Ssa 21feb2018

23

Information Collection Request

Formative Studies on NIOSH Communications and Publications:

NIOSH Customer Satisfaction Survey

Reinstatement with Change

0920-0544

Supporting Statement Section A

Submitted by:

Juliann C. Scholl, Ph.D.

Education and Information Division

National Institute for Occupational Safety and Health

1090 Tusculum Avenue

Mailstop C-10

Cincinnati, Ohio 45226

Phone (513) 533-8178

Fax (513) 533-8560

e-mail xhn3@cdc.gov

November 1, 2017

Table of Contents

A. Justification

1. Circumstances Making the Collection of Information Necessary

2. Purpose and Use of the Information Collection

3. Use of Improved Information Technology and Burden Reduction

4. Efforts to Identify Duplication and Use of Similar Information

5. Impact on Small Businesses or Other Small Entities

6. Consequences of Collecting the Information Less Frequently

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

8. Comments in Response to the Federal Register Notice and Efforts
to Consult Outside the Agency

9. Explanation of Any Payment or Gift to Respondents

10. Protection of the Privacy and Confidentiality of Information Provided by Respondents

11. Institutional Review Board (IRB) and Justification for Sensitive Questions

12. Estimates of Annualized Burden Hours and Costs

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

14. Annualized Cost to the Government

15. Explanation for Program Changes or Adjustments

16. Plans for Tabulation and Publication and Project Time Schedule

17. Reason(s) Display of OMB Expiration Date is Inappropriate

18. Exceptions to Certification for Paperwork Reduction Act Submissions

List of Attachments

Attachments 1- Applicable Sections of Laws and Regulations

Attachment 2- 60 Day FRN

Attachment 3- Data Collections Instruments

3a- Full Survey, Intermediary Version

3b- Full Survey, Employer Version

3c- Short Survey, Intermediary Version

3d- Short Survey, Employer Version

Attachment 4- Contract Materials Prepared for Respondents

4a- Recruiting Email Message

4b- First Follow-up Email Message

4c- Second and Final Follow-up Email Message

Attachment 5- Instructions to Respondents

5a- Frequently-asked questions (FAQs)

5b- Debriefing Message at End of Survey

Attachment 6- Non-research Determination Letter

Attachment 7- Additional Material

7a- 2003 Customer Satisfaction Survey Final Report

7b- 2010 Customer Satisfaction Survey Final Report

Formative studies on NIOSH Communications and Publications

Supporting Statement Part A

• Goal of the study—collect stakeholder feedback on NIOSH products and their dissemination

• Intended use of the resulting data—provide recommendations for improving development and dissemination of NIOSH publications and products

• Methods to be used to collect—convenience sample

• The subpopulation to be studied—occupational safety and health (OSH) professionals who either serve as intermediaries who distribute OSH information and educational materials to other organizations, or employers or organizational members whose job includes managing some aspect of workplace safety and health.

• How data will be analyzed—descriptive statistics to determine frequencies across groups

Justification

1. Circumstances Making the Collection of Information Necessary

As mandated in the Occupational Safety and Health Act of 1970 (PL 91-596), the mission of the National Institute for Occupational Safety and Health (NIOSH) is to conduct research and investigations on work-related disease and injury and to disseminate information for preventing identified workplace hazards (Sections 20 (a) (1) and (d), Attachment 1). This is a reinstatement with change collection (0920-0544, expiration date, 4/30/2010) and NIOSH is requesting a 2-year approval period. This dual responsibility recognizes the need to translate research into workplace application if it is to impact worker safety and well-being. Indeed, NIOSH, through its communication efforts, seeks to promote greater awareness of occupational hazards and their control, influence public policy and regulatory action, shape national research priorities, change organizational practices and individual behavior, and ultimately, improve American working life. While the means for packaging and delivering NIOSH generated information varies, the primary communication vehicle is its series of numbered print publications. The total number of publications downloaded from the NIOSH website in 2015 was more than 767,000. Reflecting the need to address different issues and target audiences, these publications are catalogued by NIOSH as Policy Documents, Technical Documents, and Educational Documents.

Policy documents support new or revised standards and regulatory actions aimed at assuring safe and healthful workplaces. NIOSH Criteria Documents, Current Intelligence Bulletins, Special Hazard Reviews and Reports to Congress are examples of NIOSH publications expressly designed for this purpose. The main audiences for such documents are governmental policy makers and regulators at the Federal, State and Local levels. Groups having collateral interest in these documents are professionals offering occupational safety and health services to industry, business and trade associations, labor organizations, insurers, and those engaged in academic pursuits.

Technical documents are intended to clarify occupational safety and health issues through scientific means, furnish new data to support policy recommendations, or identify and promote efforts to address research needs. The subject matter for NIOSH technical documents is highly variable. Publications in this category can deal with prescribed sampling and analytical methods for characterizing workplace exposures to certain agents, hazard control technologies, attributes of personal protective equipment, findings from surveillance studies and investigations of workplace risks as related to fatality, injury, and illness. The main audiences for these types of documents are scientific and health professionals in academia, industry, organized labor and insurers. Other interested groups include Federal, State and local authorities responsible for assuring the safety and health of workers.

Educational documents are intended to promote an awareness of workplace health and safety issues, offer guidance to employers on hazard control strategies, educate worker groups who may be at risk, and encourage use of safer, more healthful work practices. These documents are designed for the general public and written in lay language. They are often used for training and communication purposes by occupational safety and health (OSH) professionals to inform workers about job-related health and safety issues. In some instances, an educational document may complement the issuance of a policy document or technical report, the intent being to inform those who may not have the technical background to comprehend a more complex treatment of a given subject. NIOSH educational documents are also quite varied in content and form. Some are published as how-to manuals, illustrating specific steps or control actions in dealing with certain workplace risks. Others may be printed as pamphlets or newsletters to call attention to a specific hazard or describe a proven hazard control technique. The main targets for these documents are those employers and worker groups for whom the subject of the publications has special significance in their work operations. Secondary audiences include OSH professionals, industry/trade associations, and insurers who may serve the employer/workforce groups in question. Policy-makers/regulators may also use these documents in assisting employers on compliance issues.

All of the above kinds of documents are made available to the public through the use of mailing lists of known interested parties, NIOSH eNews, home page announcements on the NIOSH Website, promotion at conferences, and other means. In a given year, automatic mailings and responses to new requests for NIOSH publications can exceed 750,000 copies. Yet, these numbers tell little of whether the reports are reaching all of the appropriate audiences, or more importantly, whether the information is perceived as credible and useful by the recipients, and whether the information is applied to improve working conditions. Therefore, a baseline Customer Satisfaction Survey (CSS) was conducted in 2003 and a follow-up CSS in 2010 to assess customer satisfaction and perceived impact of NIOSH publications. The previous ICR was discontinued after the data was collected. The proposed study is a reinstatement of the 2010 study with changes to the instrument and data collection methods to account for new products and technologies that did not exist 2010.

The survey data will offer a measure of how well NIOSH is meeting its GPRA strategic goal on information dissemination at least for one major audience, namely, OSH professionals. The target audience for this survey consists of occupational safety and health (OSH) professionals who either serve as (a) intermediaries who represent an organization to distribute OSH information and educational materials to other organizations, or (b) employers (e.g, managers) or organizational members whose job includes (or partially includes) managing some aspect of workplace safety and health (The term “employer” is used for simplicity.). The proposed study will take up to 2 years to complete. For the current CSI Survey, NIOSH is again partnering with the same four professional associations: American Industrial Hygiene Association (AIHA), American College of Occupational and Environmental Medicine (ACOEM), American Association of Occupational Health Nurses (AAOHN), and American Society of Safety Engineers. In addition, NIOSH will partner with 3 additional associations: American Insurance Association (AIA), Insurance Loss Control Association (ILCA), and National Fire Protection Association (NFPA). Adding the three associations is to expand the scope of the study and to capture a broader range of stakeholders that make up NIOSH’s key audience.

In its statement of strategic goals in conforming to the Government Performance and Results Act (GPRA), and in accordance with the Presidential Memorandum on Improving Customer Service (March 23, 1995, Attachment 1), NIOSH acknowledged its intention to “provide workers, employers, the public, and the occupational safety and health community with information, training, and the capacity to prevent occupational diseases and injuries (Goal #4).” In supporting this goal, the proposed survey will assess how well NIOSH information products are meeting the needs of a major constituency and ways that the publication and distribution process might be improved.

2. Purpose and Use of the Information Collection

As a follow-up to the Customer Satisfaction Survey (CSS) that NIOSH conducted in 2003 and again in 2010, the proposed data collection activity is for the NIOSH Customer Satisfaction and Impact (CSI) Survey. This CSI Survey will collect general information about the participants’ background related to OSH training (e.g., physician, nurse) and type of current employer (e.g., hospital, government agency, professional association), sources used to obtain OSH information, opinions about NIOSH and its communication products, preferences and recommendations for such information, and opinions about NIOSH partnerships. NIOSH will contract with a research firm to collect, manage, and analyze all data for this study. Respondents will be ask to respond to the data collection one time only.

The purpose of the present survey is to evaluate consumer perceptions and understanding of NIOSH communication products program as a whole in serving the broad OSH professional community. The following questions drive the proposed study:

(1) To what extent are NIOSH communication products viewed as credible, useful sources of information on occupational safety and health issues?

(2) To what extent has NIOSH been successful in distributing its communication products to its primary and traditional audience?

(3) To what extent, and in what ways, do users feel that NIOSH communication products influenced workplace safety and health program policies and practices, or resolved other related issues?

(4) What improvements could be made in the nature of NIOSH communication products and/or their manner of delivery that could enhance their use and benefits?

(5) What is the reach and perceived importance of NIOSH outreach initiatives?

Four versions of a survey addressing the above five questions have been developed (Attachments 3a-3d). The survey includes items measuring the familiarity of the target group with NIOSH publications in general, the merits of the subjects covered and manner of treatment, individual respondent experiences and perceived value in using NIOSH information to fulfill workplace safety/health functions or other job needs. Questions dealing with access to NIOSH documents and means for obtaining NIOSH documents are included based on current distribution options. Questions also address preferred delivery modes in light of advances in information technologies. Data will be collected on the respondents’ training and job responsibilities in an effort to determine how these factors may affect the above reactions. Respondents will also offer suggestions related to content and distribution methods.

Four versions of the CSI Survey were developed:

• Full-version Survey for Intermediaries (Attachment 3a)

• Full-version Survey for Employers (Attachment 3b)

• Short-version Survey for Intermediaries (Attachment 3c)

• Short-version Survey for Employers ((Attachment 3d)

Each participant will complete one of the four versions, depending on whether they are identified as an “intermediary” or “employer” and whether they complete the full or short version.

The full-version survey contains 33 questions including Likert-type and open-ended items; the format and number of items is similar to the 2003 and 2010 Surveys. The 2010 Survey served as the basis for developing the current version. On the current survey, 12 items were retained from the 2010 survey as originally written, 9 more from the 2010 were retained but revised, and there are 12 new items. Many of the 12 new items contained elements of the discarded 2010 items, but were rewritten and reorganized to reflect distinct topics (e.g., how NIOSH information is shared, the extent to which impact on workplace safety can be attributed to NIOSH products). The revision accounted for changes in NIOSH publications, digital products, and new dissemination channels emerging since 2010.

The short-version survey contains 6 of the questions that appear on the full version, and they solicit information about respondents’ OSH-related duties, how often they use NIOSH information, whether their organization offers information in languages other than English, perceptions of the quality and impact of NIOSH products, and perceptions of NIOSH as a credible source. The short-version survey is offered to participants who decline to complete the full survey when they are being recruited via email. Incorporating the short version is based on previous research conducted by NIOSH [Okun et al. 2016], which suggests that offering a short version is instrumental in increasing the overall response rate. The previously approved ICR accounted for 205 burden hours. The proposed reinstatement accounts for 312 burden hours in order to gather additional information on new products and technologies that did not exist in 2010.

The following table illustrates the four versions of the survey:	Intermediary	Employer
Full version	33 questions	33 questions
Short version	6 questions	6 questions

Each participant will complete only one of these four versions. Each full-version and short-version survey has a different form for (a) intermediaries who work on behalf of a professional association to distribute OSH information and educational materials to other organizations, and (b) employers or organizational members whose job includes [or partially includes] managing some aspect of workplace safety and health. In general, these versions are identical in the number and types of items included, but contain variations in wording to make the topics more relevant to intermediary or employer respondents. For example, the intermediary version includes such language as “your organization’s members” whereas the employer version contains phrases such as “your company’s employees.” Collecting feedback from intermediaries and employers at business organizations is based on the distinct role that intermediaries have in disseminating OSH information to businesses [Hasle 2010], particularly small businesses that typically lack the resources needed to obtain such information [Cunningham, Sinclair 2015; Page 2009]. Agencies like NIOSH rely on intermediary organizations (e.g., business and trade associations, chambers of commerce, labor organizations) to connect with businesses in order to disseminate OSH recommendations and educational materials to key stakeholders [Bruening et al. 2015]. Distinguishing the feedback received from respondents in intermediary organizations versus those who are employers or individual OSH employees (e.g. industrial hygienists, medical officers) in business organizations can yield richer data and reveal more about NIOSH’s ability in reaching its target audiences.

The survey will be implemented through a Task Order contract with a research services vendor. As previously mentioned, the survey will be limited to OSH professionals and employers, and for this purpose the following 7 major organizations identified with OSH matters will be enlisted to partner with NIOSH to recruit respondents:

• American Industrial Hygiene Association (AIHA; approximately 8,000 members)

• American College of Occupational and Environmental Medicine (ACOEM; 4,000 members)

• American Association of Occupational Health Nurses (AAOHN; 4,200)

• American Society of Safety Engineers (ASSE; 36,000, approximately 8,000 are Certified Safety Professionals or CSPs)

• American Insurance Association (AIA, 300 members)

• Insurance Loss Control Association (ILCA, 100 members)

• National Fire Protection Association (NFPA, 60,000 members)

The AIHA, ACOEM, AAOHN, and ASSE previously partnered with NIOSH for the 2003 and 2010 surveys. Each association in the proposed study will share their membership lists with NIOSH for drawing a sample of respondents. The total membership for the 7 organizations combined is approximately 84,600. Out of this population, a total sample of 2500 will be randomly selected, with 500 randomly sampled within each of the 5 following occupational groups: AIHA, ACOEM, AAOHN, ASSE, and Other (includes members of AIA, ILCA, and NFPA) (see Table 2.2):

Table 2-2: Stratified Sampling of the 7 Partnering Organizations

AIHA	ACOEM	AAOHN	ASSE	Other (AIA, ILCA, NFPA)
500	500	500	500	500

Individuals sampled who appear on more than one membership list will be assigned to the group most aligned with their professional training based on the title listed in their membership information. NIOSH employees who are members of the partnering organizations will also be excluded from the membership listings prior to sample selection. Various attempts will be made to maximize the response rate. Typical response rates for online surveys solicited by emails range from 30-42% [Perez et al. 2013; Sauermann, Roach 2013] without the use of honoraria or other monetary incentives. The 2010 CSS had an average response rate of 41%, with rates by organization ranging from 34-48%. For the 2010 survey, respondents were given the choice between completing a paper-and-pencil questionnaire mailed to them and completing the same survey online. For the proposed study, respondents will only be offered an online survey, thus reducing labor and other costs associated with receiving a mailed survey, completing it, and sending it back. As another departure from the sampling done for the 2010 survey, the current sample will not be limited to those who hold specific occupations that reflect the organization to which they belong (e.g., registered nurses belonging to AAOHN). Rather, the wider diversity of professions contained within each organization will be included in the proposed survey to better capture intermediaries and business organization members (i.e., employers) who are key users of NIOSH publications and products. Given these measures, the response rate for the current study is expected to be 60% across all five occupational groups and for the long- and short-version surveys. The 60% estimate is based on the fact that the response rates for the 2010 Customer Satisfaction Survey ranged from 34-48%. The response rate for this study is slightly increased because all versions of the survey will be administered online, contrary to the 2010 survey. This increased estimate is based on literature suggesting that online surveys get better response rates than do paper-and-pencil surveys [Sauermann, Roach 2013].

Beginning with the initial recruiting email (see Attachment 4a), respondents will be informed of the survey project and will be invited to follow a hyperlink to a passcode-protected website containing the online survey. A toll-free phone number will also be included so that the participant may contact a staff person with the contractor in the event that they have any questions or concerns. About 4-6 weeks after the recruiting email, the first follow-up email (see Attachment 4b) will be sent to participants who have not yet responded to the recruiting email (by completing the survey or declining to participate), and will again include the same information and instructions about the study as did the recruiting email. Participants who do not respond after the first follow-up email will be sent a second and final follow-up email (Attachment 4c) after an additional 4-6 weeks and be given the same information and instructions as in the previous two emails. No other follow-up emails will be delivered thereafter.

The contractor will develop a study website to provide participants with easy access to the survey and responses to frequently asked questions. The website will be comprised of a header and series of web pages that are loaded by participants when they login to the website. Participants will be able to review project information, obtain NIOSH and contractor contact information, read instructions for completing the survey, read frequently asked questions, and launch the survey website (Attachment 5).

The data for the CSI Survey will be collected via machine-readable optical character recognition (OCR) forms (electronic), thereby eliminating the need for any manual data entry and ensuring that respondents are exposed to the survey instruments that are formatted precisely the same way. The contractor will design user-friendly, machine-readable OCR forms using TeleForm^®, an automated content capture system that reduces the operating costs associated with manual data entry.

TeleForm^® provides advanced OCR and throughput capabilities, with accuracy rates approaching 100%. Various types of fields may be added to a form including, for example, constrained print fields (high accuracy character recognition), single-choice fields (bubble), multi-choice fields (mark all that apply), and image zones for unconstrained fields (e.g. other/specify fields). These flexible formatting options facilitate the creation of user-friendly forms that are quick to complete. Response options to all items will be in a format designed to minimize response time and effort.

The contractor will create web-based PDFs with VB scripts that incorporate QA/QC features into the executable PDFs that participants complete online. Participants will fill out and submit the SAQ online.

In addition to the use of a multi-mode approach and user-friendly forms, the survey is designed to further limit respondent burden by enabling those lacking sufficient familiarity or experience with NIOSH publications to forego answering additional questions that solicit responses pertaining to NIOSH and its products. Also, the first question of the survey asks respondents to indicate the type of organization they work for. Their choice of response to this item will either classify them as an “intermediary” or an “employer,” which will then determine which set of survey items they will be shown through the rest of the survey. This skip pattern will limit respondent burden further by not exposing them to survey items that are not relevant to them, based on how they respond to the first question.

3. Use of Improved Information Technology and Burden Reduction

NIOSH will contract with a research firm to collect, manage, and analyze all data for this study. As detailed below, the contractor will use information technology tools to manage the data collection process and reduce the burden of participation by tracking respondent contacts; offering an electronic response mechanism that eliminates the cost and labor associated with producing and distributing paper-and-pencil questionnaires; providing a participant website; programming user-friendly prompts into the questionnaire webpage for easy navigation; offering a short-version survey to participants who decline to complete the full version (Attachments 3a-3d); and incorporating skip patterns into the questionnaire to account for questions that are not applicable to respondents.

A computerized tracking system will be developed specifically for this project for use in monitoring data collection activities. The tracking system will store the dates for: dissemination of recruiting and follow-up emails, completion of questionnaires, and refusals to complete the questionnaire. The tracking system will be used to generate weekly reports summarizing the status of the data collection activity throughout the data collection period. This system will reduce respondent burden by ensuring that respondents are contacted at appropriate times, and that respondents who complete the survey or decline to complete it are not sent follow-up emails.

4. Efforts to Identify Duplication and Use of Similar Information

The current survey will not duplicate any existing NIOSH work, and is a logical extension of previous customer satisfaction surveys (2003 and 2010). This conclusion was based on a thorough review of internal program activities, literature search, conference and meetings attended that dealt with NIOSH programs, as well as a search of the Internet.

Although not related to the current survey, a search of NIOSH programmatic activities indicated that NIOSH completed a survey in 2005 of manufacturers and users of personal protective devices, namely respirators. The survey was conducted under contract with the U. S. Office of Personnel Management (OPM) to determine how effectively the “NIOSH Personal Protection Technology Laboratory” (NPPTL) was functioning. The survey respondents included both the manufacturers of respirators and the users of respirators, namely fire departments, first responders and safety and health practitioners. [OMB Approved: No. 3206-0236.] OPM processed and analyzed the data and briefed the NPPTL Program on the results. Action plans were developed to address items revealed in the survey results, and to further identify opportunities for improvement in the NPPTL Program.

The review also indicated that NIOSH recently received OMB approval to survey Business and Labor Associations that represent each of the eight NIOSH National Occupational Research Agenda (NORA) industry sectors. [OMB Approved: No. 0920-06AV.] The main goals of this survey project, which started in 2008, were to determine (1) sources of OSH information currently used by the various sector trade associations and labor unions, (2) OSH information presently being disseminated by these trade associations and labor unions to their members, (3) channels of communication within the different sector associations and unions used to disseminate OSH information, and (4) needs for specific types of OSH information, especially those needs not presently being serviced. This was a phone survey conducted over three years. Findings revealed that most of the organizations surveyed deemed OSH information as important. Also, labor organizations had the highest percentage of groups disseminating information to workers, and websites were the most common channel used to distribute OSH information [Okun et al. 2016].

The current survey, as indicated, is a follow-up to the 2003 and 2010 CSSs to assess the level of satisfaction of OSH practitioners with NIOSH’s communication products, namely its publications and information services. Since the vast majority of professional OSH practitioners belong to one of the four primary professional stakeholder organizations, ACOEM, AAOHN, AIHA, and ASSE, NIOSH in 2003 partnered with these four professional organizations to conduct the CSS.

The 2003 survey was the first to assess the total array of NIOSH publications as circulated to and used by the OSH professional community. The 2010 survey was implemented to determine how well NIOSH has responded to the needs and issues emerging from the 2003 survey findings. Considering the highly influential role of the target associations in addressing workplace safety and health issues, the current views of members of these associations regarding the merits of NIOSH publications provide critical indicators of the Institute’s current performance.

The proposed CSI Survey is an essential part of NIOSH’s efforts to determine the outcomes of the programmatic changes that have been implemented since the baseline survey was completed. The results of the follow-up survey will also be incorporated into NIOSH’s reporting to OMB on its progress in meeting its goals and mission.

5. Impact on Small Businesses or Other Small Entities

The only small businesses which may be impacted by this data collection are any physicians who are members of the four OSH professional associations, and employers who are members of the intermediary networks accessed in the first phase of the survey. These physicians may be directing OSH programs in companies, serving as faculty in schools of public health and medicine, or conducting medical management services for employees. These physicians have influential roles and their views toward, and use of, NIOSH publications are critical. Every effort has been made to minimize the burden of the survey on these small entities. First, the survey will be completed only one time. Second, in designing the survey instrument, the number of questions has been held to the minimum necessary for addressing the objectives of the proposed study. Third, the survey has been formatted to facilitate quick response and requires an average of only 20 minutes to complete. Fourth, a 5-item questionnaire is offered to participants who do not want to complete the full survey; this survey will take approximately 5 minutes to complete. Questions on the data collection instrument have been held to the absolute minimum required for the intended use of the data.

6. Consequences of Collecting the Information Less Frequently

The consequences to NIOSH of conducting the survey of customer satisfaction less frequently or not at all would be a gradual erosion of NIOSH’s capacity to be responsive to the changing needs of the workforce, which ultimately would be reflected in the rate of decline or lack of decline in the number of injuries and illnesses, as reported by the Bureau of Labor Statistics.

This survey is one of the tools that NIOSH uses to ensure that its research products and services are meeting the needs of practitioners and are relevant to the workplace hazards they find in their occupations. Given the accelerated changes in economic sectors, available information technologies, businesses, and in the associated workplaces, it is critical that NIOSH maintain its responsiveness to those changes. Surveys of practitioners’ needs on a periodic basis, such as every five years, offer one of the few relatively quick methods to determine if the agency’s efforts at being responsive, as judged by those who are responsible for implementing NIOSH’s recommendations, are indeed effective.

There are no legal obstacles to reduce the burden.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

This request complies fully with the guidelines of 5 CFR 1320.5. No exceptions to the guidelines are required.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

A. Federal Register Notice. A 60-day Federal Register Notice was published in the Federal Register on September 19, 2016, Vol. 81, No. 181, pp. 64157-64159 (see Attachment 2). No responses were received.

B. Efforts to Consult Outside the Agency. The CSI Survey was designed to be similar to the 2010 survey, but expanded and revised to reflect changes in NIOSH initiatives and technological advances. Dr. Bolanle Olaniran, Professor of Communication Studies at Texas Tech University (Texas Tech University, Department of Communication Studies, Box 43082, Lubbock, TX 79409; email: b.olaniran@ttu.edu; Tel (806-834-3978) provided input on construction of the survey, design of the study, and statistical procedures for analyzing the results. Dr. Olaniran has extensive experience in researching the use of information technologies and has expertise in quantitative survey design. As with the 2010 survey, NIOSH consulted with staff at Battelle, the contractor for the current survey. Lisa John, Ph.D., a Battelle project director with more than 20 years of survey experience (Battelle St. Louis office, 10420 Old Olive Street Road, Ste 300, St. Louis, MO 63141; Tel (314) 993-5234) consulted on the final content and wording of the survey questions and response categories. Ms. Stephanie Gray, Management and Technical lead for Battelle’s IT/Data Management Survey work, offered input into the survey design to make it more reader-friendly and formatted the final survey. The final draft was reviewed by 8 pilot test participants representing the target professions. These individuals completed the draft survey and provided further recommendations regarding wording and content.

9. Explanation of Any Payment or Gift to Respondents

No direct financial payments will be provided to the respondents. To help motivate members to respond to the survey and increase the response rate, the initial recruiting email will contain hyperlinks to NIOSH products for download. One of the links is to the NIOSH Pocket Guide to Chemical Hazards (http://www.cdc.gov/niosh/npg/), where respondents can download both PDF and mobile app versions of the document. A similar incentive was provided to respondents of both the 2003 and 2010 surveys. Research indicates that providing incentives along with the questionnaire in the study solicitation raises response rates more effectively than promising an incentive upon receipt of a completed questionnaire (Dillman, 2000). Emailing the link to web downloads eliminates the costs associated with sending CD-ROMs through traditional mail.

10. Protection of the Privacy and Confidentiality of Information Provided by Respondents

After consultation, the CDC Privacy Act officer determined that the privacy act does not apply. The NIOSH CSI Survey collects no personal information and includes no sensitive questions or questions about health status or illnesses. Moreover, no personally identifiable information (PII) about respondents is obtained via the survey, and no database of information is maintained other than that required by the contractor to facilitate the survey process. Names and email addresses of recruited respondents will be retrieved from the participating organizations by the contractors for purposes of sampling and maintaining records of who completes the survey and when they complete it. However, this information will not be linked to the survey data, which will be anonymous. Names and email addresses will not be part of the survey data and will not be maintained as part of the information collection. Survey information for each respondent will be assigned a random code for data management purposes, and will not include any “personal identifier” (e.g., individual’s name, social security number, email) that can be linked to an individual.

The contractor will use security controls to protect against unauthorized access, modification, destruction or disclosure of data through access control and authentication. Security controls will protect survey information through technical controls, administrative controls and physical controls, as detailed below.

Participant data obtained from the partnering organizations and survey data collected during this study will be stored in the contractor’s secure databases on Local Area Networks (LANs) behind firewalls. The contractor will obtain names and email addresses of members from the eight organizations and will contact all members for participation in the study. The contact information (name and email address) will be used solely for the purpose of distributing the survey. As stated earlier in this section, names and email addresses will not be maintained as part of the survey information being collected. In other words, survey responses will not be linked to individual respondents; responses will be anonymous, and no personal identifying information (PII) is requested in the questionnaire. Analytical data sets may be stored on analysts’ PCs when they are working with the data. Access to the data will be controlled and limited to contractor and NIOSH personnel directly involved with the project.

All servers will be located in secure controlled access areas. Physical access to contractor offices during non-office hours will require possession of an electronic card. During office hours all visitors can only enter through a staffed reception area where they are logged in and must be escorted at all times while on the premises. All server rooms will require 24-hour electronic card access. Each electronic card will be programmed for a specific user and will provide that user with access to all areas to which they are authorized. Contractor offices also will have alarm systems monitored by professional security agencies that are activated when the offices are vacant. Authorized users will have individual access codes and all access, including invalid attempts, will be logged. In addition to these general security measures, sensitive material will be stored in locked file cabinets when not in use. Only office administrators and staff authorized to work with these materials have keys to these file cabinets. Contractor personnel will have been trained in these policies and periodically reminded of their importance. Staff members will be required to lock their computers when away from their desk using Windows Task Manager. Password-protected auto-locking will be configured to activate after 10 minutes of inactivity.

The contractor’s IT division will maintain an intranet site on Cybersecurity Policies and Procedures that is accessible by all employees. This site includes staff responsibilities for protecting data and security requirements for protection of the network, PCs, mobile devices and the data residing on them. In addition, the IT division will frequently send emails to all staff reminding them of specific security issues, such as use of the internet, remote access, email safety, etc.

The contractor’s databases will be backed up nightly to a folder on the server’s hard drive and integrity is verified upon completion. The folder containing these full database backups will then be backed up to tape as part of our network backup plan. The network backups provide nightly incremental backups and full backups on weekends for all data stored on LANs and WANs. Tapes are stored offsite at secure contracted facilities. Permissions to project databases will be limited to staff members assigned to work on the project. Non-technical project staff can only access the data indirectly through applications and are authenticated by username and password when logging into the application. All PC-based files, folders, and applications will be backed up nightly to a secure server in encrypted format using Connected DataProtector software. Laptops will be backed up using this software when staff reconnects to the company network. Files will remain encrypted while stored and only the owner of the files and the IT administrator will have the encryption key. Staff can elect to backup or restore files at any time in addition to the automatic backup. Sample member information is always stored and transferred separately from analysis data. Only survey data will be transferred to NIOSH; participant data will be destroyed upon completion of the project. The contractor will transfer the final survey data to NIOSH upon the completion of the contract. This information will not be retained by the contractor beyond the end of the contract. Survey data will be retained and destroyed by NIOSH in accordance with the applicable CDC Records Control Schedule.

Participation in the survey is voluntary and anonymous. Planned analyses involve the collation and treatment of grouped data. While certain types of demographic data (professional training, type and size of organization for which respondent works, sector of work, and professional responsibilities) will be obtained for the purposes of relating professional background and job responsibilities to the reported utility of NIOSH information, all data collection is to be anonymous. No names or personal identifiers will be obtained or appear on the questionnaires. The contractor will obtain names and email addresses of members from the partnering organizations who will be contacted for participation. The contact information will be used solely for the purpose of distributing the survey. Survey responses will not be linked to individual respondents; responses will be anonymous, and no identifying information is requested in the questionnaire.

11. Institutional Review Board (IRB) and Justification for Sensitive Questions

The proposed data collection was reviewed by the CDC Institutional Review Board and it was determined that the proposed data collection does not meet the definition of research in 45 CFR 46 and is exempt (Attachment 6). The recruiting email sent to potential respondents will state that the intended use of the information is to help NIOSH better serve the information needs of the members of each organization and others working to protect the health of American workers respondents. No private information will be collected and there are no plans for sharing individual responses. Responses will be summarized by organization, in group form. The cover letter informs participants that their responses are anonymous and will be grouped with those of other participants. The letter also informs respondents that grouped responses will be provided to the leader of their organization.

Participation in the survey is voluntary and anonymous. Participants are informed about the voluntary nature of their response in the cover letter that will be emailed by the contractor.

No questions of a sensitive nature will be asked in the survey.

12. Estimates of Annualized Burden Hours and Costs

A. Annualized Burden Hours.

The table below breaks down the expected number of respondents for the full- and short-version surveys for each of the four versions of the survey. 2500 respondents will be randomly selected to participate in the study. A 60% response rate brings the total number of respondents to 1500. We expect 375 respondents (annually) to complete the full version intermediary survey (Attachment 3a). The burden table below account for 20 minutes of time and 125 burden hours. The short version intermediary survey will be completed by 375 respondents (Attachment 3c). The average burden per response is 5 minutes and the total burden hours is 31. The full version survey for employers accounts for 375 respondents (Attachment 3b). Each respondent will complete the survey once and the average burden per response is 20 minutes and the total burden hours is 125. The short version for employers accounts for 375 respondents (Attachment 3d). The average burden in response is 20 minutes and the total burden hours is 30.

The total estimated burden hours is 312.

Table 12-1. Estimated Annualized Burden Hours—Customer Satisfaction and Impact (CSI) Survey

Type of Respondent	Form Name	No. of Respondents	No. Responses per Respondent	Average Burden per Response (in hours)	Total Burden Hours
AIHA, AAOHN, ACOEM, ASSE, and Other1 members	NIOSH Customer Satisfaction Survey—full version, intermediary	375	1	20/60	125
AIHA, AAOHN, ACOEM, ASSE, and Other members	NIOSH Customer Satisfaction Survey—short version, intermediary	375	1	5/60	31
AIHA, AAOHN, ACOEM, ASSE, and Other members	NIOSH Customer Satisfaction Survey—full version, employer	375	1	20/60	125
AIHA, AAOHN, ACOEM, ASSE, and Other members	NIOSH Customer Satisfaction Survey—short version, employer	375	1	5/60	31
TOTAL		1500			312

¹ Other professionals who work in OSH and potentially use and/or disseminate NIOSH material. They include members of American Insurance Association (AIA), American Association of State Compensation Insurance Funds (AASCIF), Insurance Loss Control Association (ILCA), and the National Fire Protection Association (NFPA).

B. Annualized Cost to Respondents. Five types of respondents (based on organizational group) will participate in this survey, as detailed in Table 12-2. According to the Bureau of Labor Statistics, and based on May 2015 figures obtained from the U.S. Department of Labor, Bureau of Labor Statistics Occupational Employment Statistics (http://www.bls.gov/oes/current/oes_nat.htm), the average hourly wage for occupational health and safety specialists (including industrial hygienists; AIHA) is $34.51. For registered nurses (AAOHN), the average hourly wage $34.14 per hour. The average hourly wage for general internists (ACOEM) is $94.48, and the average hourly wage for safety engineers (ASSE) is $42.21. The average hourly wage for the “Other” group was calculated using the mean hourly wage of the other four organizational groups ($51.34). Although other OSH professions are represented within these organizations, the hourly figures used reflect their primary occupations. Because each of the four survey versions will be completed by respondents representing all five occupational categories, the hourly wage rate associated with each category will vary; therefore, the average hourly wage rate was calculated at $51. 34/hour and applied towards each respondent type.

The total cost burden for this project is $16018.08. Annualized burden costs for each version of the survey (based on the total burden hours) are provided in Table 12-2.

Table 12-2 Estimated Annualized Burden Costs—Customer Satisfaction and Impact (CSI) Survey

Type of Respondent	Form Name	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
AIHA, AAOHN, ACOEM, ASSE, and Other1 members	NIOSH Customer Satisfaction Survey—full version, intermediary	125	$51.34	$6417.5
AIHA, AAOHN, ACOEM, ASSE, and Other members	NIOSH Customer Satisfaction Survey—short version, intermediary	31	$51.34	$1591.54
AIHA, AAOHN, ACOEM, ASSE, and Other members	NIOSH Customer Satisfaction Survey—full version, employer	125	$51.34	$6417.5
AIHA, AAOHN, ACOEM, ASSE, and Other members	NIOSH Customer Satisfaction Survey—short version, employer	31	$51.34	$1591.54
Total		312		$16018.08

¹ Other professionals who work in OSH and potentially use and/or disseminate NIOSH material. They include members of American Insurance Association (AIA), American Association of State Compensation Insurance Funds (AASCIF), Insurance Loss Control Association (ILCA), and the National Fire Protection Association (NFPA).

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

There are no capital, start up, operation, or maintenance costs to respondents associated with this proposed collection of information.

14. Annualized Cost to the Government

This project was designed as a 15-month effort including survey design, data collection, analysis, and reporting. The total cost to the government will be $184,651. This figure includes $168,951 in contract costs to the research firm under contract and $15,700 in other costs to the federal government. This is figure represents costs for the 15 months, not as annualized.

15. Explanation for Program Changes or Adjustments.

This study is a reinstatement with changes from the previously approved ICR that expired in 2010. This updated and expanded survey will account for changes in NIOSH publications, digital products, and new dissemination channels emerging since 2010. The proposed survey will also solicit more audience-based information that reflects the new media environment in which many NIOSH publications are offered. Such expansions will yield findings that show how well customer service practices at NIOSH have followed previous recommendations, as well as provide insights into how users seek and use NIOSH information in the current digital environment.

Specific changes were made to:

• Sample:

  • Whereas the 2010 survey sampled from 4 organizational groups (AIHA, AAOHN, AOCEM, and ASSE), the new survey utilizes those same four groups and adds an “Other members” group that includes sampling from AIA, ILCA, and NFPA. Adding the three partnering organizations will enable the study to be more inclusive of the industries that NIOSH serves.

  • Overall, the sample will stratified into 5 groups:

    • AIHA members

    • AAOHN members

    • AOCEM members

    • ASSE members

    • Other Members (AIA, ILCA, and NFPA)

• Instrument—Four versions instead of one version:

  • The new survey was expanded to a full-version (33 questions) and a short version (6 questions) to increase the response rate. All respondents will be invited to complete the full version; those who opt out will be invited to complete the short version.

  • Once respondents indicate their willingness to participate, they will be directed to the full-version survey. When they get to the first question, their response will classify them as “intermediary” or “employer,” after which they will be directed to the remaining questions of whichever survey they are completing (i.e., the long or the short version).

  • Overall, based on their level of willingness to participate as well as their response to the first question on the survey, each respondent will be “funneled” into completing one of the following versions:

    • Full-version: intermediary

    • Short-version: intermediary

    • Full-version: employer

    • Short-version: employer

• Instrument—Updated and new items

  • The current survey contains 33 Likert-type and open-ended items. The format of these questions is similar to those in the 2010 survey. From the 2010 survey:

    • 12 items were retained verbatim from the 2010 survey.

    • 9 items from the 2010 were retained but revised

    • 12 new items appear on the current survey. Many of the 12 new items contained elements of the discarded 2010 items, but were rewritten and reorganized to reflect distinct topics (e.g., how NIOSH information is shared, the extent to which impact on workplace safety can be attributed to NIOSH products).

    • The revision accounted for changes in NIOSH publications, digital products, and new dissemination channels emerging since 2010.

16. Plans for Tabulation and Publication and Project Time Schedule

A. Tabulation Plan: The analysis for this survey is simple and straightforward. The survey form is divided into sections containing items designed to measure use of NIOSH publications in addressing OSH issues, the credibility of NIOSH materials, ease of respondent access to NIOSH publications, importance of various types of publications and topic areas, familiarity with and perceived importance of NIOSH research partnerships, and respondent biographical factors (e.g., area of professional training, job responsibilities, sector). An examination of the distribution of responses to these items will allow for an evaluation of NIOSH publications in terms of perceived value and practical application as a function of professional affiliation. Specifically, survey results will be presented as percentages of response. For each question and subquestion, the data will consist of the sum of the response frequencies divided by the number of respondents answering that question to form percentages. The percentages will be presented in tables, figures, and text. To enhance the informational value of the results, the data will also be broken down by the organization with which respondents are affiliated. Illustrative table shells are presented below.

Table 16-1. Illustrative Table Shell: Question 1 – Full-version Survey: What type of organization do you work for?

	Total	AIHA	ASSE	ACOEM	AAOHN	[insurer]
	%	%	%	%	%	%
Company/business
Professional organization
University/college
Labor organization
Industry or trade association
Federal/State/Local government agency
Other
None of the above

Table 16-2. Illustrative Table Shell: Excerpt from Question 25 – Full-version Survey: Perceptions about NIOSH publications and products in general.

	Strongly Agree				No Opinion
	%	%	%	%	%
NIOSH publications contain current, up-to-date information.
NIOSH publications are unbiased.
NIOSH publications are written at the appropriate technical level.
NIOSH publications are written in language that is clear.
NIOSH publications provide useful and practical recommendations and guidance that are readily usable.
The length of NIOSH publications is appropriate for coverage of the topic.
NIOSH publications are delivered in a timely manner.

B. Publication Plan: The main beneficiary of this survey will be NIOSH, in particular, the Education and Information Division, which has prime responsibility for the publication and circulation of NIOSH information products. The findings will be used internally by those involved in preparing various types of NIOSH documents so as to aid in future writing and distribution efforts, such as NIOSH’s Research to Practice (r2P) program and the NIOSH Health Communication Specialists. Results will also be shared with other groups in NIOSH and other governmental agencies engaged in safety and health communication activities.

In addition, the survey results will be shared with the partner organizations, namely, ACOEM. AAOHN, AIHA, ASSE, AIA, ILCA, and NFPA. The outcomes of the survey hold important benefits to their individual members. Ascertaining how NIOSH is meeting their current information needs and if and how they could be improved can lead to more useful products. The final report of the project is planned for presentation at program meetings of these organizations as well as for submission for publication in scientific journals identified with health communication issues.

C. Project Time Schedule: While the OMB package is undergoing review, we will program the survey instrument, tracking system, and study website; obtain and de-duplicate the membership lists from the partnering organization; and set up the merge programs for the recruitment materials. The time schedule for the remainder of the project is shown below.

Table 16-3. Project Time Schedule

Activity	Time Schedule
Fielding of Questionnaire	6 months after OMB approval
Analyses of Survey Data	10-12 months after OMB approval
Publication of Findings	24 months after OMB approval

A 1-year clearance is requested.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

Not applicable. Display of OMB Expiration Date is appropriate for this study.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

References

Bruening RA, Strazza K, Nocera M, Peek-Asa C, Casteel C [2015]. How to engage small retail businesses in workplace violence prevention: Perspectives from small businesses and influential organizations. Am. J. Indus. Med. 58, 668-678.

Coganoglu C, Warde B, Moreo PJ. [2001]. A comparison of mail, fax, and web survey methods. Int. J. Market. Res. 43, 441-452.

Cunningham TR, Sinclair R [2015]. Application of a model for delivering occupational safety and health to smaller businesses: Case studies from the US. Saf. Sci. 71, 213-225.

Dillman D. [2000]. Mail and Internet Surveys. New York: John Wiley & Sons, Inc.

Hasle B, Bager B, Granerud L. [2010]. Small enterprises – accountants as occupational health and safety intermediaries. Saf. Sci. 48, 404-409.

NIOSH [2017]. Workplace safety and health information dissemination, sources, and needs among trade associations and labor organizations. By Scholl JC, Okun AH, Schulte PA, Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH) Publication No. 2017- 166.

Okun AH, Watkins J, Schulte P [2016]. Workplace safety and health information dissemination, sources, and needs among trade associations and labor unions. Manuscript submitted to Am. J. Indus. Med.

Page K. [2009]. Blood on the coal: the effect of organizational size and differentiation on coal mine accidents. J. Saf. Res., 85-95.

Perez DF, Nie JX, Ardern CI, Radhu N, Ritvo P [2013]. Impact of participant incentives and direct and snowball sampling on survey response rate in an ethnically diverse community: Results from a pilot study of physical activity and the build environment. J Immigrant Min Health 15, 207-214.

Sauermann H, Roach, M [2013]. Increasing web survey response rates in innovation research: An experimental study of static and dynamic contact design features. Res. Pol. 42(1), 273-286.