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Note to Reviewer
The Terms of Clearance in the November 13, 2002 Office of Management and Budget's (OMB), Notice of Action for the "Standard on the Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147)" contained comments from OMB. OSHA prepared three separate responses addressing OMB's comments. The first response addresses OMB's assertion that OSHA adopted an interpretation regarding energy-control procedures that is contrary to the original Regulatory Impact Analysis. The second response addresses OMB's request for further economic analysis for the Control of Hazardous Energy Information Collection Request (ICR). The updated Supporting Statement adopts an economic approach that OSHA believes is reasonable. Finally, the Agency responds to OMB's request to provide examples of various written documentations addressing written energy control procedures, by referencing an OMB/OSHA site-visit to a manufacturing plant that implements a number of varied energy control procedures. Attached are the Agency's responses followed by the updated Supporting Statement. 1. OSHA's Response to OMB's Assertion that OSHA has Adopted an Interpretation Regarding Energy-Control Procedures that is Contrary to the Original Regulatory Impact Analysis The Terms of Clearance in the Office of Management and Budget's November 13, 2002 Notice of Action concerning the Standard on the Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) suggests that some misunderstanding remains regarding the obligation to develop energy-control procedures pursuant to 29 CFR 1910.147(c)(4)(i) and (ii). OSHA believes that this misunderstanding may be the product of a misconception regarding the options available for complying with the provisions of 1910.147(c)(4)(i) and (ii). While the Standard is a "performance" standard, which provides an employer significant latitude to develop the procedures that may be implemented most easily and effectively in a particular work environment, some people have construed the Standard to limit an employer's options to either a single "generic, plant-wide procedure" or a significant number of "machine-specific procedures." In reviewing comments using the phrase "generic, plant-wide procedure," OSHA understands the commenters to mean a single procedure that would detail the energy-control practices in a general manner for all machines at a facility, regardless of variations between machines or the associated energy isolation devices. Likewise, in reviewing comments using the phrase "machine-specific procedures," OSHA understands the commenters to be referring to a unique procedure for each individual machine, regardless of whether groups of machines are similar and regardless of whether the energy-control devices associated with groups of machines are the same or similar. However, OSHA has clearly and consistently rejected this "either/or" dichotomy. Instead, OSHA has recognized that the performance language of the Standard permits employers to adopt options that lie between a "generic plant-wide procedure" and "machine-specific procedures." For example, while a single generic procedure often will lack the specificity required by 1910.147(c)(4)(ii) due to variations between the machines at a facility, an employer may combine common procedural elements into a generic, plant-wide procedure and then supplement the procedure with checklists, appendices, and/or work orders that address the unique characteristics of individual machines (or groups of machines) and energy isolation devices. Likewise, while an employer may develop a unique procedure for each individual machine in a facility, the employer also may develop one procedure for each group of similar machines that have the same or similar types of energy isolation devices. Indeed, since the Standard was promulgated, OSHA has permitted employers significant latitude in developing energy-control procedures, ultimately insisting only that the procedures (either alone or in conjunction with associated provisions, such as checklists, appendices, and work orders) provide sufficient specificity to permit employees to effectively isolate hazardous energy and safely perform servicing and maintenance activities. ERG's Report and OSHA's Regulatory Impact Analysis OSHA published the Regulatory Impact and Regulatory Flexibility Analysis of 29 CFR 1910.147 (The Control of Hazardous Energy Sources -- Lockout/Tagout) in August 1989. The Agency's conclusions concerning the cost of developing and (in many cases) documenting energy-control procedures were based on a report by ERG, as well as a review of the docket associated with the development of the Standard. RIA at VI-31. The ERG report, in turn, recognized that the Standard would not always permit an employer to develop, document, and use one generic procedure per worksite. Rather, after considering the guidance provided in the Standard's non-mandatory Appendix, ERG concluded that: The Appendix suggests that a complete set of procedures be prepared to govern maintenance and servicing tasks. The procedures would require identification and locking or tagging of all hazardous energy sources. Other topics firms should cover would include:ERG Report at 7-67 to 7-68. ERG used this understanding "in guiding the preparation of cost estimates" for the development and documentation of energy-control procedures. Id. at 7-68. ERG determined the cost for developing energy-control procedures using the assumption that many employers would adopt a general lockout/tagout procedure to cover the basic content and format of procedures in the plant. This general procedure, which frequently can be summarized in a few typed pages, would provide all of the procedural items [previously identified by ERG], except for those items which must be specified in checklists for specific machines. In most plants, all of the procedural issues (including the items listed above) can be covered in a plant-wide or facility-wide procedure. Id. at 7-68 (emphasis added).Thus, ERG explicitly recognized that, while many portions of an energy-control procedure frequently may be standardized throughout a facility, it would be necessary to supplement the generic procedure with checklists to provide the required specificity. For example, it may be necessary to supplement a plant-wide procedure in circumstances in which energy associated with one group of machines was isolated by different energy isolation devices than energy associated with a second group machines, or in circumstances in which verification of de-energization was achieved differently for two distinct groups of machinery. Thus, given the diversity and complexity of machinery often associated with larger firms, ERG assumed that larger firms would take significantly longer than smaller firms to develop and document procedures with the necessary specificity (assuming no pre-existing procedures) -- e.g., 40 hours for high-impact large firms; 20 hours for high-impact medium firms; 6 hours for high-impact small firms; and 1 hour for high-impact very small firms. OSHA relied heavily on ERG's analysis in developing the section of the Regulatory Impact Statement concerning the cost of developing and documenting energy-control procedures. RIA at VI-31. Using ERG's calculation, OSHA assumed that "high-impact" firms already complying with the relevant ANSI standard would require from one hour to sixteen (16) hours (depending upon the size of the establishment -- from "very small to "large") to bring existing procedures into conformity with the requirements of the new standard. OSHA further assumed that "high-impact" firms that had no existing procedure would require from one hour to forty (40) hours (depending upon the size of the establishment -- from "very small to "large") to develop and document procedures that conformed with the requirements of the new standard. The Standard's Provisions Concerning Energy-control Procedures The manner in which ERG (in its report) and OSHA (in the regulatory-impact analysis) described an employer's obligation with respect to energy-control procedures was consistent with the Standard's provisions for developing and documenting energy-control procedures, as detailed in 29 CFR 1910.147(c)(4)(i) and (ii). In this regard, 29 CFR 1910.147(c)(4)(i) states: (4) Energy-control procedure.(i) Procedures shall be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.The Standard also provides that any energy-control procedure must meet the following conditions specified by 29 CFR 1910.147(c)(4)(ii): The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to the following:OSHA's Discussion of Energy-control Procedures in the Standard's Preamble The manner in which ERG (in its report) and OSHA (in the regulatory-impact analysis) described an employer's obligation with respect to energy-control procedures also was consistent with OSHA's intent regarding the specificity of energy-control procedures, as explained in the Standard's preamble: In paragraph (c)(4), OSHA requires that employers develop, document, and utilize procedures for the control of potentially hazardous energy, and that the procedures clearly and specifically outline the steps to be followed, techniques to be used, and measures to be applied by the employer to assure that the procedure is used.54 FR 36644, 36670-71 (September 1, 1989), as corrected by 55 FR 38677-88 (September 20, 1990). OSHA's History of Administering the Standard's Energy-control Procedure Provisions OSHA regularly has administered the provisions concerning the development and documentation of energy-control procedures in a manner consistent with the Standard's language and the Agency's explanation in the Standard's preamble. For example, on April 10, 1991, in responding to an inquiry from Duane Barns, the Director of OSHA's Directorate of Compliance Programs stated that: During the meetings on the lockout/tagout regulations, discussions were conducted concerning the use of a "generic" procedure for the various types of energy which would be encountered at a facility. The generic procedure would have to be included as a component of the company's lockout/tagout procedure and would additionally require that the company procedure clearly enunciate the further specific requirements for servicing and maintenance "work authorization permits." The company procedure would have to specify that the work permit identify the equipment to be serviced, the types and unique energy characteristics to be encountered, methods for safe work, and the process or procedures to be used to accomplish the task.... A company procedure which mandates that "generic" procedures are to be augmented with specific operational procedures as part of a required work permit system provides for compliance with the standard.Likewise, on September 19, 1995, in response to an inquiry from Lawrence P. Halprin, Esq., the Director of OSHA's Directorate of Compliance Programs acknowledged that: [a] separate procedure does not have to be developed for each and every machine or piece of equipment and that a comprehensive (generic) energy-control procedure with supplemental checklists or appendices may very well address adequately the steps necessary to perform servicing and maintenance safely. Such a procedure would normally be considered one procedure. OSHA believes, however, that there are also situations which require a unique energy-control procedure to deal with the servicing and maintenance hazards.Most recently, in the August 2002 Supporting Statement for the Information-Collection Requirements for the Standard on the Control of Hazardous Energy Sources (Lockout/Tagout) (29 CFR 1910.147), OSHA stated that [the Agency] does not enforce requirements for "machine-specific" procedures, and recognizes that "[s]imilar machines and/or equipment (those using the same type and magnitude of energy) and which have similar types of controls can be covered with a single procedure." When necessary, an employer may develop several energy-control procedures for similar groups of machines or equipment. These individual procedures may have a number of identical portions, but will provide specific guidance regarding the intended use of the lockout procedure, instructions for de-energizing the machine, use of lockout/tagout devices, and how to test machines or equipment to verify the effectiveness of the energy-control measures used.... Alternatively, the employer may develop a single, generic procedure and supplement it with checklists that provide this guidance for similar groups of machines or equipment.Conclusion Since the Control of Hazardous Energy (Lockout/Tagout) standard was promulgated, OSHA has interpreted and enforced the provisions of the Standard concerning energy-control procedures in a consistent manner, which is in accordance with the Standard's language and the preamble explanation of these provisions. Moreover, while OSHA has increased the burden hours associated with the development and documentation of energy-control procedures over the last several years in response to valid comments addressing the burden of complying with provisions concerning energy-control procedures, neither ERG (in its analysis) nor OSHA (in the regulatory-impact analysis) assumed or indicated that every workplace could satisfy the provisions of § 1910.147(c)(4) merely by developing one plant-wide generic procedure for all pieces of machinery and equipment at the facility. Thus, it is incorrect to conclude that, for purposes of calculating the regulatory burden, the Agency assumed "one generic procedure per worksite." Not only does such a conclusion misconstrue OSHA's regulatory analysis, it is inconsistent with the language of the Standard and the Agency's long-standing interpretation of the Standard, and it would permit employers in certain instances to develop energy-control procedures without the level of detail necessary to permit employees to effectively isolate hazardous energy and safely perform servicing/maintenance activities. 2. Response to OMB's Request for Further Economic Analysis of the Control of Hazardous Energy ICR (OMB Control No. 1218-0150) The Terms of Clearance for this ICR requested that OSHA conduct an economic analysis of its provisions specifying energy-control procedures (29 CFR 1910.147(c)(4)) to examine the regulatory impact of these provisions "as currently interpreted and enforced." As discussed in Response 1, the Terms of Clearance addresses an issue that OSHA believes evolved due to miscommunication regarding the degree of specificity required for energy-control procedures. In this regard, OSHA notes that, in assessing the burden associated with the development of energy-control procedures in the late 1980s, the Agency and its contractor (ERG) attempted to ascertain the burden associated with types of procedures that are consistent with procedures that OSHA currently expects employers to develop and implement. In responding to the Terms of Clearance, OSHA recognizes that the ultimate concern is whether the regulatory-impact analysis adequately accounted for the burden hours necessary to develop procedures mandated by 1910.147(c)(4)(ii). In conducting its review, OSHA identified the following two issues that it may not have addressed fully in the regulatory-impact analysis:
Issues with Respect to the Baseline (Number of Employers Affected by the Energy-Control Procedure Provisions) OSHA used a 1984 employer survey to estimate the percentage of affected employers already using written energy-control procedures. The survey question asked if the employer had written procedures, but did not address the question of how tailored the procedures were to specific types of machines. Thus, an employer with written procedures that lacked the detail necessary to comply with the provisions of 1910.147(c)(4)(ii) could reasonably have answered "yes" to this question, as could an employer with procedures fully in accordance with OSHA's subsequent requirements regarding written procedures. For this reason, OSHA agrees that the analysis likely overestimated the percentage of employers having written procedures that would comply with the Standard. Unfortunately, no cost-effective and reliable method is available to determine what kinds of written procedures were in place prior to 1989 (the year OSHA published the final Standard). However, one approach would be to assume that no employer had developed written procedures with the degree of detail required by the Standard (i.e., no employer had developed procedures at that time with detailed directions for locking out or tagging out distinct types of machines). If this assumption is made, the burden for written procedures would increase from approximately 950,000 hours to approximately 1.7 million hours. See Response Table 3A. Since a program for controlling hazardous energy that did not clearly inform workers how to control hazardous energy on given machines would be useless, it is reasonable to assume that many employers did develop and implement detailed energy-control procedures prior to promulgation of the Standard. Thus, a presumption that none of the employers with written procedures had developed procedures with sufficient specificity to meet the terms of the Standard likely would significantly overestimate the burden hours. A more reasonable approach, in the absence of further data, would be to assume that approximately one-half of the employers who responded that they had written procedures would need to supplement existing procedures with additional detail or develop new procedures. This approach would result in a burden hour increase of approximately 373,500 hours for a total of 1,315,225 burden hours(1). See Response Table 3C for details. Issues with Respect to the Hours Required to Develop Compliant Written Procedures The Terms of Clearance states that the original regulatory analysis "assumed one generic procedure per worksite." As noted in the ICR, if OSHA assumed one plant-wide generic procedure for each worksite, the regulatory analysis would not have estimated that a large firm with many distinct types of machines would require 40 hours to develop written procedures, while a small firm with only a few types of machines would only require one hour. Similarly, large firms in industries with diverse types of machines required 40 hours to develop written procedures, while those in industries with less diverse machinery required 20 hours. Therefore, if only one plant-wide generic procedure had been assumed, the time required to develop such procedures would have been more uniform across firm sizes, regardless of the number and diversity of machines at the worksite. After reviewing comments to the December 28, 2001 ICR with respect to the diversity of machines that may exist in a given facility, OSHA determined that the estimates that it used in the past may be too low considering the diversity of machinery across facilities. In other words, while OSHA had not changed its interpretation regarding the Standard's requirements, the Agency conceded that it had underestimated the diversity of machinery to which the Standard may apply at individual worksites. Further, OSHA was concerned that the estimates in the previous ICRs did not closely track the original regulatory analysis. As a result, in its August 30, 2002 ICR, OSHA modified its estimates of the burden associated with written procedures, raising the annual burden estimate from 241,000 hours to 950,000 hours OSHA Estimates Compared to Commenter Estimates One commenter (Lawrence Halprin)(2) assumed that employers developed no written procedures for the baseline condition; consequently, he developed a somewhat higher estimate (than OSHA's) of the hours required to compile individual written procedures, resulting in a total burden of approximately 2.1 million hours. See Response Table 3B. When OSHA assumed that no employers had developed compliant procedures prior to the promulgation of the Standard, the Agency estimated the total burden to be approximately 1.7 million hours. See Response Table 3A. The difference between these two estimates (approximately 400,000 hours) is small enough that it can be attributed to differences in estimating the costs of developing the same types of procedures, rather than differences concerning the underlying characteristics of the procedures to be developed. Conclusion OSHA believes the most reasonable approach to resolve these issues is to assume, for the purposes of establishing the baseline, that approximately one-half of the employers reporting written procedures developed compliant written procedures prior to the promulgation of the Standard. (Table 3 in The Supporting Statement has adopted this approach.) This approach yields an annual burden estimate of 1,315,000 hours, as opposed to the current estimate of 950,000(3) burden hours. Additional analysis attempting to more precisely ascertain the baseline would be costly and unproductive given the absence of historical data. Further analysis of the second issue would require expending several hundred thousand dollars for a survey to better resolve the issue. Even with a valid survey, reasonable estimates of burden hours may well differ by margins similar to the current differences between OSHA's estimates and the estimates of the commenter. Explanation of Response Tables 3, 3A, 3B, and 3C OSHA originally developed Response Table 3 to support its May 2002 ICR for the Standard. The table was derived from the 1989 Regulatory Impact Analysis supporting the Standard. It differentiates the burden-hour calculation by size of establishment in high-impact establishments, and adjusts for current practice estimated at the time the Standard took effect (i.e., whether employers had developed written energy-control procedures). Different calculations are required to estimate burdens for new and existing establishments in both high- and low-impact sectors. OSHA doubled the burden hours from the original RIA to account for the burden associated with writing procedures for diverse machines. Subsequent to the May 2002 ICR, OSHA found that the Food Services sector had been omitted from the analysis; when OSHA corrected Table 3 in the ICR to account for the Food Services sector, the burden-hour total changed slightly (from 941,725 to 950,007). Response Table 3A uses OSHA's estimates of unit time, assuming no establishments had compliant written procedures at the time the Standard took effect (1,680,444 hours). Response Table 3B is based on Mr. Halprin's unit costs and the assumption that, before its promulgation, no establishments had written procedures that complied with the Standard's requirements (2,089,213 hours). Response Table 3C uses OSHA's estimates of unit time, assuming that one-half of the establishments had compliant written procedures at the time the Standard took effect (1,315,225 hours). Response Table 3 Original table submitted to OMB (corrected for omitted Food Stores sector) -- 950,007 total burden hours for written procedures Establishment Calculations - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - High-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishments - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - Low-Impact Establishments
Calculation of Hours for Existing Establishments - Low-Impact Establishments
GRAND TOTAL 644,657 High-Impact Establishments 305,350 Low-Impact Establishments 950,007 * The RIA estimated 10% of establishments with LO/TO programs lacked written workplans; for simplification, this analysis has assigned this small group the same burden-hour estimate as those establishments without LO/TO programs. Note: Numbers may not total due to rounding. Response Table 3A Using OSHA's unit-cost estimates, assuming no current compliance -- 1,680,445 total burden hours for written procedures Establishment Calculations - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - High-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishments - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) -- Low-Impact Establishments
Calculation of Hours for Existing Establishments - Low-Impact Establishments
GRAND TOTAL 1,375,095 High-Impact Establishments 305,349 Low-Impact Establishments 1,680,445 * Unit-time estimates with no offset for current practice Note: Numbers may not total due to rounding. Response Table 3B Using Mr. Halprin's unit-time estimates, assuming no current compliance -- 2,089,213 total burden hours for written procedures Establishment Calculations - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - High-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishments - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - Low-Impact Establishments
Calculation of Hours for Low-Impact Establishments
GRAND TOTAL 1,827,485 High-Impact Establishments 261,727 Low-Impact Establishments 2,089,213 *Using Halprin's unit-cost estimates With no offset for current practice Note: Numbers may not total due to rounding. Response Table 3C Assuming half of the original compliance rates (corrected for omitted Food Service sector) -- 1,315,225 total burden hours for written procedures Establishment Calculations - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - High-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishments - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - Low-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishments - Low-Impact Establishments
GRAND TOTAL 1,009,876 High-Impact Establishments 305,350 Low-Impact Establishments 1,315,225 * The RIA estimated 10% of establishments with LO/TO programs lacked written workplans; for simplification, this analysis assigned this small group the same burden-hour estimate as those establishments without a LO/TO program. Note: Numbers may not total due to rounding. 3. Response to OMB's Request to Provide Examples of Equipment Subject to the Standard with Minimally Compliant and Non-Compliant Written Energy-Control Procedures The Terms of Clearance for this ICR requested that OSHA provide "written descriptions of particular equipment (with multiple energy sources) and controls at one or more manufacturing facilities subject to this Standard, as well as minimally acceptable written energy control procedure or procedures that would satisfy OSHA's current interpretation of the Standard." The Terms of Clearance also requested that OSHA "provide examples of procedures that do not satisfy the standard." After receiving the Terms of Clearance, OSHA contacted OMB and recommended an alternative approach that OSHA believed would provide OMB with the information it requested in the Terms of Clearance. In making this recommendation, OSHA noted that the Standard was a "performance" standard, and that it would be of little value to develop and discuss examples of written energy-control procedures that were not related to specific types of machines or equipment or to particular servicing and maintenance activities. OSHA's recommended alternative was to arrange for a worksite visit, during which OSHA and OMB would review actual energy-control procedures and observe these procedures during servicing and maintenance operations. OMB agreed that a site visit would be more beneficial than reviewing example energy-control procedures in the abstract. On August 14, 2003, staff from OSHA and OMB visited the General Electric (GE) light- bulb manufacturing facility in Winchester, Virginia. During the visit, OSHA and OMB representatives reviewed a number of energy-control procedures, and learned about the manner in which the GE facility implemented the procedures when engaging in various servicing and maintenance activities. After completing the worksite visit, the OMB representative indicated that the visit was beneficial, and believed that it provided much more valuable information than would have been the case if OSHA merely submitted abstract examples of energy-control procedures. It was OSHA's understanding at that time that the site visit was an acceptable substitute for providing examples of energy-control procedures, and the equipment subject to these procedures, as requested by OMB in the Terms of Clearance. SUPPORTING STATEMENT FOR
THE INFORMATION-COLLECTION REQUIREMENTS FOR THE STANDARD ON THE CONTROL OF HAZARDOUS ENERGY (LOCKOUT/TAGOUT) (29 CFR 1910.147(4) (OMB CONTROL NO. 1218-0150 (January 2004))  Federal Register [03/11/2004] # 68:11664-11666Control of Hazardous Energy (Lockout/Tagout) Standard; Extension of the Office of Management and Budget's Approval of Information-Collection (Paperwork) Requirements 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 objective of the Occupational Safety and Health Act of 1970 (i.e., "the 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 Act authorizes "the development and promulgation of occupational safety and health standards." (29 U.S.C. 651.) Section 6(b)(7) of the Act specifies that "[a]ny standard promulgated under this subsection shall prescribe the use of labels or other appropriate forms of warning as are necessary to insure that employees are apprised of all hazards to which they are exposed, relevant symptoms and appropriate emergency treatment, and proper conditions and precautions of safe use or exposure." This provision goes on to state that "[t]he Secretary, in consultation with the Secretary of Health and Human Services, may by rule promulgated pursuant to section 553 of title 5, United States Code, make appropriate modifications in the foregoing requirements relating to the use of labels or other forms of warning . . . as may be warranted by experience, information, or medical or technological developments acquired subsequent to the promulgation of the relevant standard." (29 U.S.C. 655.) With regard to recordkeeping, the 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.) The Act states further that "[t]he Secretary . . . shall prescribe such rules and regulations as [he/she] may deem necessary to carry out [his/her] responsibilities under this Act, including rules and regulations dealing with the inspection of an employer's establishment." (29 U.S.C. 657.) Under the authority granted by the Act, the Occupational Safety and Health Administration (i.e., "OSHA" or "the Agency") published at 29 CFR 1910.147 a safety standard for general industry titled "Control of Hazardous Energy (Lockout/Tagout)" (i.e., "the Standard"). The Standard regulates control of hazardous-energy sources using lockout or tagout procedures while employees service, maintain, or repair machines or equipment when activation, start up, or release of energy from an energy source is possible. Items 2 and 12 below describe in detail the specific information-collection requirements of the Standard. 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. The Standard specifies several paperwork requirements. The following sections describe who uses the information collected under each requirement, as well as how they use it. The purpose of these requirements is to control the release of hazardous-energy sources while employees service, maintain, or repair machines or equipment when activation, start up, or release of energy from an energy source is possible; proper control of hazardous-energy sources prevent death or serious injury among these employees. Energy-Control Procedure (paragraph (c)(4)(i)). With limited exception, employers must document the procedures used to isolate from its energy source and render inoperative, any machine or equipment prior to servicing, maintenance, or repair by employees. These procedures are necessary when activation, start up, or release of stored energy from the energy source is possible, and such release could cause injury to the employees. Paragraph (c)(4)(ii) states that the required documentation must clearly and specifically outline the scope, purpose, authorization, rules, and techniques employees are to use to control hazardous energy, and the means to enforce compliance. The document must include at least the following elements: (A) A specific statement regarding the use of the procedure;The employer uses the information in this document as the basis for informing and training employees about the purpose and function of the energy-control procedures, and the safe application, use, and removal of energy controls. In addition, this information enables employers to effectively identify operations and processes in the workplace that require energy-control procedures. Periodic Inspection (c)(6)(ii). Under paragraph (c)(6)(i), employers are to conduct inspections of energy-control procedures at least annually. An authorized employee (other than an authorized employee using the energy-control procedure that is the subject of the inspection) is to conduct the inspection and correct any deviations or inadequacies identified. For procedures involving either lockout or tagout, the inspection must include a review, between the inspector and each authorized employee, of that employee's responsibilities under the procedure; for procedures using tagout systems, the review also involves affected employees, and includes an assessment of the employees' knowledge of the training elements required for these systems. Paragraph (c)(6)(ii) requires employers to certify the inspection by documenting the date of the inspection, and identifying the machine or equipment inspected and the employee who performed the inspection. Training and Communication (c)(7)(iv). Paragraph (c)(7)(i) specifies that employers must establish a training program that enables employees to understand the purpose and function of the energy-control procedures, and provides them with the knowledge and skills necessary for the safe application, use, and removal of energy controls. According to paragraph (c)(7)(ii), employers are to ensure that: Authorized employees recognize the applicable hazardous-energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control; affected employees obtain instruction in the purpose and use of the energy-control procedure; and other employees who work, or may work, near operations using the energy-control procedure receive training about the procedure, as well as the prohibition regarding attempts to restart or reactivate machines or equipment having locks or tags to control energy release. When the employer uses a tagout system, the training program must inform employees that: Tags are warning labels affixed to energy-isolating devices, and therefore do not provide the physical restraint on those devices that locks do; they are not to remove tags attached to an energy-isolating devices unless permitted to do so by the authorized employee responsible for the tag, and they are never to bypass, ignore, or in any manner defeat the tagout system; tags must be legible and understandable by authorized and affected employees, as well as other employees who work, or may work, near operations using the energy-control procedure; the materials used for tags, including the means of attaching them, must withstand the environmental conditions encountered in the workplace; tags evoke a false sense of security, and employees must understand that tags are only part of the overall energy-control program; and they must attach tags securely to energy-isolating devices to prevent removal of the tags during use. Paragraph (c)(7)(iii) states that employers must retrain authorized and affected employees when a change occurs in: Their job assignments, the machines, equipment, or processes such that a new hazard is present; and the energy-control procedures. Employers also must provide retraining when they have reason to believe, or periodic inspection required under paragraph (c)(6) indicates, that deviations and inadequacies exist in an employee's knowledge or use of energy-control procedures. The retraining must reestablish employee proficiency and, if necessary, introduce new or revised energy-control procedures. Under paragraph (c)(7)(iv), employers are to certify that employees completed the required training, and that this training is up-to-date. The certification is to contain each employee's name and the training date. Training employees to recognize hazardous-energy sources and to understand the purpose and function of the energy-control procedures, and providing them with the knowledge and skills necessary to implement safe application, use, and removal of energy controls, enables them to prevent serious accidents by using appropriate control procedures in a safe manner to isolate these hazards. In addition, written certification of the training assures the employer that employees receive the training specified by the Standard at the required frequencies. Notification of Employees (paragraph (c)(9)). This provision requires the employer to notify affected employees prior to applying, and after removing, a lockout or tagout device from a machine or equipment. Such notification informs employees of the impending interruption of the normal production operation, and serves as a reminder of the restrictions imposed on them by the energy-control program. In addition, this requirement ensures that employees do not attempt to reactivate a machine or piece of equipment after an authorized employee isolates its energy source and renders it inoperative. Notifying employees after removing an energy-control device alerts them that the machines and equipment are no longer safe for servicing, maintenance, and repair.(5) Outside Personnel (Contractors, etc.) (paragraph (f)(2)(i)). When the onsite employer uses an offsite employer (e.g., a contractor) to perform the activities covered by the scope and application of the Standard, the two employers must inform each other regarding their respective lockout or tagout procedures. This provision ensures onsite employers know about the unique energy-control procedures used by an offsite employer; this knowledge prevents any misunderstanding regarding the implementation of lockout or tagout procedures, and the use of lockout or tagout devices for a particular application. Disclosure of Inspection and Training Certification Records (paragraphs (c)(6)(ii) and (c)(7)). The inspection records provide employers with assurance that employees can safely and effectively service, maintain, and repair machines and equipment covered by the Standard. These records also provide the most efficient means for an OSHA compliance officer to determine that an employer is complying with the Standard, and that the machines and equipment are safe for servicing, maintenance, and repair. The training records provide the most efficient means for an OSHA compliance officer to determine whether an employer has performed the required training at the necessary and appropriate frequencies. 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 burden. Employers may use automated, electronic, mechanical, or other technological information-collection techniques, or other forms of information technology (e.g., electronic submission of responses), when establishing and maintaining the required records. The Agency wrote the paperwork requirements of the Standard in performance-oriented language ( i.e., in terms of what data to collect, 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 purpose(s) described in 2 above. The requirements to collect and maintain information are specific to each employer and employee involved, and no other source or agency duplicates these requirements or can make the required information available to OSHA (i.e., the required information is available only from employers). 5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe the methods used to reduce the 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 or is not conducted less frequently, and any technical or legal obstacles to reducing the burden. The Agency believes that the information-collection frequencies required by the Standard are the minimum frequencies necessary to effectively regulate hazardous-energy sources, and thereby fulfill its mandate "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" as specified by the Act at 29 U.S.C. 651. Accordingly, when employers do not perform the required information collections, or delay in providing this information, employees may not use energy-control procedures effectively and safely, thereby increasing their probability of death and serious injury caused by uncontrolled release of hazardous energy. 7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
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 before submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to those comments specifically address comments received on cost and hour burdens. 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, revealed, 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 three years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that mitigate against 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 will publish a notice in the Federal Register requesting public comment on its request to extend the Office of Management and Budget's previous approval of the collection-of-information requirements specified by the Standard. This notice is part of a preclearance consultation program that provides the general public and government agencies with an opportunity to comment on this request. 9. Explain any decision to provide any payments or gift to respondents, other than reenumeration 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 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. None of the provisions in the Standard require sensitive information. 12. Provide estimates of the hour burden of the collection of information. The statement should:
For this Information-Collection Request (ICR), OSHA used an industry-classification scheme from the Regulatory Impact Analysis (RIA) performed on the final Standard.(6) This scheme classifies industries covered by the Standard into the following three impact groups: High-impact, low-impact, and zero- or negligible-impact. The high-impact group consists of all manufacturing industries (i.e., Standard Industrial Codes (SICs) 20-39), while the low-impact group includes industries in the following sectors: Transportation (i.e., SICs 40-47), utilities (i.e., electrical-generation establishments, but not power-distribution establishments (i.e., SIC 49, less 491 and 4931)), wholesale-trade, retail-food, and several industries in the service sector (i.e., personal services (i.e., SIC 72), business services (i.e., SIC 73), automotive repair (i.e., SIC 74), miscellaneous repair (i.e., SIC 76), and amusement services (i.e., SIC 79). Included in the zero- or negligible-impact group are industries found to have little potential for an accident involving hazardous-energy release. These industries include retail-trade, finance, insurance, real-estate, service, and public-administration industries not classified in the high- or low-impact groups. In deriving establishment and employment figures for the three impact groups, the Agency updated the total number of establishments from the previous ICR using census data from the 1997 County Business Patterns(7). The Agency applied percentages obtained from the RIA to these updated figures to estimate the number of high- and low-impact establishments having authorized employees as well as the number of authorized and affected employees at these establishments (see Tables 1 and 2). Regarding the time estimates for performing the wide variety of information collections required by the Standard, OSHA is using the time estimates from the previous ICR. These estimates appear to be reasonable because the Agency based them on data from the RIA which was available for public review and comment when it was published in the final Standard. In addition, most of the establishments engaged in performing these information collections have many years of experience in doing so; therefore, these times probably are upper-bound estimates. In determining the wage rates for the various occupations that perform the paperwork requirements, OSHA used the most recent data from Employer Costs for Employee Compensation, Bureau of Labor Statistics (BLS), U.S. Department of Labor (DOL), March 2003. The specific wage rate for each occupation, which includes a fringe-benefit rate of 27.8 percent, is provided as follows:
(A) Energy-Control Procedure (paragraph (c)(4)(i)) OSHA estimates that 32,917 high-impact establishments develop new procedures annually. The time to perform this activity ranges from 2 to 80 hours. In addition, 43,621 low-impact establishments will develop new procedures. The time for low-impact establishments to develop procedures is estimated at 2 hours. (See Table 3 for specific number of establishments in each size category for both high- and low-impact establishments; the burden hour for each size establishment; and details as to how OSHA arrived at the number of establishments.) The Agency also estimates that, on a yearly basis, a supervisor takes from 30 minutes (.50 hour) to 20 hours to update procedures in the 329,168 high-impact establishments and 30 minutes to update procedures in the 436,213 low-impact establishments affected. (See Table 3 for specific number of establishments in each size category for both high- and low-impact establishments; the burden hour for each size establishment; and details as to how OSHA arrived at the number of establishments.) Therefore, the total burden hours are calculated as follows:
(B) Periodic Inspection (paragraph (c)(6)(ii)) OSHA assumes that a supervisor takes 20 minutes (.33 hour) to inspect an establishment's energy-control procedure once a year, and to prepare and maintain the inspection certificate. Therefore, the estimated total yearly burden hours and cost resulting from this paperwork requirement are:
(C) Training and Communication (paragraph (c)(7)) The Agency estimates that 7.72 million employees covered by the Standard require training each year (i.e., the total number of authorized and affected employees in high- and low-impact establishments listed in Tables 1 and 2). However, OSHA is not accounting for the burden hours and cost of developing and administering the required training because these requirements are performance based. Nevertheless, this provision specifies that employers must prepare, maintain, and disclose training records. The Agency assumes that, each year, employers have to prepare and maintain training records for 23 percent (i.e., 1,775,600) of these employees (i.e., new employees and employees who require retraining), as well as maintain training records for the remaining 5,944,400 employees. In this regard, OSHA believes that a secretary spends 3 minutes (.05 hour) preparing and maintaining the record for the 23 percent of employees who are new or require retraining; and another 1 minute (.02 hour) maintaining the already prepared record for the remaining employees (77 percent). Accordingly, the annual burden-hour and cost estimates for the paperwork requirements associated with this training requirement are:
(D) Notification of Employees (paragraph (c)(9)) OSHA has determined that the average number of lockout or tagout events that occur annually vary by the size of the establishment and whether the establishment is in a high-impact or low-impact industry. OSHA estimates that there are approximately 124,144 authorized employees(8) in very small, high-impact establishments who would have to notify affected employees of the application and removal of lockout/tagout devices (since this practice was not customary and normal in these facilities prior to the promulgation of the Standard) (see Table 1). OSHA estimates that, on average, there are 75 maintenance or servicing operations conducted annually in each very small, highe-impact establishment. For other high-impact establishments, it is estimated that there are approximately 402,203 authorized employees in establishments who would have to notify affected employees of the application and removal of lockout/tagout devices (see Table 1). It is estimated that, on average, there will be 150 such maintenance or servicing operations conducted annually in each of these establishments. Additionally, there are 655,294 authorized employees in low-impact establishments who would have to notify affected employees of the application and removal of lockout/tagout devices (see Table 2). These employees are estimated to perform, on average, 12 maintenance or servicing operations annually for each low-impact establishment. OSHA estimates that a total of 77,504,778 lockout or tagout events occur annually where notification (not customarily performed) is needed. OSHA assumes that an authorized employee is a non-supervisory manufacturing worker who requires 15 seconds (.004 hour) to provide the required notification (i.e., 10 seconds for applying a lockout/tagout device, and five seconds for removing the device). Accordingly, the total annual burden hour and cost estimates for this notification are: High-impact, very small establishments:124,144 authorized employees x 75 operations/year = 9,310,800 events/yearHigh-impact, other than very small establishments:402,203 authorized employees x 150 operations/year = 60,330,450 events/yearLow-impact establishments:655,294 authorized employees x 12 operations/year = 7,863,528 events/year
(E) Outside Personnel (Contractors, etc.) (paragraph (f)(2)(i)) Paragraph (f)(2)(i) requires onsite and outside (contractor) employers to notify each other of their respective LO/TO procedures. Notification of respective LO/TO procedures takes 5 minutes (.08 hour) for the onsite and outside contractor to meet and discuss respective LO/TO procedures. As both the onsite employer and outside contractor attend the five minute meeting, the Agency assumes a total of 10 minutes (.17 hour rounded) for this requirement. A supervisor/manager, at a wage rate of $28.20 per hour will perform the notifications. Further, OSHA believes that contractors are involved in 10 percent of all lockout/tagout events. As determined above, there are 77,504,778 lockout/tagout events annually that require employees to be notified (77,504,778 x 10% = 7,750,478 notifications).
(F) Disclosure of Inspection and Training Certification Records (paragraphs (c)(6)(ii) and (c)(7)) OSHA believes that approximately 11,459 establishments covered by the Standard(9) will be subject to an OSHA inspection and required to disclose inspection and training certification records annually (see Item 14 below). OSHA estimates that it will take a supervisor 5 minutes (.08 hour) to gather and disclose the requested information.
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.)
14. Provide estimates of the 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), 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 into a single table. OSHA estimates that a compliance officer (GS-12, step 5), with an hourly wage rate of $32.20, spends about 30 minutes (.50 hour) during an inspection reviewing the documents required by the Standard. The Agency determines that its compliance officers will inspect about 11,459 employers who have lockout/tagout programs regulated by the Standard during each year covered by this ICR.(10) OSHA considers other expenses, such as equipment, overhead, and support staff salaries, to be normal operating expenses that would occur without the paperwork requirements specified by the Standard. Therefore, the total cost of these paperwork requirements to the Federal government is:
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1. OSHA is requesting a net increase of 959,248 burden hours (from 2,462,279 to 3,421,527). Table 4 below describes each of the requested burden-hour adjustments. 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. No forms are available for the Agency to display the expiration date. 18. Explain each exception to the certification statement identified in Item 19 per "Certification for Paperwork Reduction Act Submission," of OMB Form 83 I. OSHA is not seeking an exception to the certification statement specified by Item 19 of OMB 83-I Table 1: Establishments and Employment in Manufacturing (SICs 20-39) High-Impact Industries
Source: U.S. Department of Commerce, County Business Patterns, 1997; and Regulatory Impact and Flexibility Analysis of 29 CFR 1910.147 (The Control of Hazardous Energy Sources?Lockout/Tagout), August 1989. Table 2: Establishments and Employment in Low-Impact Industries
*Estimates for the transportation industry include only those firms in SICs 40 47 that are covered under the final rule as outlined on pages II-1 and II-2 of the 1989 RIA. **Estimates for electrical utilities include only facilities involved in electrical consumption as distinct from power distribution (SIC 49 less 491 and 4931). ***Includes personal-services (SIC 72), business services (SIC 73), auto-repair services (SIC 74), miscellaneous-repair services (SIC 76), and amusement services (SIC 79). Source: U.S. Department of Commerce, County Business Patterns, 1997; OSHA Trade News Release, "OSHA Seeks Comments on Impact of Ergonomics Proposal on State and Local Governments, Postal Service, Railroads," May 22, 2000, ; and Regulatory Impact and Flexibility Analysis of 29 CFR 1910.147 (The Control of Hazardous Energy Sources?Lockout/Tagout), August, 1989. Table 3 Written Procedures Assuming Half of the Original "Percent of Establishments in Compliance When the Rule is Published"
(corrected for omitted Food Service Sector) Establishment Calculations - High Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) - High-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishment - High-Impact Establishments
Calculation of Hours for New Establishments (No Existing Program) Low-Impact Establishments
Calculation of Hours for Recurring Burden in Existing Establishment - Low Impact Establishments
GRAND TOTAL 1,009,876 High-Impact Establishments 305,350 Low-Impact Establishments 1,315,225 The RIA estimated 10% of establishments with LO/TO programs lacked written workplans; for simplification, this analysis assigned this small group the same burden-hour estimate as those establishments without LO/TO programs. NOTE: TOTALS MAY NOT EQUAL DUE TO ROUNDING. Table 4: Requested Burden-Hour Adjustments
As a result of decreasing by half the percentage of high-impact establishments that were in compliance when the rule was published, increases occurred in the number of establishments affected by the Standard. Specifically, the percent reductions in Table 3 for the establishment size changed as follows: Very small, 20% to 10%; small, 45% to 22.5%; medium, 65% to 32.5%; and large, 90% to 45%.
Footnote 1 The revised OSHA estimate likely overstates the number of employers having inadequate written energy-control procedures for distinct types of machinery prior to the promulgation of the Standard because an industry consensus standard published in 1982 concerning the control of hazardous energy contained recommendations for developing written energy-control procedures. American National Standards Institute (ANSI), Z244.1-1982, Lockout/Tagout of Energy Sources -- Minimum Safety Requirements. In addition, while the ERG survey did not specifically ask how detailed the written procedures are, it did ask questions that bear on this issue. For example, Table 4-12 of the ERG Report provides results on training questions: 94% of respondents answered that employees were trained on where to place locks/tags on equipment; 82% stated that employees were trained on how to test lockout/tagout procedures to be sure power is off; 67% were trained to bleed off residual energy, pressure, etc. In short, either the procedures were generic but covered different machines in such detail as to be effectively in compliance with the Standard, or they had procedures tailored to specific types of machines. Also, Table 4-16 indicates that a substantial part of the time employers needed for developing their procedures prior to the promulgation of the Standard revolved around the initial decision as to which equipment required lockout/tagout procedures, suggesting that employers voluntarily developed more than a cursory, "one-size-fits-all" plan. (Back to text) Footnote 2 Letter to OSHA dated February 26, 2002, from Lawrence Halprin, Docket No. ICR 1218-0150(2002). (Back to text) Footnote 3 While OSHA initially estimated 942,000 hours, in re-examining the burden-hour calculations, OSHA found this estimate excluded one affected sector. Including this sector in the calculation brings the total burden hours to 950,000 hours. (Back to text) Footnote 4 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 hoe to enforce, these provisions. (Back to text) Footnote 5 Paragraph (e)(2) requires similar notification; because of this similarity, the Agency is taking no burden hours or cost for this provision. (Back to text) Footnote 6 Regulatory Impact and Regulatory Flexibility Analysis of 29 CFR 1910.147 (The Control of Hazardous Energy Sources-Lockout/Tagout), U.S. Department of Labor, OSHA, Office of Regulatory Analysis, August 1989. The source of these data was a contract report titled, Industry Profile Study of a Standard for Control of Hazardous Energy Sources Including Lockout/Tagout Procedures, Eastern Research Group, May 1985. (Back to text) Footnote 7 1997 County Business Patterns, U.S. Department of Commerce, Economics and Statistics Administration, April 2001. (Back to text) Footnote 8 To calculate burden hours and cost, OSHA assumes that every authorized employee will notify the affected employees. The Standard requires only that one of the authorized employees (or an employer representative) notify the affected employees. Thus, OSHA likely overestimates the burden hours and cost associated with this requirement. (Back to text) Footnote 9 OSHA estimated the number of inspections by multiplying OSHA's inspection rate (1.4%) by the number of establishments covered by this ICR (i.e., 818,532 establishments x 1.4% = 11,459 inspections). (Back to text) Footnote 10 The Agency estimated the number of inspections by determining the inspection rate (1.4%) for all employers under the jurisdiction of the OSH Act (including both Federal OSHA and approved state-plan agencies) in 2000, and then multiplying the total number of employers who have employees covered by the Standard (i.e., 818,532; see Tables 1 and 2) by this percentage (i.e., 818,532 employers x 1.4% = 11,459 inspections). (Back to text) |
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