WE HAVE APPROVED THIS COLLECTION OF INFORMATION FOR SIX MONTHS TO ALLO THE AGENCY SUFFICIENT TIME TO ADDRESS SEVERAL QUESTIONS. FIRST, IT APPEARS THAT OSHA FORM 71 COULD BE REPLACED BY A CERTIFICATION AS DEFINED AT 5 CFR 1320.7(K)(1). SECOND, IT IS NOT CLEAR WHY THE RECORD OF TESTS OF HAZARDOUS ATMOSPHERES COULD NOT BE REPLACED BY A CERTIFICATION ATTESTING THAT THE TESTS HAD BEEN DONE AND CORRECTIVE ACTION TAKEN IF NEEDED. THIRD, THE RECORDKEEPING REQUIREMENTS AT 1917.50, CERTIFICATION OF MARINE TERMINAL MATERIALS HANDLING DEVICES, APPEAR TO BE CERTIFICATIONS AS DEFINED AT 5 CFR 1320.7(K)(1). IF THEY ARE, OMB APPROVAL IS NOT REQUIRED, NOR SHOULD THESE HOURS BE INCLUDED N THE INVENTORY. FOURTH, IT IS NOT CLEAR WHY THE RECORDS OF THE RESULTS OF TESTS OF ELEVATORS AND ESCALATORS AT 1917.116 COULD NOT BE CERTIFICATIONS. FIFTH, IT IS NOT CLEAR WHY THE AGENCY REQUIRES PROOF OF "FINANCIAL STABILITY" AND A DETAILED SCHEDULE OF FEES FROM PERSONS SEEKING ACCREDITATION, AS REQUIRED AT 1919.3(B)(5) AND (6). SIXTH, TH REPORTING REQUIREMENTS AT 1919.11(E) AND (F) APPEAR TO HAVE NO PRACTICAL UTILITY, PARTICULARLY GIVEN THE REQUIREMENTS AT 1919.11(A), (B) AND (C). THE AGENCY SHOULD ALSO ADDRESS THESE ISSUES, IF POSSIBLE IN THE UPCOMING PROPOSED RULES ON PARTS 1915 AND 1918.
Inventory as of this Action
Requested
Previously Approved
07/31/1987
07/31/1987
10/31/1986
27,902
0
22,040
38,254
0
35,754
0
0
0
OSHA NEEDS THIS INFORMATION TO ACCREDIT COMPANIES TO INSPECT AND PROVIDE CERTIFICATION FOR CRANES, DERRICKS AND ACCESSORY GEAR USED IN LONGSHORING AND SHIPYARD INDUSTRIES AND MARINE TERMINALS. USE OF THE OSHA FORMS 70, 71, AND 72, HAS PROVEN SUCCESSFUL, AND THEIR USE HAS SERVED AS AN AID TO THE AGENCY AND THE INDUSTRY IN TRACKING CONDITIONS GERMANE TO EMPLOYEE SAFETY AND HEALTH.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.