WE HAVE CLEARED
THE RECORDKEEPING REQUIREMENTS FOR "SAFETY DEFECT RECORD OF
SELF-PROPELLED EQUIPMENT" THROUGH 9/85 AT WHICH TIME THE AGENCY
EXPECTS TO COMPLETE ITS RULEMAKING. PURSUANT TO OUR REVIEW UNDER
THE PAPERWORK REDUCTION ACT AND 5 CFR 1320, WE HAVE THREE MAJOR
CONCERNS WITH THESE RECORDKEEPING REQUIREMENTS. FIRST, THE NEED AND
PURPOSE OF THE RECORD OF SAFETY DEFECTS IS NOT CLEAR. OTHER
APPROACHE SUCH AS A CERTIFICATION WOULD SEEM TO MEET THE AGENCY'S
NEEDS AND WOUL IMPOSE LESS BURDEN ON THE PUBLIC. SECOND, THE NEED
AND PRACTICAL UTILITY OF THE INSPECTION ON EACH SHIFT IS NOT CLEAR.
THIRD, THE NEED AND PURPOSE OF THE 6-YEAR RETENTION OF THESE
RECORDS HAS NOT BEEN JUSTIFIED. WE PROVIDE THESE COMMENTS FOR
CONSIDERATION DURING THE AGENCY'S RULEMAKING DELIBERATIONS. WE WILL
REVIEW THE AGENCY'S RESPONSE TO THESE CONCERNS WHEN THE
RECORDKEEPING REQUIREMENTS FOR THE FINAL RULE ARE SUBMITTED FOR OMB
REVIEW.
Inventory as of this Action
Requested
Previously Approved
09/30/1985
09/30/1985
09/30/1984
1,377,805
0
1,443,000
2,433,156
0
2,548,334
0
0
0
REQUIRES OPERATOR BEFORE PLACING
SELF-PROPELLED EQUIPMENT INTO OPERATION TO MAKE A VISUAL AND
OPERATIONAL CHECK OF VARIOUS PRIMARY OPERATING SYSTEMS AFFECTING
SAFETY, I.E., BRAKES, LIGHTS, TIRES, STEERING, AND RELATED ITEMS.
ANY SAFETY DEFECTS FOUND ARE REPORTED TO THE RESPONSIBLE SUPERVISOR
WHO IS REQUIRED TO MAKE A RECORD OF THE REPORTED DEFECTS AND
SCHEDULE REPAIRS OF SAME.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.