FR 2025-03200

The document from the Occupational Safety and Health Administration (OSHA) invites public feedback on its proposal to extend the Office of Management and Budget's (OMB) approval for information collection requirements related to the Personal Protective Equipment (PPE) Standard for Shipyard Employment. This request seeks comments on the necessity, accuracy, and burden of these requirements, with the deadline for submissions set for April 29, 2025.

General Overview

OSHA's notice highlights the ongoing paperwork associated with maintaining safety standards in shipyards, specifically regarding PPE. The agency is seeking to continue its current practices of collecting data to ensure safety standards are met and that PPE is adequate for worker protection. Stakeholders are encouraged to provide input on this process, particularly focusing on how the paperwork requirements affect employers and workers in the shipyard industry.

Significant Issues and Concerns

Several issues arise from the document. Firstly, there is a reduction in estimated burden hours from 220 to 217 hours, yet the methodology behind this decrease remains vague. This lack of transparency may concern those interested in understanding how such figures are calculated and adjusted.

Additionally, while OSHA advises against submitting personal information with public comments, there is no detailed explanation of how such data will be handled if it inadvertently becomes part of the public record. This absence of clarity on personal data protection could deter participation or cause concern among potential commenters.

The language surrounding submission processes, especially with rules on copyrighted materials and personal data, can be complex and possibly intimidating for some participants, thereby limiting broad public engagement.

Moreover, the document does not address potential consequences for non-compliance with these information collection needs. This omission can lead to uncertainty or anxiety for businesses obligated to adhere to the requirements.

Finally, the document does not explore specific technological developments that could reduce the burden on employers. This oversight could be viewed as a missed opportunity to streamline processes or reduce costs.

Impact on the Public

Broadly, this document may impact the public by shaping the safety and regulatory environment in which shipyard workers operate. By collecting and assessing comments, OSHA's regulations can better align with the needs and capacities of the industry, ensuring worker safety while promoting efficient practices.

Impact on Specific Stakeholders

For stakeholders directly involved in shipyard employment, such as business owners and employees, this document could have both positive and negative implications. On the positive side, ensuring the continuation and refinement of safety standards boosts worker safety and well-being. However, any extended or unchanged paperwork requirements may present an ongoing administrative burden, especially for smaller businesses with limited resources.

In summary, OSHA's notice seeks to balance the critical aspect of worker safety with the administrative demands placed on employers. While the intent is clear, the execution and review process might benefit from greater transparency and user-friendliness to better support all stakeholders involved.

In the reviewed document, a particular financial reference is the estimated cost (operation and maintenance), which is reported as $0. This figure suggests that there are no direct financial expenditures required for the operation and maintenance associated with the information collection requirements under the Personal Protective Equipment Standard for Shipyard Employment.

Summary of Financial Reference

The document specifies that the estimated cost for operation and maintenance related to the information collection requirement is $0. This suggests that the processes and systems currently in place for collecting the necessary information do not require additional financial resources for upkeep. This could mean that there are no expected expenses for new equipment, software, or additional staffing for managing these requirements.

Financial Reference in Relation to Identified Issues

While the document does provide an estimated total burden in hours, reduced from 220 hours to 217 hours, it does not clearly explain the methodology or the financial implications of this reduction. This lack of transparency may contribute to issues of ambiguity for businesses trying to understand the financial savings or costs associated with compliance. The estimate of $0 for operation and maintenance doesn't address what existing resources are being utilized, nor does it explore potential cost savings through technological advancements, as suggested as one of the document's issues.

This absence of clear financial implications aligns with one of the concerns raised about how OSHA could help minimize burdens on employers by leveraging technological advancements. If new technologies were implemented, there might be an expected initial cost offset by long-term savings, but these aspects are not discussed, leaving potential efficiency opportunities unexplored.

Overall, while there is an indication of no additional financial burden for operation and maintenance, clarity on the methodology for estimating any related costs and the implications of burden-hour reduction could provide a more comprehensive understanding of the financial landscape surrounding these regulatory requirements.