Overview
Title
Proposed Agency Information Collection Activities; Comment Request
Agencies
ELI5 AI
The Federal Railroad Administration is asking people to share their thoughts on plans to check if train workers are using alcohol or drugs, to keep everyone safe. They want to make sure the way they collect this information is necessary, correct, and not too hard to do.
Summary AI
The Federal Railroad Administration (FRA) is asking for public comments on an information collection request about the control of alcohol and drug use in railroad operations before it submits the request for approval. This collection helps ensure railroad safety by testing employees for alcohol and drugs. The FRA aims to gather feedback on the necessity, accuracy, and efficiency of the information collected. The public has until May 12, 2025, to submit comments related to this on the website www.regulations.gov under Docket No. FRA-2025-0012.
Abstract
Under the Paperwork Reduction Act of 1995 (PRA) and its implementing regulations, FRA seeks approval of the Information Collection Request (ICR) summarized below. Before submitting this ICR to the Office of Management and Budget (OMB) for approval, FRA is soliciting public comment on specific aspects of the activities identified in the ICR.
Keywords AI
Sources
AnalysisAI
Overview
The document in question is a notice from the Federal Railroad Administration (FRA), a part of the U.S. Department of Transportation. The FRA is seeking public feedback on an Information Collection Request (ICR) regarding the control of alcohol and drug use in railroad operations, as mandated by the Paperwork Reduction Act of 1995. This is a routine process that aims to ensure that information collections by federal agencies are necessary, have practical utility, and comply with regulations. Public comments are invited until May 12, 2025.
Significant Issues and Concerns
One of the main issues with the document is its reliance on technical jargon and references to specific legal sections, such as § 219.4 and § 219.23. These terms might not be easily understood by the general public, which could limit informed feedback. The notice's abstract and summary omit specific details on what aspects of the ICR activities require public comment, potentially hindering the gathering of useful input from the public.
Additionally, while the document mentions a reduction in the estimated burden hours from 4,830 to 2,674, it lacks a detailed explanation of how this decrease was achieved and which adjustments were most significant. This lack of transparency might make it difficult for stakeholders to understand the impact of the proposed changes fully.
Impacts on the Public and Stakeholders
Broadly, this document represents an opportunity for the public to influence the FRA's approach to monitoring drug and alcohol use in the railroad industry. By inviting comments, the FRA is seeking to ensure that its information collection practices are efficient and effective. However, the complexity of the document might discourage public participation and limit the breadth of feedback received.
For specific stakeholders, such as railroad companies and their employees, the document outlines potential changes in the regulatory landscape. The reduction in estimated burden hours could signify less paperwork and administrative duties, which might be seen favorably by industry professionals. However, without clear communication of these changes, stakeholders might remain uncertain of their responsibilities or the implications of the revised estimates.
Conclusion
In summary, while the FRA's notice is an essential step in maintaining rigorous safety standards in the railroad industry, the document's technical nature and lack of detailed explanations may present obstacles for public engagement and comprehension. The potential reduction in administrative tasks could benefit key stakeholders, but clear communication of these changes is crucial to ensure a shared understanding across the board. The FRA would benefit from simplifying the language and providing more contextual information to foster greater public participation and feedback.
Financial Assessment
In examining the financial references within the Federal Railroad Administration's (FRA) documentation on their information collection activities, several points deserve attention. This commentary will provide a detailed analysis of these financial elements in a manner accessible to individuals with a high school education.
Summary of Financial References
The document outlines a Total Estimated Burden Hour Dollar Cost Equivalent of $238,317. This figure represents the cost associated with the time spent collecting and processing the information mandated by the FRA's regulations on the control of alcohol and drug use in railroad operations. To derive this cost estimate, the FRA utilized specific wage data, notably referencing the 2023 Surface Transportation Board Full Year Wage A&B data series, particularly for employee group 200, which is classified under Professional Administrative Staff. The hourly wage for this group is $50.93.
Moreover, when calculating the total burden wage rate, the document articulates a computation that includes a 75% markup on the base hourly wage, leading to a total rate of $89.13. This indicates that the FRA considers both direct hourly wages and an assumed premium to account for potential additional overheads or indirect costs.
Relation to Identified Issues
One critical issue is the complexity and technical nature of the document, including the financial data. The financial information utilizes specific wage classifications and calculation methods that may not be immediately clear to the general public. The reference to detailed data sources like the 2023 Surface Transportation Board Full Year Wage A&B data series, combined with a precise calculation of wage costs, could present challenges in understanding for those not familiar with such datasets or economic terms.
Additionally, while the document mentions a reduction in total burden hours from 4,830 to 2,674, the financial implications of this reduction are unclear. The text does not specify how these savings impact the overall budget or whether they result in reduced costs for the taxpayers. Although the reduction in hours suggests efficiency improvements, the connection between these operational changes and the financial figures presented lacks clarity. Such transparency is crucial for public understanding and for evaluating the efficiency of government operations.
Overall, while the FRA has attempted to provide a financial overview of the burden associated with its information collection activities, the complexity of the financial references and calculations could hinder public comprehension and limit informed feedback. Simplifying these financial disclosures and clarifying how changes in operational estimates impact financial outcomes could enhance transparency and public engagement.
Issues
• The abstract and summary do not provide sufficient detail on the specific aspects of the ICR activities that require public comment, which might lead to limited informed feedback from the public.
• The document contains highly technical jargon and references to specific sections and terminologies (e.g., § 219.4, § 219.23) that might not be easily understood by the general public without additional explanation or simplification.
• The estimated burden hours reduction is mentioned without a detailed explanation of how the reduction was calculated and what specific changes led to this decrease, raising questions on transparency and understanding of these calculations.
• The document references specific data such as employee group hourly wage rates and burdens in professional terms (e.g., 'the 2023 Surface Transportation Board Full Year Wage A&B data series') which may not be accessible or easily interpretable for all readers.
• The document doesn't clearly specify which changes in estimates were most significant in causing the total burden hour reduction from 4,830 hours to 2,674 hours, which may raise concerns about clarity and completeness.