Overview
Title
Agency Information Collection Activities; Submission for OMB Review; Comment Request; Roof Control Plans for Underground Coal Mines
Agencies
ELI5 AI
The Department of Labor wants to know what people think about their new rules to keep roofs from falling down in underground coal mines, asking for thoughts by January 17, 2025. They need a thumbs up from another group, OMB, to make sure gathering this info is helpful and not too hard for the miners.
Summary AI
The Department of Labor, specifically through the Mine Safety and Health Administration (MSHA), is asking for public comments on a proposed information collection regarding Roof Control Plans in underground coal mines. These plans aim to prevent accidents from roof collapses, which are a significant risk in mining. They require approval from the Office of Management and Budget (OMB) under the Paperwork Reduction Act. The public has until January 17, 2025, to submit comments on the necessity and efficiency of this information gathering.
Abstract
The Department of Labor (DOL) is submitting this Mine Safety and Health Administration (MSHA)-sponsored information collection request (ICR) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995 (PRA). Public comments on the ICR are invited.
Keywords AI
Sources
AnalysisAI
The Department of Labor, through its Mine Safety and Health Administration (MSHA), has issued a notice requesting public comments on the collection of information regarding the submission of Roof Control Plans for Underground Coal Mines. This request is made as part of the requirements under the Paperwork Reduction Act of 1995, aiming to ensure that the information collected serves a practical utility and is necessary for the agency's functions. Mines have to submit these plans to prevent significant accidents caused by roof collapses, a notable hazard in underground mining operations. Public feedback is invited until January 17, 2025, especially regarding the efficiency and necessity of this data collection.
Significant Issues and Concerns
While the notice makes a straightforward request for public input, several issues arise from its content:
Evaluation Criteria Ambiguity: The document does not detail how MSHA evaluates the "adequacy" of the roof control plans. This omission leaves some ambiguity regarding what coal mine operators must address in their plans to receive approval. Clear criteria would help stakeholders understand and better implement measures required for safety.
Lack of Detailed Cost and Burden Breakdown: The notice briefly mentions the estimated annual burden hours and costs but fails to elaborate on how these figures were determined. This lack of detail may impact the trust and transparency perceived by the public, as stakeholders may wish to see the calculations that support these estimates.
Vagueness in 'Practical Utility': The term "practical utility" within the request is somewhat vague. Offering specific examples of how the collected information is used in real preventive measures would help clarify the impact and necessity of this data collection process.
Referencing Another Source: The document references another Federal Register notice for more substantive information, requiring interested parties to seek additional sources for details. This could deter some from fully understanding or participating in the review process.
Component Breakdown of Burden: Breaking down the "Annual Burden Hours" and "Total Estimated Annual Other Costs Burden" would allow for deeper insight into what tasks are most time-consuming or costly, helping to identify potential efficiencies.
Impact on the Public and Stakeholders
Broadly, this notice signifies a structured governmental effort to enhance safety regulations within the mining industry through detailed planning requirements. The public, especially those residing in areas with active mining operations, may view these plans as critical to community and worker safety.
For Mining Companies: This document represents not only a safety responsibility but also an administrative requirement that may involve significant time and resources. Transparency in evaluation criteria and burden estimates is crucial to foster compliance and reduce administrative strain.
For Safety Advocates and Miners: The collection of roof control plans should, ideally, promote safer working conditions, reducing the frequency and severity of accidents. Specific stakeholders concerned with workplace environments will likely support measures that are proven to enhance safety.
In summary, the document calls for a cooperative effort between the public and the Department of Labor to ensure mine safety while highlighting areas where better clarity and communication could enhance the effectiveness and acceptance of the safety measures proposed.
Financial Assessment
The document provided outlines a request from the Department of Labor's Mine Safety and Health Administration (MSHA) for comments on an information collection request relating to roof control plans in underground coal mines. A significant aspect of the document is its mention of financial implications associated with this information collection.
Summary of Financial Implications
The document includes a brief mention of the total estimated annual other costs burden: $3,396. This figure is intended to encapsulate the financial impact associated with the information collection activities required by the initiative. However, the document does not offer a detailed breakdown or specific uses for these funds. This lack of transparency and specificity may contribute to some of the issues identified with the notice, such as the absence of detailed information on how the estimated costs were calculated.
Relation to Identified Issues
The financial reference to the $3,396 costs burden ties directly to one of the issues noted: the absence of a detailed breakdown of these costs. While the document provides an overall figure, it does not delve into specifics regarding how this amount was determined or the various components that make up these costs. For instance, stakeholders might benefit from knowing how much is allocated to administrative procedures, compliance checks, or other operational facets linked to the roof control plans.
Understanding how these funds are allocated could also address concerns about the “accuracy of the agency's estimates of the burden and cost of the collection of information.” If the document elaborated on how these estimates were derived, including the methodology and assumptions employed, it might enhance the perceived transparency and accuracy of the financial aspect of the information collection request.
Moreover, the vague mention of “practical utility” could be illustrated with financial implications. For instance, explaining how the costs lead to enhanced safety measures or reduced incidents in mines might provide clearer insight into the practical benefits that justify the financial expenditure.
Lastly, by integrating more detailed financial insights into the document, stakeholders could be better positioned to offer informed feedback, which is a central objective of the comment request notice. Without these details, the opportunity for meaningful public participation and scrutiny is potentially diminished, underscoring the necessity for greater transparency in how financial data is presented in such documents.
Issues
• The document does not specify which parameters or criteria MSHA uses to evaluate the adequacy of roof control plans, which could lead to ambiguity in understanding the requirements.
• The notice does not provide detailed information on how the estimated burden and costs were calculated, which might affect the perceived accuracy and transparency of the ICR process.
• The phrase 'practical utility' is somewhat vague and might benefit from a more precise definition or examples of how the information collection serves a practical purpose.
• The document refers to a previous Federal Register notice for substantive information, which could require readers to look elsewhere for crucial details, impacting clarity and self-sufficiency of the notice.
• The document lists the 'Annual Burden Hours' and 'Total Estimated Annual Other Costs Burden' without breaking down these numbers into components, which could aid in better understanding and identifying potential inefficiencies.