM within areas of high concentrations of HM registrants and HM incidents;

• Possess e-system(s) capable of managing and communicating the HM shipping paper information at their own expense;

• Possess their own equipment and personnel and/or contractor resources necessary to transport HM shipments;

• Be willing to allow, and participate in, pilot test inspections and emergency response simulations;

• Be willing to provide feedback on experiences regarding e-HM communication during the pilot tests, including providing actual e-HM communications data from the pilot tests;

• Be willing to provide information on the basic function and capabilities of their e-system(s);

• Be willing to provide information on administrative, business, training, equipment, and operational-related benefits and costs associated with the implemented e-system(s);

• Transport HM within the targeted pilot test regions of the U.S.; and

• Be in good standing with all levels of government and demonstrate compliance with all applicable regulations governing the safe and secure transportation of HM.

Shippers and carriers who do not or are unwilling to complete the Informed Consent Form and the Shipper and Carrier Participant Question Set will not be selected for inclusion in the pilot tests.

The Inspection and Emergency Response Simulation Question Sets will be completed by law enforcement inspectors and emergency responders who participate in the pilot tests; each simulation will result in a completed question set. The 260 (inspection) and 24 (emergency response) maximum estimates previously displayed are the total number of question sets estimated to be completed during the pilot tests; each pilot test inspector/emergency responder may complete more than one question set if he/she performs more than one simulation. For purposes of calculating the burden associated with the question sets, PHMSA assumes that 50% of the inspectors and 25% of the emergency responders (130 inspectors and six (6) emergency responders) will conduct multiple (i.e., two) simulations; these calculations are represented in the previous table. PHMSA will email each pilot test inspector and emergency responder a link to the respective question set once pilot testing begins; the email will also include instructions that inspectors and emergency responders are requested to 1) complete a separate simulation question set for each pilot test simulation they perform, and 2) provide PHMSA an electronic copy of the HM shipping paper information they received during the simulation and a hardcopy of the actual HM shipping paper (for information verification purposes).

The inspection and emergency response simulations will occur in three to four U.S. regions, which will be selected once PHMSA finalizes the shipper and carrier pilot test volunteer participants. At least one rural area will be included in one of these regions, per MAP-21 requirements. The following tables identify PHMSA’s simulation estimations by mode for three and four regions:

Inspection Simulations by Mode and Region (based on 260 maximum)

		Region A	Region B	Region C	Region D (optional)
MODE	Air	5	5	5	5
	Maritime	5	5	5	5
	Rail	15	15	15	15
	Roadway	40	40	40	40

Because most HM in the U.S. is transported via roadway, PHMSA intends to conduct the majority of inspection simulations (85%) on HM being transported on roadways and via rail. Scenarios that will be used during these roadway and rail inspection simulations will include a variety of scenes such as:

• Rail cars/trucks containing bulk HM (i.e., a single HM in a rail car/truck)

• Rail cars/trucks containing mixed HM loads from multiple shippers/carriers

• HM on roadway and/or rail in rural area

• Roadway intramodal transfers

The remaining 15% of inspection simulations will be conducted on HM transported via planes and vessels. Because it will be difficult to conduct these simulations while the conveyance is actually in transport (i.e., in the air or at sea), the majority of these inspections will be conducted at an airline or port terminal. Scenarios that will be used during the air and maritime inspection simulations will include a variety of scenes such as:

• Pilot/captain or his/her designee available for consult with inspector

• Pilot/captain or his/her designee incapacitated and unavailable for consult

Emergency Response Simulations by Mode and Region (based on 24 maximum)

		Region A	Region B	Region C	Region D (optional)
MODE	Air	1	1	1	1
	Maritime	1	1	1	1
	Rail	2	2	2	2
	Roadway	2	2	2	2

Because emergency responders provide assistance during emergencies (as opposed to inspectors, who provide pre-planned and impromptu HM inspections as part of their normal operations), the number of planned emergency response simulations (24) is lower than the number of planned inspection simulations (260) in order to minimize burden to emergency responders. In addition, the emergency response simulations will be planned “hypothetical emergencies” and will only test the e-communication of HM shipping paper information between the shipper/carrier and the emergency response company/organization. Scenarios that will be used during these emergency response simulations will include a variety of hypothetical scenes such as:

• Pilot/captain/conductor/driver available for consult with responder

• Pilot/captain/conductor/driver incapacitated and unavailable for consult

2. Describe procedures for collecting information, including statistical methodology for stratification and sample selection, estimation procedures, degree of accuracy needed, and less than annual periodic data cycles.

1. Electronic Question Sets

All four question sets will be deployed electronically. Each respondent will receive a link via an email from PHMSA that will take him/her to the respective question set. The data collection effort described in this supporting package was purposefully designed to collect information electronically from respondents to:

• Minimize the burden on the public for the information collection effort;

• Allow respondents, wherever possible, to select answers from built-in yes/no, multiple choice, and checkbox selection menus;

• Ensure the nonprobability data can easily and efficiently be reviewed by PHMSA across all individual responses, by each transportation mode, across all transportation modes, and within each question set; and

• Provide non-generalizable information PHMSA can use to provide an initial recommendation, provided together with PHMSA’s assumptions and limitations, to Congress on whether e-systems can potentially be offered as an alternative for conveying the HM shipping paper information while maintaining at least the current level of safety and without negatively impacting HM commerce.

Each of the following information collection activities will have an associated Informed Consent Form (refer to Appendix A):

• Shipper and Carrier Informed Consent Form (covers shipper and carrier companies/organizations and all company/organization employees and contract personnel, including all activities associated with completing the Shipper and Carrier Participant Selection Question Set and participating in the pilot tests)

• Webinar Pilot Test Orientation Meeting Informed Consent Form (covers all shippers, carriers, law enforcement, and emergency responder agencies/companies/organizations, along with their employees and contract personnel, participating in the webinar and exchanging information in support of, during, and immediately following the pilot tests)

• Inspector Informed Consent Form (covers all law enforcement agencies/companies/organizations who participate in the pilot tests, including the completion of Inspection Simulation Question Sets)

• Emergency Responder Informed Consent Form (covers all emergency response agencies/companies/organizations who participate in the pilot tests, including the completion of Emergency Response Simulation Question Sets)

• Impact Analysis Informed Consent Form (covers all HM stakeholders who complete an Impact Analysis Question Set)

PHMSA will collect information from the four question sets electronically. All responses will be entered into an on-line data collection tool, with each response being captured in the tool once. Data from each pilot test inspection and emergency response simulation will be entered into the on-line data collection tool once.

2. Shipper and Carrier Participant Question Set and Procedures

Upon receiving OMB approval of this supporting package, PHMSA will email a unique link to the Shipper and Carrier Participant Question Set to each of the 55 shipper and carrier companies/organizations who expressed an interest in participating in the pilot tests with a request for each entity to a) confirm it is still interested in participating in the pilot tests and b) complete the Informed Consent Form and the Shipper and Carrier Participant Selection Question Set by the closing date (to be determined after OMB approves this information collection effort). Each shipper and carrier company/organization will only have to complete this question set once. PHMSA anticipates that senior shipper/carrier company/organization representatives who have authority to volunteer the company/organization to participate in the pilot tests will complete the Informed Consent Form and the question set. Once the closing date is reached, PHMSA will review completed question sets, verify that shippers and carriers possess the necessary qualifications and capabilities for pilot test participation, and select those who meet the minimum criteria described in Section 1.B of this Part for inclusion in the pilot tests. Shippers and carriers will be notified via email of their selection status; those who are selected as participants will be asked to confirm they still want to participate, and will also receive a separate email indicating the date, time, and webinar address for the orientation meeting.

Desired pilot test shipper participants are individuals knowledgeable about HM classes; their company’s/organization’s HM transportation procedures; and PHMSA’s shipping paper requirements as stated in 49 CFR 172. These shippers should also be responsible for completing, or providing instruction to employees who complete, shipping papers. Desired pilot test carrier participants are individuals who operate HM transportation conveyances (planes, ships, trains, trucks, etc.); are responsible for receiving and/or transferring HM from shipper locations and/or from other carrier conveyances/locations; and are familiar with PHMSA’s shipping paper requirements as stated in 49 CFR 172.

Template communication emails for shippers and carriers are provided in Appendix B.

3. Region Selection, Alignment, and Planning Activities

After PHMSA selects the volunteer pilot test shipper and carrier participants, it will use the information provided in the completed Shipper and Carrier Participant Question Sets to:

• Align the shipper and carrier participants into three or four U.S., regions (Note: Based on PHMSA’s cursory review of the main locations where pilot test volunteer are located, the Northeast, South, Southwest, and Northwest appear to be potential pilot test regions. These regions are very broad, and some overlap. PHMSA will be able to select the actual pilot test regions, including boundaries, once it receives the completed Shipper and Carrier Participant Question Sets.);

• Ensure, as much as possible, that all modes are covered by the shipper and carrier participants in each region;

• Verify that at least one pilot test region includes a rural area through which a shipper/carrier participant’s HM shipment will travel during the pilot test;

• Create rudimentary HM transportation shipment routes for all modes in each pilot test region, based on information provided by the shippers and carriers in the Shipper and Carrier Participant Question Sets;

• Review the list of potential law enforcement inspectors and emergency responders, and determine the region to which they will align (Note: Ideally, PHMSA will attempt to align emergency responders and inspectors within a 30-mile radius (maximum) from a location along the pilot test HM shipment route.); and

• Ensure, as much as possible, that the number of simulations per mode and region meet the estimates provided in 1.B of this Part.

This information will be summarized in a draft pdf document after PHMSA selects the volunteer pilot test shipper and carrier participants. This document will be provided via email to webinar participants approximately one week prior to the webinar.

4. Inspection Simulation and Emergency Response Simulation Question Sets and Procedures

After PHMSA selects the volunteer pilot test shipper and carrier volunteer participants, determines the three or four test regions, and drafts rudimentary HM transportation shipment routes for all modes in each pilot test region, it will review the list of potential emergency responders and inspectors, and determine the region to which they will align. PHMSA will then send an email to all inspectors and emergency responders:

• Asking them to confirm by a closing date (to be determined once OMB approves this information collection effort) they still want to volunteer to participate in the pilot test simulations; and

• Providing a brief explanation that they are being asked to:

  • Conduct inspections according to their company’s/organization’s current inspection or emergency response procedures using their company’s/organization’s equipment and staff resources;

  • For emergency response simulations, responders will be reminded they are only simulating an emergency, and will only request electronic shipping paper information corresponding to the information they would normally look for on a hardcopy shipping paper;

  • Complete an Informed Consent Form associated with the simulation collection activities;

  • Complete one online Inspection or Emergency Response Simulation Question Set for each simulation;

  • Submit a copy of the electronic HM shipping paper information received for each simulation conducted; and

  • Provide PHMSA either by email, fax, or post, with a hardcopy of the HM shipping paper information received from the shipper/carrier.

After the closing date for response, PHMSA will send a follow-up email to all inspectors and emergency responders who are still interesting in volunteering to participate in the pilots tests identifying the dates and times for the regional webinars. Desired pilot test law enforcement inspectors are those who periodically conduct pre-planned and/or impromptu modal inspections of HM transportation conveyances, such as police officials, sheriffs, modal inspectors, etc. Desired pilot test emergency response personnel include first responders, fire personnel, emergency services dispatchers, etc.

Next, PHMSA will attempt to align emergency responders and inspectors within a 30-mile radius (maximum) from a location along the pilot test HM shipment route. Because this alignment may not be possible in all cases, especially in rural areas using mostly volunteer response groups with large jurisdictional areas of responsibility, PHMSA will prepare draft inspection and emergency response simulation logistics plans, where modal HM shipments are represented along with potential locations for inspectors and emergency responders to conduct pilot test simulations within as close to a 30-mile radius from the HM transportation conveyance as possible. These draft simulation logistics plans will be emailed to the volunteer inspectors and emergency responders at least one week prior to the respective webinar for their input.

5. Pilot Test Webinar Orientation Meetings

After selecting and communicating via email with volunteer pilot test participants, PHMSA will coordinate the development of three to four webinars, based on the number of regions selected for the pilot tests. Each webinar will be two hours in duration, and all regional pilot test participant organizations, and preferably the actual pilot test participants, will be invited to attend. Webinar participants will be requested to complete an Informed Consent Form prior to the webinar. For purposes of calculating burden associated with webinar participation, PHMSA is estimating one representative per each volunteer organization (refer to section 1.A of this Part).

Each webinar will include:

• An introduction of all agencies/companies/organizations participating in the regional pilot test;

• The modes, facilities, and HM transportation corridors that will be included in the regional pilot test;

• The dates of the regional pilot test;

• Description of the equipment, e-systems, and electronic data formats used by each regional volunteer pilot test participant to transmit and/or receive e-HM shipping paper information;

• Identification of any law enforcement- or emergency response-specific procedures or limitations that could potentially impact electronic data transmission during the pilot tests;

• Means for identifying HM transportation conveyances participating in the pilot tests during actual HM transport;

• Refinement of the draft HM transportation pilot test modal shipment routes;

• Refinement of the draft simulation logistics plans disseminated to regional pilot test volunteer participants prior to the webinar;

• Procedures and methods for communicating with each other and with PHMSA during and immediately following the pilot test; and

• Discussion of any questions participants may have regarding implementation of the pilot tests.

PHMSA will edit the draft HM transportation modal shipment routes and simulation logistics plans based on comments from webinar participants. While PHMSA will email final shipment routes and simulation logistics plans to regional volunteer pilot test participants before the start of the pilot test period, these plans will still be subject to change during the actual pilot tests (based on route changes, shipment modifications, etc.).

6. Impact Analysis Question Set and Procedures

Once the pilot test begins, PHMSA will send an email, with a link to the Impact Analysis Question Set and Informed Consent Form to a limited group of HM stakeholders (pilot test volunteers and other HM stakeholders, including technology vendors, who have contacted PHMSA in the past two years regarding the MAP-21 pilot project) explaining the current status of the pilot tests and introducing the Impact Analysis Question Set. PHMSA will provide the following information in these emails:

• Participation in this online information collect effort is completely voluntary;

• Participation in the online information collection will require completing an Informed Consent Form;

• PHMSA will not provide any monetary compensation for completing the question set;

• Completion of the online question set is expected to take no more than 60 minutes to complete;

• PHMSA will make every effort to ensure respondents’ answers remain private to the extent provided by law;

• The types of information being asked for in the Impact Analysis Question Set;

• The open period for completing the online question set; and

• A statement that this question set will be limited to the first 250 respondents.

The 250 maximum volunteer respondents expected to complete this question set will allow these questions to be vetted first by this limited distribution group to identify any needed question modifications, in anticipation of PHMSA potentially sending a revised question set to the HM community in a later information collection package to further obtain e-system impact information.

The nonprobability data collected in these question sets will be reviewed by PHMSA, and used to provide non-generalizable cost and benefit information regarding the benefits and limitations associated with using e-systems for HM shipping paper communications in its October 2014 report to Congress.

3. Describe methods to maximize response rate and to deal with issues of non-response.

Although the information collection effort is a qualitative research study, PHMSA has requested in its prior communications with the HM community that stakeholders interested in participating in the pilot tests post a comment to the 60-Day Notice or contact PHMSA by sending an email to the HM-ACCESS web account with their desire to participate. PHMSA has also periodically posted HM-ACCESS status updates on its public website and emails to its approximately 3,500 HM subscriber list, informing the HM community of the program’s progress. These methods have been employed to ensure that interested stakeholders are informed, involved, and more likely to participate in the information collection effort.

A requirement for participation is that all volunteering regulated entities (shippers and carriers) complete the set of on-line Shipper and Carrier Participant Selection Question Set. Responses are needed to verify that volunteers satisfy requirements for participation and to systematically evaluate their qualifications. Volunteering regulated entities that fail to complete the on-line Shipper and Carrier Participant Selection Question Set and the Informed Consent Form will be excluded from pilot test participation.

For each simulation conducted, law enforcement and emergency response participants are required to complete either the on-line Inspection Simulation or Emergency Response Simulation Question Set. PHMSA needs the information from these question sets to evaluate the results of the simulations conducted. Consequently, if a law enforcement or emergency response participant fails to complete an on-line question set, PHMSA will be unable to evaluate the results of that simulation, and it will not be included as nonprobability data for PHMSA’s evaluation and feasibility assessment.

The on-line Impact Analysis Question Set was designed to collect information from a limited number (250) of HM stakeholders (i.e., pilot test volunteers and other HM stakeholders who communicated with PHMSA during the past two years regarding this program) to aid in the collection of non-statistical HM stakeholder information for the initial assessment of potential impacts, including cost-benefit information, associated with using e-systems. Completion of the online impact analysis questions is completely voluntary. This limited distribution group will thus vet these questions first and identify any needed question modifications, in anticipation of PHMSA potentially sending a revised question set to the HM community in a later information collection package to further obtain e-system impact information.

PHMSA recognizes the limitations associated with this qualitative, non-random research study. PHMSA also understands that the data obtained during the pilot tests, even if all estimations regarding participation are met, will be non-probable and non-generalizable. Even with these limitations, PHMSA believes the pilot tests have warrant, as they will be the first test PHMSA has conducted as to whether e-systems can potentially provide HM shipping paper information in at least as effective and safe a manner as the current paper-based requirement.

4. Describe tests of procedures or methods.

PHMSA vetted early versions of the online question sets with some of the PHMSA field staff who assist with inspections, to gain their insight into the types of questions being asked of pilot test participants and whether the questions were focused on the types of observations that would provide PHMSA with nonprobability observations regarding e-systems used for HM shipping paper information communications.

PHMSA also held meetings with Federal transportation officials representing air (Federal Aviation Administration), maritime (U.S. Coast Guard), rail (Federal Railroad Administration), and roadway (Federal Motor Carrier Safety Administration) in April 2014, to gain their input regarding the observation collection process; potential U.S. regions suited for conducting “snapshot in time” pilot tests; and the design, flow, and logic programmed into the question sets.

5. Provide name and telephone number of individuals who were consulted on statistical aspects of the information collection and who will actually collect and/or analyze the information.

This information collection is a qualitative research study that does not employ statistical methods. No individuals were consulted on statistical aspects of this information collection. This qualitative research study will rely on nonprobability data to develop non-generalizable information from which PHMSA will make a recommendation as to whether a regulatory change allowing agencies/companies/organizations the option to use e-systems for storing and transferring HM shipping paper data is warranted, based on the nonprobability data from the “snapshot in time” non-random pilot tests.

APPENDICES

Note: These forms, scripts, and question sets can be found in the Information Collection Instrument Section of ROCIS.

Appendix A: Informed Consent Forms

Appendix B: Text for Shipper and Carrier Selection Email Notifications

Appendix C: Shipper and Carrier Participant Selection Question Set

Appendix D: Inspection Simulation Question Set

Appendix E: Emergency Response Simulation Question Set

Appendix F: Impact Analysis Question Set

Appendix A: Informed Consent Forms

Appendix B: Text for Shipper and Carrier Selection Email Notifications

Appendix C: Shipper and Carrier Participant Selection Question Set

As part of PHMSA’s participant evaluation and selection process and as indicated within the 60-Day and 30-Day Notices (see Part A, section 8), each volunteering regulated entity will need to complete a shipper and carrier participant selection question set to verify its qualifications and capabilities. The information provided will enable PHMSA to systematically screen each volunteer and select those that satisfy a minimum set of requirements for consideration and are judged to be best capable to aid PHMSA in achieving the objectives of MAP-21. The questions will be completed online and were designed with answers to most questions to be yes/no, multiple choice, or check box, to minimize burden to responders and to aid in data analysis. Logic has been programmed into the question set; if a question is answered in a manner that does not require additional explanation/information, it automatically brings the respondent to the next applicable question. This programming ensures respondents only answer those questions applicable to their individual company/organization, thereby further minimizing burden to the respondents.

There are 33 primary and 1 clarifying subordinate questions for a total of 34 questions. Not all 34 questions will need to be completed by every respondent, as various primary and subordinate questions are programmed to the response of a proceeding question. However, the estimated total burden of 27.5 hours for the shipper and carrier participant question data collection assumed each respondent answering all potential 34 questions. All of the questions have been organized into pages and different categories of information. Respondents must answer each page in sequential order before moving to the next page. This organization allows for a logical progression by respondents through those questions which, if answered in a manner that does not satisfy one of PHMSA’s pre-stated shipper and carrier requirements for participation, immediately brings the respondent to the end of the question set (i.e., the Termination Page), without requiring him/her to answer the remaining questions. This action reduces the time shippers and carriers who do not meet the minimum requirements spend answering the on-line questions.

Appendix D: Inspection Simulation Question Set

Law enforcement pilot test participants (inspectors) will conduct simulated inspections as identified with Part A of this Supporting Statement. For each inspection simulation conducted, the law enforcement participant will need to complete one inspection simulation question set. The inspection simulation question set has been designed to evaluate the feasibility and effectiveness of the e-system involved in each pilot test. The objective of the question set is to collect information on the technology involved, ability of the system and performance of the e-system, including duration of transfer and data quality of the electronic shipping paper information received as a result of the electronic transfer.

The questions will be completed online and were designed with answers to most questions to be yes/no, multiple choice, or check box, to minimize burden to responders and to aid in data analysis. Logic has been programmed into the question set; if a question is answered in a manner that does not require additional explanation/information, it automatically brings the respondent to the next applicable question. This programming ensures respondents only answer those questions applicable to their individual company/organization or simulation result, thereby further minimizing burden to the respondents.

There are 41 primary and 42 clarifying subordinate questions for a total of 83 questions. Not all 83 questions will need to be completed by every respondent, as various primary and subordinate questions are programmed to the response of a proceeding question. However, the estimated total burden of 260 hours for the inspection simulation question data collection assumed each respondent answering all potential 83 questions. All of the questions have been organized into pages and different categories of information. Respondents must answer each page in sequential order before moving to the next page. This organization allows for a logical progression of information and observation as it relates to conducting each inspection simulation.

Appendix E: Emergency Response Simulation Question Set

Emergency response pilot test participants will conduct emergency response simulations as identified with Part A of this Supporting Statement. For each emergency response simulation conducted, the emergency response participant will need to complete one emergency response simulation question set. The emergency response simulation question set has been designed to evaluate the feasibility and effectiveness of the e-system involved in each pilot test. The objective of the question set is to collect information on the technology involved and the ability of the system and performance of the e-system, including duration of transfer and data quality of the electronic shipping paper information received as a result of the electronic transfer.

The questions will be completed online and were designed with answers to most questions to be yes/no, multiple choice, or check box, to minimize burden to responders and to aid in data analysis. Logic has been programmed into the question set; if a question is answered in a manner that does not require additional explanation/information, it automatically brings the respondent to the next applicable question. This programming ensures respondents only answer those questions applicable to their individual company/organization or simulation result, thereby further minimizing burden to the respondents.

There are 41 primary and 143 clarifying subordinate questions for a total of 184 questions. Not all 184 questions will need to be completed by every respondent, as various primary and subordinate questions are programmed to the response of a proceeding question. However, the estimated total burden of 24 hours for the emergency response simulation question data collection assumed each respondent answering all potential 184 questions. All of the questions have been organized into pages and different categories of information. Respondents must answer each page in sequential order before moving to the next page. This organization allows for a logical progression of information and observation as it relates to conducting each emergency response simulation.

Appendix F: Impact Analysis Question Set

PHMSA has developed an impact analysis question set to aid in assessing potential impacts associated with using e-systems. The intention of the impact analysis question set is to collect information from a limited number (250) of HM stakeholders (i.e., pilot test volunteers and other HM stakeholders who communicated with PHMSA during the past two years regarding this program) to aid in the collection of nonprobability HM stakeholder information for the initial assessment of potential impacts, including cost-benefit information, associated with using e-systems. The question set is intended to be completed by HM stakeholders (shippers, carriers, law enforcement personnel, emergency responders, and other HM professionals), including both pilot test participants and non-pilot participants. Although not required, pilot test participants will be encouraged to complete the impact analysis question set, in addition to participating in the actual pilot tests.

The questions will be completed online and were designed with answers to most questions to be yes/no, multiple choice, or check box, to minimize burden to responders and to aid in data analysis. Logic has been programmed into the question set; if a question is answered in a manner that does not require additional explanation/information, it automatically brings the respondent to the next applicable question. This programming ensures respondents only answer those questions applicable to their individual agency/company/organization, thereby further minimizing burden to the respondents.

There are 49 primary and 80 clarifying subordinate questions for a total of 129 questions. Not all 129 questions will need to be completed by every respondent, as various primary and subordinate questions are programmed to the response of a proceeding question. However, the estimated total burden of 250 hours for the impact analysis question data collection assumed each respondent answering all potential 129 questions. All of the questions have been organized into pages and different categories of information. Respondents must answer each page in sequential order before moving to the next page. This organization allows for a logical progression of information and observation.

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