Supporting Statement_GarageDoorOpeners_2022

Information Collection Request (ICR)
Supporting Statement for the Standard for Automatic Residential Garage Door
Operators
OMB Control Number 3041-0125

A.

Justification

1.
Information to be collected and circumstances that make the
collection of information necessary
The Consumer Product Safety Commission is responsible for the
enforcement of the mandatory federal regulation “Safety Standard for Automatic
Residential Garage Door Operators” (16 CFR, Part 1211). This standard
requires all automatic residential garage door operators manufactured and sold
in the U.S. on or after January 1, 1993, to conform to the entrapment protection
requirements developed by Underwriters Laboratories, Inc. (UL 325), including
subsequent revisions.
The recordkeeping requirements of the standard (16 CFR, Part 1211.31
attached) became effective on January 21, 1993. According to these
requirements, written certification records must be maintained for a period of at
least three years from the date of certification of each residential garage door
operator subject to the standard. These certificates are based on a test of each
operator or on a “reasonable testing program.” These records must be available
upon request to any designated officer or employee of the Commission upon
request in accordance with section 16(b) of the CPSA, 15 U.S.C. 2065(b).
Automatic residential garage door operators are continually being
introduced into the market, either by established manufacturers and importers or
new manufacturers and importers. Therefore, the Commission seeks approval to
continue the recordkeeping requirements without change.
2.

Use and sharing of collected information

CPSC will use the information obtained from the requested records to
assess the current level of compliance with the entrapment provisions of the
standard for automatic garage door operators. Also, we will use information we
obtain at a given firm in any appropriate legal action(s) initiated, if the firm or its
product(s) fail to comply with the entrapment provisions of the standard. The
recordkeeping requirements will enable the Commission to identify industry-wide

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problems and address them prior to the report of related incidents associated
with noncomplying products.
3.

Use of information technology (IT) in information collection

Manufacturers and importers subject to the regulation may use any
improvements in information technology that they deem suitable for compiling
and maintaining the records required by the regulation.
4.

Efforts to identify duplication

Information collected by the Commission during this enforcement activity
is not collected by any other agency, organization, or individual. There is no
similar information available.
5.

Impact on small businesses

Enforcement activities associated with the standard for automatic garage
door operators may include a number of small firms. CPSC staff has identified
17 manufacturers and importers, including private labelers, of automatic
residential garage door operators. Information from company websites and from
Data Axle, Inc. (ReferenceUSA.com), indicate that, of the 17 identified firms
manufacturing or importing the products, 8 are either large companies or
subsidiaries of large domestic or foreign companies (subsidiaries of large firms
are considered to be large, regardless of the number of employees at the
subsidiary). The remaining nine appear to be small firms under the SBA size
standards for their industry sectors. 1 All known firms, including the small firms,
voluntarily conformed to the various requirements of UL 325 since before the
time that UL 325 became the referenced standard in the federal rule. In the
August 2015 proposed update of the mandatory rule, the Commission noted that
all known firms met the UL certification requirements; UL certification is
considered sufficient evidence of compliance with the mandatory rule. Thus, the
requirements do not impose significant impacts on small businesses.
6.
Consequences to Federal program or policy activities if collection is
not conducted or is conducted less frequently
The Commission relies on the recordkeeping provisions of the UL
standard to monitor compliance with the rule. Without the recordkeeping
requirements, the level of compliance would be unknown. The lack of written test
records would require an increase in Federal government inspections and
sample collections for testing to determine the industry’s compliance with the
standard.
Domestic manufacturers of “other miscellaneous electrical equipment” (NAICS code
335999) with fewer than 500 employees; and merchant wholesalers (including importers) of “durable
goods” (NAICS Subsector 423) with fewer than 100 employees.

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7.
Special circumstances requiring respondents to report information
more often than quarterly or to prepare responses in fewer than 30 days
There may be special circumstances in which respondents will be
requested to prepare a written response involving the collection of information
within fewer than 30 days after receipt of the request. These circumstances
apply when the CPSC Compliance staff is trying to determine preliminarily
whether a defect is present in an automatic residential garage door operator, and
whether that defect rises to the level of a substantial product hazard under
Section 15 of the Consumer Product Safety Act (CPSA), 15 U.S.C. 2064. Firms
are typically given 10 working days to respond to our request for information.
8.

Agency’s Federal Register Notice and related information

A Federal Register Notice announcing the renewal of this clearance was
published Thursday, May 5, 2022, 87 FR 26738. No comments were received.

CPSC staff participates in the Underwriters Laboratories, Inc. (UL)
Standards Technical Panel for ANSI/UL 325, Safety for Door, Drapery, Gate,
Louver, and Window Operators and Systems. CPSC staff participation allows
us to provide input into changes to the voluntary standard and the associated
CPSC mandatory safety rule (16 CFR part 1211), and to provide the
Commission with the earliest possible notification of proposed changes to the
rule. A Federal Register Notice announcing the Commission’s latest proposed
update of this rule was published in September 2015. Additional information
on the voluntary and mandatory standards for Garage Door Operators is
available publicly on the CPSC website (Garage Door Operators/Gate
Operators | CPSC.gov).
9.

Decision to provide payment or gift
Not applicable.

10.

Assurance of confidentiality

All records cited as being confidential remain confidential according to the
Commission’s procedures under the Freedom of Information Act. These
procedures are provided in 15 U.S.C. 1015.
11.

Questions of a sensitive nature
Not applicable. There are no questions of a sensitive nature.

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12.

Estimate of hour burden to respondents

CPSC staff has identified 17 respondents. These firms conduct
performance tests and maintain records based on the test results in order to
maintain UL certification and verify compliance with the rule. Staff estimates that
each respondent will spend 40 hours annually (35 hours for testing and 5 hours
for recordkeeping) on the collection of information related to the rule. Therefore,
the total estimated burden is 680 hours (17 firms x 40 hours).
The total annual cost of the testing burden is estimated to be about
$42,733, based on an hourly rate of $71.82 as total compensation for
management, professional, and related occupations in goods-producing private
industries (17 firms x 35 hours x $71.82); the annual cost of recordkeeping is
estimated to be about $2,948 based on an hourly rate of $34.68 for sales and
office workers (17 firms x 5 hours x $34.68). 2 Thus, the total cost associated with
the testing and recordkeeping burden is about $45,681 ($42,733 + $2,948). This
estimate includes professional and clerical time that may be spent to retrieve
product data from automated or other records systems, explain firm
practices/policies intended to assure compliance with the standard, or
accompany Commission personnel during inspections.
13.
Estimates of other total annual cost burden to respondents or
recordkeepers
There are no costs to respondents beyond those presented in Section
A.12. There are no other operating, maintenance, or capital costs associated with
the collection.
14.

Estimate of annualized costs to the federal government

Approximately 1.5 staff months for agency employees to examine and
evaluate the information could be required for compliance activities. The
estimated annual cost to the federal government is based on performance of the
work by employees paid at a GS-12 Step 5 pay rate employee, $101,813.
According to the most recent Employer Costs for Employee Compensation, this
represents approximately 68.4 percent of total compensation for management,
professional and related occupational groups. 3 Therefore, total compensation for
an employee at the GS-12 Step 5 pay rate will have an annual value of about
$148,849 (or $12,404 per month). The annual cost to the federal government of
the collection of information is therefore estimated to be about $18,606 ($12,404
times 1.5 months).
2 U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” September
2021, Table 4. Private industry workers by occupational and industry group:
https://www.bls.gov/news.release/ecec.t04.htm.
3
U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” September
2021, Table 2, https://www.bls.gov/news.release/ecec.t02.htm.

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15.

Program changes or adjustments

No change has been made to the collection of information in the Safety
Standard for Automatic Residential Garage Door Operators since it was last
approved by OMB.
According to available data, CPSC has identified 17 firms the supply
automatic residential garage door operators that would be subject to PRA burden
under this collection. Therefore, since the last PRA renewal, staff has reduced
the estimated number of firms subject to PRA burden from 18 to 17, based on
currently available information. Accordingly, staff estimates total burden hours
associated with the collection have declined from 720 to 680, as a result of
changes to agency estimates.
16.

Plans for tabulation and publication
Not applicable.

17.

Rationale for not displaying the expiration date for OMB approval
Not applicable.

B.

Collection of Information Employing Statistical Methods
Not applicable.

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