FR 2024-29835

The document titled "Agency Information Collection Activities; Submission for OMB Review; Comment Request; Underground Retorts" outlines a request from the Department of Labor (DOL), specifically under the Mine Safety and Health Administration (MSHA), for public comments regarding the collection of information related to safety practices in oil shale mining. This request is guided by the Paperwork Reduction Act of 1995 (PRA) and aims to gather insights into the appropriate management and safety protocols where underground retorts are used, a processing method for extracting oil shale.

General Summary

This notice formally invites public comments on an information collection initiative that pertains to safety standards involved in operations that might lead to the release of volatile gases like methane in underground mining settings. The submission is pending review and approval by the Office of Management and Budget (OMB). Public comments are being solicited until January 17, 2025, offering businesses, experts, and the general public the opportunity to express their views on the relevance and efficiency of the proposed safety and reporting measures.

Significant Issues or Concerns

A few notable issues permeate the document. Firstly, the description includes legal and regulatory jargon, such as references to "Section 103(h) of the Federal Mine Safety and Health Act of 1977" and "Title 30 CFR 57.22401", which might not be easily understood by individuals without a legal or mining background. This complexity can deter effective public engagement.

Secondly, the document mentions an "Annual Burden Hours" of 160 hours assigned for a single respondent, which sounds substantial given there's only one subjected entity. This raises questions about how these hours were calculated and whether this allocation truly reflects the effort needed for compliance or is unnecessarily extensive.

Another concern is the specification that only one respondent is impacted by this information collection requirement, which lacks clarity regarding its applicability and why this single instance merits such detailed reporting.

Lastly, the technical term "underground retorts" is not explained in the document, making it challenging for readers who are unfamiliar with mining terminologies to fully grasp the safety context.

Impact on the Public Broadly

The document essentially impacts the broader public by potentially influencing how mining operations—particularly those with potential methane hazards—are managed in terms of safety reporting and operational planning. An effective information collection process could lead to safer mining environments, reducing the risk of accidents and ensuring environmental and worker safety. However, the lack of clarity and comprehensibility might limit meaningful public input, thereby impacting the richness of feedback gathered.

Impact on Specific Stakeholders

For stakeholders, particularly those directly involved in mining operations or regulatory compliance, the outcome of this review process could have significant implications. On the positive side, clearer safety and reporting standards can enhance workplace safety and operational transparency. However, if the burden of compliance is perceived as excessive due to the high annual hours required or misunderstood due to vague definitions, it could result in operational and administrative challenges for those expected to comply.

Overall, while the document seeks to shore up safety protocols, thus supporting safer mining practices potentially, ensuring that the engagement process is user-friendly and the requirements are reasonable and clear is vital for achieving a beneficial impact.

The document under review centers on an information collection request (ICR) submitted by the Department of Labor (DOL), specifically the Mine Safety and Health Administration (MSHA), for approval by the Office of Management and Budget (OMB). The focus of the financial analysis here is on the burden and costs associated with this information collection.

Financial Summary

In the context of the document, the only explicit financial reference is to the Total Estimated Annual Other Costs Burden, which is stated as $0. This indicates that aside from the time investment estimated for compliance with this requirement, there are no additional direct fiscal expenditures required by the respondent.

Context and Relation to Issues

The document specifies that the information collection applies to businesses or other for-profits and involves an annual burden of 160 hours for the single respondent. Based on the financial reference, it's clear that this burden is perceived more in terms of time rather than monetary cost. As a result, the stated $0 for additional costs suggests that no external expenses, such as fees or purchases, are anticipated for the respondent to comply.

However, the document issues highlight a gap in clarity around the calculation of this annual burden of 160 hours. This time commitment could represent a significant indirect financial cost, typically reflecting the labor costs associated with gathering and reporting required information. Without explicit financial recompense or cost-sharing mechanisms, the time burden implicitly converts into a financial one, especially when considering opportunity costs for the respondent.

Moreover, there's no given explanation for having only one respondent, which raises questions about the scope and scale of this regulatory requirement and whether this reflects a specific industry segment or a particular operational context that might not be widely known. The absence of multiple respondents could imply limited applicability or relevance, further indicating why no additional costs have been projected.

Conclusion

In summary, while the document points to a $0 cost beyond the labor involved in compliance, this absence of explicit financial burden does not necessarily mitigate the potential indirect financial impacts inherent in dedicating 160 hours annually to compliance efforts. This allocation of labor resources, particularly for the lone respondent, underscores a noteworthy economic consideration that merits attention for its potential implications on business operations. The financial implications extend beyond direct costs, encompassing the economic value of the time and resources devoted to fulfilling this regulatory obligation.