Overview
Title
Agency Information Collection Activities; Submission for OMB Review; Comment Request; Records of Preshift and Onshift Inspections of Slope and Shaft Areas of Slope and Shaft Areas of Slope and Shaft Sinking Operations at Coal Mines
Agencies
ELI5 AI
The Department of Labor is asking people to share their thoughts on how we track safety checks at coal mines to keep them safe from things like dangerous gas and low oxygen. They want to make sure these safety checks are done right and the rules for keeping track of them are clear.
Summary AI
The Department of Labor is asking for public comments on a new information collection request by the Mine Safety and Health Administration. This request is about keeping records of safety inspections at coal mines, specifically in slope and shaft areas, to check for hazards like methane gas or lack of oxygen. The public can submit comments on this until June 4, 2025. The aim is to make sure these inspections are conducted properly and that the information is gathered efficiently.
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.
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Sources
AnalysisAI
Summary of the Document
The document is a notice from the Department of Labor, specifically the Mine Safety and Health Administration (MSHA), seeking public comments on a proposed information collection request (ICR). This request focuses on the collection of records from safety inspections conducted at coal mines, particularly in areas where mining slopes and shafts occur. These inspections are essential for identifying hazardous conditions such as methane gas presence or insufficient oxygen levels. The public has until June 4, 2025, to submit their comments.
Significant Issues and Concerns
This document contains several complex legal and regulatory references that could be difficult for the general public to understand. For instance, it mentions the Paperwork Reduction Act (PRA) and specific sections from the Code of Federal Regulations, which may not be familiar to all readers. The document also omits detailed explanation on how these inspection records contribute to improving safety outcomes in practical terms. Moreover, the methods and assumptions used to estimate the burden and cost of collecting this information are not disclosed, raising questions about the accuracy of these estimates. While the notice assures no penalties for failing to comply with collections lacking a valid OMB Control Number, this still leaves readers with little understanding of the real implications of non-compliance.
Impact on the Public Broadly
Broadly speaking, the collection and submission of comments serve as an opportunity for the public to engage in the governance process, ensuring that safety measures at coal mines are both efficient and effective. However, the technical nature of the notice might limit meaningful participation from individuals who lack a strong regulatory background. Additionally, as the document does not provide clear details about the actual benefits of the proposed data collection, public understanding of its importance might be limited.
Impact on Specific Stakeholders
For coal mine operators and other stakeholders within the private sector, this document presents both an obligation and an opportunity. On the positive side, by adhering to these inspections and documentation processes, mine operators can contribute to maintaining a safer work environment, potentially reducing the risk of accidents and health hazards. However, the requirement could also impose a significant administrative burden. The document reports an expected 8,250 burden hours annually, which implies substantial time and resources will need to be dedicated to compliance.
The notice indicates a zero-dollar estimate for additional costs, which can raise skepticism among stakeholders who might anticipate some expenses related to record keeping, such as staffing or electronic data management systems. Without clear explanations on how this zero-cost assessment was made, there could be cause for concern among mine operators and their financial planners.
Overall, while this regulatory notice underscores a critical part of coal mining safety, its impact will vary significantly depending on whether the various stakeholders feel adequately informed and equipped to address the requirements it sets forth.
Financial Assessment
The document in question makes a singular financial reference, stating that there is a Total Estimated Annual Other Costs Burden of $0. This financial claim suggests that the proposed information collection activities, related to coal mine safety inspections, do not incur any additional costs beyond what has already been accounted for in their regular operations. However, this raises several points of interest and potential concern.
One issue tied to this financial reference is the lack of explanation or detail regarding why there are no additional costs associated with the information collection process. For instance, readers might reasonably expect that activities such as conducting, recording, and reporting inspections would entail some financial expenditure, whether in terms of labor, materials, or time. The notion of a zero-cost burden may appear overly simplistic or possibly misleading without further clarification. The absence of additional information on cost assumptions or calculations could lead to skepticism about the feasibility or validity of the stated financial burden, especially among those who bear these responsibilities.
Moreover, the complexity of legal and regulatory language within the document could obscure understanding or scrutiny of financial claims. For individuals less familiar with regulatory frameworks or paperwork procedures, the assertion of a zero-cost burden might pass without sufficient questioning or consideration of its implications. This is particularly pertinent since no detailed methodology or assumptions have been provided to support this zero-cost assertion, potentially undermining the transparency and comprehensibility of the document's financial assessment.
Furthermore, understanding how the financial aspects tie into safety outcomes could provide better insights into the practical utility of the information being collected. The document notably lacks specific information on how inspections, and their associated records, translate into safety results or cost-saving measures, if any. Addressing these elements could have enhanced both the document's clarity and the reader’s confidence in its claims.
In conclusion, while the document asserts a Total Estimated Annual Other Costs Burden of $0, the absence of accompanying explanations or justifications regarding this financial claim could limit the reader's ability to critically assess the financial implications of the proposed information collection activities. More detailed information would be beneficial to understand whether this zero-cost claim holds true under practical scrutiny.
Issues
• The document contains complex language that may not be easily understood by the general public, especially in sections discussing legal and regulatory aspects.
• The notice does not provide specific information on how the records of inspections improve safety or specific outcomes achieved, making it difficult to assess the practical utility of the information collection.
• The document lacks details on the methodology and assumptions used to estimate the burden and cost of information collection, which could impact the accuracy of these estimates.
• There is no information on how non-compliance with the ICR requirements affects stakeholders, beyond simply stating they cannot be penalized without a valid OMB Control Number.
• The text fails to explain why there are no estimated additional costs involved in the information collection, which might be of concern to those who question the zero-cost claim.
• The document assumes familiarity with the Federal Register and other federal regulatory references, which might not be accessible knowledge to all intended readers.