Emergency Justification Letter

UNITED STATES OF AMERICA

Federal Trade Commission
WASHINGTON, D.C. 20580

Office of the Executive Director

Sharon Block
Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Re: Emergency Clearance Request under the
Paperwork Reduction Act
Dear Ms. Block:
I am the Federal Trade Commission’s COVID-19 Pandemic Response Team Leader. We
are submitting an emergency clearance request for authority under the Paperwork Reduction Act
to collect information from medical providers on part two of the form on which federal
employees seek a medical exception to the requirement for a COVID-19 vaccination or a delay
because of a temporary condition or medical circumstance. The FTC needs information
requested on part two of the form from the medical provider to effectively evaluate the
employee’s reasonable accommodation request.
The FTC requests a 180-day emergency clearance to obtain the information required in
the form titled “Request for a Medical Exemption or Delay to the COVID-19 Vaccination
Requirement.” During the 180-day emergency clearance period, the FTC will work to establish
a regular clearance submission. As this request for approval concerns an urgent safety need, the
FTC is also seeking OMB’s approval to waive the need for the Federal Register Notices
otherwise required by 5 C.F.R. 1320.5(a)(l)(iv) and 1320.8(d)(l) prior to publication and
implementation of this disclosure.
Special circumstances exist that require an emergency clearance pursuant to 5 CFR
1320.13(a). Executive Order 14,043 directed the Safer Federal Workforce Task Force to issue
guidance within 7 days of the date of that order (Sept. 9, 2021) on implementation by federal
agencies covered by the order. The Task Force thereafter directed that Federal employees must
be fully vaccinated by November 22, 2021, other than in limited circumstances where the law
requires an exception.

Thus, the collection of information is needed prior to the expiration of time periods
ordinarily required by the PRA statute and implementing rules and is essential to the mission of
the FTC. 5 CFR 1320.13(a)(1)(i)-(ii). Additionally, public harm is reasonably likely to result if
normal clearance procedures are followed. 5 CFR 1320.13(a)(2)(i). This information is being
collected and maintained to promote the safety of Federal buildings and the Federal workforce
consistent with the above-referenced authorities, the COVID-19 Workplace Safety: Agency
Model Safety Principles established by the Safer Federal Workforce Task Force, and guidance
from Centers for Disease Control and Prevention and the Occupational Safety and Health
Administration.
Please feel free to contact Richard Gold at (202) 326-3355 or via email at rgold@ftc.gov
if you have any questions.
Respectfully,
signed by DAVID ROBBINS
DAVID ROBBINS Digitally
Date: 2021.11.08 18:28:15 -05'00'

David Robbins
Executive Director