SSA_1218-0121 Powered Platforms 11.11.2020 Final for ROCIS

Powered Platforms for Building Maintenance Standard

1218-0121

November 30, 2020

SUPPORTING STATEMENT FOR THE

INFORMATION COLLECTION REQUIREMENTS OF THE

POWERED PLATFORMS FOR BUILDING

MAINTENANCE STANDARD (29 CFR 1910.66)¹

OFFICE OF MANAGEMENT AND BUDGET (OMB)

CONTROL NO. 1218-0121 (November 2020)

This ICR seeks to extend a currently approved data collection.

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The main purpose of the Occupational Safety and Health Act (OSH Act) is to “assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources” (29 U.S.C. 651). To achieve this objective, the OSH Act specifically authorizes “the development and promulgation of occupational safety and health standards” (29 U.S.C. 651). In addition, the OSH Act specifies that “[e]ach employer shall make, keep and preserve, and make available to the Secretary . . . such records . . . as the Secretary . . . may prescribe by regulation as necessary or appropriate for the enforcement of this Act . . .” (29 U.S.C. 657).

Under the authority granted by the OSH Act, the Occupational Safety and Health Administration (“OSHA” or “the Agency”) published the Powered Platform for Building Maintenance Standard (the “Standard;” 29 CFR 1910.66). The requirements of the Powered Platforms for Building Maintenance Standard include written emergency action plans and work plans for training; affixing load rating plates to each suspended unit, labeling emergency electric operating devices with instructions for their use, and attaching a tag to one of the fastenings holding a suspension wire rope; the inspection and testing of, and written certification for, building-support structures, components of powered platforms, powered platform facilities, and suspension wire ropes; and the preparation and maintenance of written training certification records. Items 2 and 12 below describe the specific information collection requirements of these paragraphs.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.

Paragraph (e)(9) of the Standard requires that employers develop and implement a written emergency action plan for each type of powered platform operation. The plan must explain the emergency procedures that workers are to follow if they encounter a disruption of the power supply, equipment failure, and other emergency. Prior to operating a powered platform, employers must notify workers how they can inform themselves about alarm systems and emergency escape routes, and emergency procedures that pertain to the building on which they will be working. Employers are to review with each worker those parts of the emergency-action plan that the worker must know to ensure their protection during an emergency; these reviews must occur when the worker receives an initial assignment involving a powered platform operation and after the employer revises the emergency action plan.

According to paragraph (f)(5)(i)(C), employers must affix a load rating plate to a conspicuous location on each suspended unit that states the unit’s weight and its rated load capacity. Paragraph (f)(5)(ii)(N) requires employers to mount each emergency electric operating device in a secured compartment and label the device with instructions for its use. After installing a suspension wire rope, paragraphs (f)(7)(vi) and (f)(7)(vii) mandate that employers attach a corrosion-resistant tag with specified information to one of the wire rope fastenings if the rope is to remain at one location. In addition, paragraph (f)(7)(viii) requires employers who resocket a wire rope to either stamp specified information on the original tag or put that information on a supplemental tag and attach it to the fastening.

Paragraphs (g)(2)(i) and (g)(2)(ii) require that building owners, at least annually, have a competent person: inspect the supporting structures of their buildings; inspect and, if necessary, test the components of the powered platforms, including control systems; inspect/test components subject to wear (e.g., wire ropes, bearings, gears, and governors); and certify these inspections and tests. Under paragraph (g)(2)(iii), building owners must maintain and, on request, disclose to OSHA a written certification record of these inspections/tests; this record must include the date of the inspection/test, the signature of the competent person who performed it, and the number/identifier of the building support structure and equipment inspected/tested.

Paragraph (g)(3)(i) mandates that building owners use a competent person to inspect and, if necessary, test each powered platform facility according to the manufacturer’s recommendations every 30 days, or prior to use if the work cycle is less than 30 days. Under paragraph (g)(3)(ii), building owners must maintain and, on request, disclose to the Agency a written certification record of these inspections/tests; this record is to include the date of the inspection/test, the signature of the competent person who performed it, and the number/identifier of the powered platform facility inspected/tested.

According to paragraph (g)(5)(iii), building owners must use a competent person to thoroughly inspect suspension wire ropes for a number of specified conditions once a month, or before placing the wire ropes into service if the ropes are inactive for 30 days or longer. Paragraph (g)(5)(v) requires building owners to maintain and, on request, disclose to OSHA a written certification record of these monthly inspections; this record must consist of the date of the inspection, the signature of the competent person who performed it, and the number/identifier of the wire rope inspected.

Paragraph (i)(1)(v) specifies that employers must prepare a written certification that includes the identity of the worker trained, the signature of the employer or the trainer, and the date the worker completed the training. In addition, the employer must maintain a worker’s training certificate for the duration of their employment and, on request, make it available to OSHA. Training certification permits employers to review the training provided to their workers, thereby ensuring that the workers received the necessary training.

Emergency action plans allow employers and workers to anticipate, and effectively respond to, emergencies that may arise during powered platform operations. Affixing load rating plates to suspended units, instructions to emergency electric operating devices, and tags to wire rope fasteners prevent workplace accidents by providing information to employers and workers regarding the conditions under which they can safely operate these system components. Requiring building owners to establish and maintain written certification of inspections and testing conducted on the supporting structures of buildings, powered platform systems, and suspension wire ropes provides employers and workers with assurance that they can operate safely from the buildings using equipment that is in safe operating condition.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burdens.

Employers may use improved information technology as appropriate to establish and maintain the required records. OSHA wrote the paperwork requirements of the Standard in performance-oriented language, i.e., in terms of what data to record, not how to record the data.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item A.2 above.

The information collection requirements in the Standard are specific to each employer and worker involved, and no other source or agency duplicates the requirements or can make the required information available to OSHA (i.e., the required information is available only from, or applies only to, the employers covered by the Standard).

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information collection requirements specified by the Standard do not have a significant impact on a substantial number of small entities.

6. Describe the consequence to federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Employers must attach tags and labels to specified equipment only once, and each worker must receive the required training only once; any reduction in this frequency would eliminate these requirements entirely. Consequently, workers would not obtain information about the hazards associated with powered platform operations (tags and labels) or develop the skills and knowledge necessary to effectively operate, use, and inspect powered platforms, recognize and prevent work-related safety hazards, respond effectively under emergency conditions, and maintain and use their fall protection arrest system (training). In addition, training certification allows employers to review the training provided to their workers, thereby, ensuring that the workers received the necessary training.

Building owners are to inspect building-support structures and inspect/test powered platforms (including control systems and specified components) at least once a year, inspect/test each powered platform facility every 30 days (or prior to use if the work cycle is less than 30 days), and inspect/test suspension wire ropes used in active service once a month. Reducing the inspection/testing frequency would delay identification of defects and deterioration in building-support structures and powered platform systems, causing workers to use equipment that is not in safe operating condition and increasing their risk of injury and death.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly· Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentially that is not supported by authority established in statue or regulation that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can prove that it has instituted procedures to protect the information's confidentially to the extent permitted by law.

No special circumstances exist that require employers to collect information in the manner or using the procedures specified by this item. The information collection requirements are consistent with the guidelines provided in 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years, -- even if the collection-of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

As required by the Paperwork Reduction Act of 1995 (44 U.S.C. 3506(c)(2)(A)), OSHA published a notice in the Federal Register on June 18, 2020 (85 FR 36883) soliciting comments on its proposal to extend the Office of Management and Budget’s approval of the information collection requirements specified by the Standard on Powered Platforms for Building Maintenance (29 CFR 1910.66). This notice was part of a preclearance consultation program that provided the general public and government agencies with an opportunity to comment. The Agency received no public comments in response to this notice.

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

The Agency will not provide payments or gifts to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The paperwork requirements specified by the Standard do not involve the collection of confidential information.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The paperwork requirements specified by the Standard do not involve the collection of sensitive information.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

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

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage-rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this should be included in Item 13.

Burden-Hour and Cost Determinations

The Agency made a number of attempts to contact manufacturers in an effort to update these numbers, however, it was unsuccessful and; therefore, for purposes of this supporting statement, OSHA will continue to use the previous estimates that there are approximately 12,930 powered platforms in use, and that there are approximately 8,150 workers employed by 900 employers/building owners. Due to changes in technology that have moved the industry away from using powered platforms, the Agency believes these numbers are an overestimate.

OSHA’s estimates of the burden hours and costs for each information collection requirement are calculated below. Costs and burden hours for this request are rounded to total dollar and hour amounts. The Agency determined average wage rates for average hourly earnings, including benefits, to represent the cost of worker time. For the relevant occupational categories, OSHA adjusted the mean hourly earnings according to the Bureau of Labor Statistics (BLS), U.S. Department of Labor, Occupational Employment Statistics (OES), May 2019 (www.bls.gov/oes/) to allow for fringe benefits. To account for fringe benefits, we used the fringe benefit rate reported in BLS’ Employer Costs for Worker Compensation (ECEC) news release for December 2019. BLS reported that for private industry, fringe benefits accounted for 29.9 percent of total compensation and wages accounted for the remaining 70.1 percent. To calculate the loaded hourly wage for each occupation, thus we divide the mean hourly wage by 70.1 percent. In addition, the Agency uses the following wage rates in making the cost determination for the Information Collection Requests: Occupational Codes 51-1011 (First-Line Supervisor), 51-4041 (Machinist), and 43-6014 (Secretary).

WAGE HOUR ESTIMATE
Occupational Title	Standard Occupation Code	Mean Hourly Wage Rate (A)	Fringe Benefits (B)	Loaded Hourly Wage Rate (C) = (A)/(1-(B)
First Line Supervisor	51-1011	$31.35	.299	$44.72
Machinist	51-4041	$22.17	.299	$31.63
Secretary	43-6014	$18.84	.299	$26.88

The following sections explain the basis of burden hour and cost estimates for the information collection requirements specified by the Standard.

(A) Written Emergency-Action Plans and Work Plans for Training (§§1910.66(e)(9) and (i)(1)(iv))

The Agency assumes that the 900 employers/building owners have completed the required emergency-action plans and written work procedures soon after OSHA published the final Standard. These existing employers/building owners need only to update these documents if operational conditions or equipment change (e.g., purchase new platforms, implement new rescue methods).² To meet this requirement, the Agency estimates that every five years, a supervisory machinist will spend 1 hour updating the existing documents.

The Agency is using an estimate of 10 percent of the 900 employers/building owners to account for new employers/building owners who need to complete emergency action plans and written work procedures. Based on the Regulatory Impact and Regulatory Flexibility Assessment of the Revisions to OSHA’s Powered Platform Standard (29 CFR 1910.66, Subpart F; the “RIA”), the Agency estimates that it will take two hours to develop the plans. Accordingly, the annual burden hours and cost of these paperwork requirements are:

Burden Hours: 900 employers/building owners/5 years x 1 hour = 180 hours

Cost: 180 hours x $44.72 = $8,050

Burden Hours: 900 employers/building owners x 10% x 2 hours = 180 hours

Cost: 180 hours x $44.72 = $8,050

(B) Plates, Labels, and Tags (§§1910.66(f)(5)(i)(C), (f)(5)(ii)(N), (f)(7)(vi), (f)(7)(vii), and (f)(7)(viii))

The Standard requires employers to affix a load-rating plate to each suspended unit, label each emergency electric-operating device with instructions for its use, and attach a tag to one of the fastenings holding a suspension wire rope. OSHA believes that equipment manufacturers and suppliers provide these plates, labels, and tags as a usual and customary practice. However, employers must replace worn or damaged plates, labels, and tags; in addition, after resocketing a wire rope, they must either stamp the specified information on the original tag or put the information on a supplemental tag and attach it to the fastening. The Agency estimates that 20 percent of the powered platforms (12,930 x .20 = 2,586) will require replacement plates, labels, or tags annually, and that a machinist will take 5 minutes (5/60 hour) to replace each of these items. OSHA also estimates that employers will resocket wire ropes on 10 percent of their powered platforms (12,930 x .10 = 1,293) each year, and will either stamp the specified information on the original tag or put the information on a supplemental tag and attach it to the fastening. The Agency estimates that a machinist will spend 20 minutes (20/60 hour) completing either of these tasks.³ Therefore, the annual burden hours and cost of these paperwork requirements are:

Burden Hours: (2,586 platforms x 5/60 hour = 216) + (1,293 platforms x 20/60 hour =

431) = 647 hours

Cost: 647 hours x $31.63 = $20,465

(C) Inspection and Testing of, and Written Certification for, Building-Support Structures, Components of Powered Platforms, Powered-Platform Facilities, and Suspension Wire Ropes (§§1910.66(g)(2)(i), (g)(2)(ii), (g)(2)(iii), (g)(3)(i), (g)(3)(ii), (g)(5)(iii), and (g)(5)(v))

These provisions require employers/building owners to: Inspect building-support structures at least every 12 months; inspect, and test as necessary, components of powered platforms at least annually; inspect, and test as necessary, powered platform facilities every 30 days (or prior to use if the work cycle is less than 30 days); and inspect suspension wire ropes at least once a month (or before placing the ropes into service if they are inactive for 30 days or longer).

Based on determination in the RIA, OSHA estimates that a machinist will take a total of: four hours to inspect/test both the building support structure and the components of a powered platform, including the certification record, once a year; and 30 minutes (30/60 hour) to inspect/test both a powered platform facility and its suspension wire ropes, and to prepare the certification record, once every 30 days. Therefore, the annual burden hours and cost of these paperwork requirements are:

Burden Hours: 12,930 platforms x 4 hours to inspect annually = 51,720

12,930 platforms x 12 inspections annually x 30/60 hour = 77,580 hours

Cost: 51,720 hours + 77,580 hours = 129,300 hours x $31.63 = $4,089,759

(D) Written Certification of Training (§1910.66(i)(1)(v))

As stated previously, the Agency believes that there are approximately 8,150 workers covered by the Standard. This figure includes existing workers and turnover workers such as new or rehired workers. Based on information in the RIA, the Agency estimates that there is a 15 percent turnover rate annually among workers.

Under §1910.66(e)(9), employers are required to prepare an emergency action plan and have written work procedures for the operation, safe use and inspection of working platforms. The standard states that the operating procedures supplied by the manufacturers can serve as the basis for the written work procedures. These documents serve as the training materials. Burden hours and cost for the development are taken under §§1910.66(e)(9) and (i)(1)(iv) (See A above).

The Agency believes that employers have already developed the necessary training materials earlier and, as a result, do not need to revise this material during the period covered by this ICR. Therefore, the Agency is taking no burden hours or cost for employers to develop or revise the training materials required by the Standard.

Based on the RIA, training consists of 2 hours of safety training on the basic powered platform and an additional 2 hours of safety training on powered platforms using a button or an intermittent tie-in stabilization system. Upon further analysis, the requirement that employers provide training to workers is not considered to be a collection of information. OSHA is not taking burden for this activity under Item 12 of this Supporting Statement. However, the Agency will take burden for the time that it takes to generate and maintain the training records. OSHA estimates that it will take a secretary three minutes (3/60 hour) to generate and maintain the written training certification records for all existing workers (8,150) and for all new/rehired workers (8,150 x .15 = 1,223). Thus, the annual burden hours and cost of these paperwork requirements are:

Burden Hours: (8,150 existing workers + 1,223 new/rehired workers)⁴ = 9,373 workers x 3/60 hour to generate and maintain training record = 469 hours

Cost: 469 hours x $26.88 = $12,607

Table 1 – Summary of Estimated Annualized Respondent Hour and Cost Burden

Information Collection Requirement (Across Top of Rows)	Type of Respondent	Number of Respondents		Number of Responses per Respondent	Total Number of Responses	Average Burden per Response (In Hrs.)	Total Burden Hours	Avg. Hourly Wage Rate		Total Burden Costs
(A) Written Emergency-Action plans and Work plans for Training (§§1910.66(e)(9) and (i)(1)(iv))
	Supervisory Machinist- Existing Employers/ Building Owners	180		1	180	1	180	$44.72		$8,050
	Supervisory Machinist – New Employers/ Building Owners	90		1	90	2	180	$44.72		$8,050
Duplicated SubTotal		270		--	270	--	360	--		$16,100
(B) Plates, Labels, and Tags (§§1910.66 (f)(5)(i)(C), (f)(5)(ii)(N), (f)(7)(vi), (f)(7)(vii), and (f)(7)(viii))
	Machinist- Part Replacement	2,586		1	2,586	5/60	216	$31.63		$6,832
	Machinist- Resocket	1,293		1	1,293	20/60	431	$31.63		$13,633
Unduplicated SubTotal		3,879		--	3,879	--	647	--		$20,465
(C) Inspection and Testing of, and Written Certification for, Building-Support Structures, Components of Powered Platforms, Powered-Platform Facilities, and Suspension Wire Ropes (§§1910.66(g)(2)(i), (g)(2)(ii), (g)(2)(iii), (g)(3)(i), g(3)(ii), (g)(5)(iii), and (g)(5)(v))
	Machinist	12,930		1	12,930	4	51,720		$31.63	$1,635,904
	Machinist	12,930		12	155,160	30/60	77,580		$31.63	$2,453,855
Duplicated SubTotal		12,930		--	168,090	--	129,300		--	$4,089,759
(D) Written Certification of Training (§§1910.66(i)(1)(v))
	Secretary - Existing Workers		8,150	1	8,150	3/60	408	$26.88		$10,967
	Secretary - New or Rehired Workers		1,223	1	1,223	3/60	61	$26.88		$1,640
Unduplicated SubTotal			9,373	--	9,373	--	469	--		$12,607
GRAND TOTALS			--		181,612		130,776			$4,138,931

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

There are no costs to the respondents other than the respondents’ time presented under A12.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Usually, OSHA requests access to records during an inspection. Information collected by the Agency during the investigation is not subject to the PRA under 5 CFR 1320.4(a)(2). Therefore, OSHA takes no burden or cost in Item 14 of this Supporting Statement for disclosing information during an inspection.

15. Explain the reasons for any program changes or adjustments.

OSHA is requesting an adjustment increase in the number of burden hours from 130,763 hours to 130,776, a total increase of 13 hours. The slight adjustment increase is primarily due to the method of calculating the burden. The agency believes that using fractions instead of decimals to represent time would make it easier for the public to follow the burden calculations.

Table 2 - Explanation of Hour and Cost Burden Adjustments

Information Collection Requirement	Current Burden Hours	Requested Burden Hours	Adjustment	Cost Under Item 12	Responses	Explanation of Adjustment
(A) Written Emergency-Action plans and Work plans for Training (§§1910.66(e)(9) and (i)(1)(iv))	360	360	0	$16,100	270	No change.
(B) Plates, Labels, and tags (§§ 1910.66 (f)(5)(i)(C), (f)(5)(ii)(N), (f)(7)(vi), (f)(7)(vii), and (f)(7)(viii))	634	647	13	$20,465	3,879	The slight adjustment increase is primarily due to the method of calculating the burden. The agency believes that using fractions instead of decimals to represent time would make it easier for the public to follow the burden calculations.
(C) Inspection and Testing of, and Written Certification for, Building-Support Structures, Components of Powered Platforms, Powered-Platform Facilities, and Suspension Wire Ropes (§§1910.66(g)(2)(i), (g)(2)(ii), (g)(2)(iii), (g)(3)(i), g(3)(ii), (g)(5)(iii), and (g)(5)(v))	129,300	129,300	0	$4,089,759	168,090	No change.
(D) Written Certification of Training (§1910.66(i)(1)(v))	469	469	0	$12,607	9,373	No change.
TOTALS	130,763	130,776	13	$4,138,931	181,612

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection information, completion of report, publication dates, and other actions.

OSHA will not publish the information collected under the Standard.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be appropriate.

OSHA lists current valid control numbers in §§1910.8, 1915.8, 1917.4, 1918.4, and 1926.5 and publishes the expiration date in the Federal register notice announcing OMB approval of the information collection requirement. (See 5 CFR 1320.3(f)(3)). OSHA believes that this is the most appropriate and accurate mechanism to inform interested parties of these expiration dates.

18. Explain each exception to the certification statement.

OSHA is not seeking such an exception.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This Supporting Statement does not contain any collection of information requirements that employ statistical methods.

1 The purpose of the purpose of this Supporting Statement is to analyze and describe the burden hours and costs associated with provisions of this standard that contain paperwork requirements; this Supporting Statement does not provide information or guidance on how to comply with, or how to enforce, the standard.

2

²OSHA believes that most new platforms purchased by employers/building owners are similar to their existing platforms, which expedites development of the required documents.

3The burden hour estimate for stamping tags or providing supplemental tags is higher than the burden-hour estimate for replacing plates, labels, and tags because employers/building owners must stamp the tags or fabricate the supplemental tags themselves, while equipment manufacturers and suppliers can provide replacement plates, labels, and tags.

4OSHA recognizes this burden estimate is an overestimate, since employers do not need to maintain training records of past workers. The 1,223 new hire or rehires represents turnover workers.

1