1219-0141 Supporting Statement 2022

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Emergency Mine Evacuation

OMB: 1219-0141

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Emergency Mine Evacuation

OMB Control Number: 1219-0141

OMB Expiration Date: 1/31/2023


Supporting Statement for

Paperwork Reduction Act Submission


Title: Emergency Mine Evacuation


Form(s): MSHA Form 2000-222, Self Contained Self Rescuer (SCSR) Inventory and Report


Authorities: 30 CFR Section 48.3(p) -Training plans; time of submission; where filed; information required; time for approval; method for disapproval; commencement of training; approval of instructors.


30 CFR 75.1502(a) - Mine emergency evacuation and firefighting program of instruction.


30 CFR 75.1504 - Mine emergency evacuation training and drills.


30 CFR 75.1505- Escapeway maps.


30 CFR 75.1714-3(e) - Self-rescue devices; inspection, testing, maintenance, repair, and recordkeeping.


30 CFR 75.1714-4(d)(3) - Additional self-contained self-rescuers (SCSRs).


30 CFR 75.1714-5 - Map locations of self-contained self-rescuers (SCSR).


30 CFR 75.1714-8 - Reporting SCSR inventory and malfunctions; retention of SCSRs.


General Instructions


A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses or employ statistical methods” is checked "Yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.




Specific Instructions


A. Justification


1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


Section 103(h) of the Federal Mine Safety and Health Act of 1977 (Mine Act), 30 U.S.C. 813(h), authorizes the Mine Safety and Health Administration (MSHA) to collect information necessary to carry out its duty in protecting the safety and health of miners. Further, section 101(a) of the Mine Act, 30 U.S.C. 811, authorizes the Secretary of Labor (Secretary) to develop, promulgate, and revise as may be appropriate, improved mandatory health or safety standards for the protection of life and prevention of injuries in coal and metal and non-metal mines.


MSHA’s health and safety standards requiring immediate accident notification are applicable to all mines. In addition, the health and safety standards require miner training for mine emergencies including firefighting and evacuation drills; storing, testing, tracking, and using self-contained self-rescuers (SCSR); and installing and maintaining Escapeways in underground coal mines.


2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.


Section 48.3(p) requires underground coal operators to modify their training plans under 30 CFR part 48 whenever they modify their program of instruction under 30 CFR 75.1502. This ensures that newly-hired miners receive the same level of training as required for experienced miners. Operators use part 48 training plans to train each miner about the safety and health aspects of the mining environment and the tasks associated with the miner's job. MSHA reviews the plans to ensure that all miners are receiving training necessary to perform their jobs in a safe manner.


Section 75.1502(a) requires underground coal operators to submit a Mine Emergency Evacuation and Firefighting Program of Instruction to the MSHA District Manager for approval. Upon approval by the District Manager, the operator uses the approved program of instruction to implement programs for training miners in responding appropriately to mine emergencies. MSHA reviews the plans to ensure that the operator's program will provide the required training and drills to all miners.


75.1504(d) requires the operator to certify the training and drill for each miner at the completion of each quarterly drill, annual expectations training, or other training, and that a copy be provided to the miner upon request. These certifications are used by MSHA, operators, and miners as evidence that the required training has been completed.


Sections 75.1505 and 75.1714-5 include requirements that Escapeway maps show the SCSR storage locations. Accurate and up-to-date maps are essential to the engineering plans and safe operation of mines and to the health and safety of the miners. MSHA and other emergency evacuation personnel will use the notations on the maps should a rescue or recovery operation be necessary. Miners use the Escapeway maps in training and during mine evacuations. Escapeway maps are required to be posted or readily accessible for all miners in each working section, areas where mechanized mining equipment is being installed or removed, at surface locations where miners congregate, and in each refuge alternative.


Section 75.1714-3(e) requires that persons that test SCSRs certify that the tests were completed and record all corrective actions. MSHA inspectors use these records to determine compliance with the standards.


Section 75.1714-8 includes requirements for compiling, maintaining, and reporting an inventory of all SCSRs at the mine, and for reporting defects, performance problems, or malfunctions with SCSRs. This will ensure that MSHA can investigate SCSR problems, and, if necessary, notify other users of these problems before accidents occur and require manufacturers to address potential problems with these critical devices.


3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.


For part 48 training plans, MSHA maintains an internet-accessible system (MSHA Training Plan Advisor) for operators to prepare and submit training plans. This is an optional method for the mining industry to prepare and file required training plans. The design of this system increases the likelihood that the plan will be complete, with the potential to decrease the paperwork burden. It is accessed through MSHA's web page at https://www.msha.gov/support-resources/forms-online-filing/2015/04/15/self-contained-self-rescuer-scsr-inventory-and.


Although the Agency allows the operator(s) to submit the program of instruction and the Training Plan Advisor electronically, they are generally mailed to MSHA.


MSHA has developed an online database system for reporting and maintaining the SCSR inventory required by section 75.1714-8. MSHA also provides a paper form (MSHA Form 2000-222, “SCSR Inventory and Report”) for mine operators who prefer to submit this information through the mail. Over 90 percent of the SCSR Inventory and Report forms are submitted electronically at https://www.msha.gov/support-resources/forms-online-filing/2015/04/15/self-contained-self-rescuer-scsr-inventory-and.


4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.


The information collection concerning training plans and programs of instruction, notification of accidents, certification of training and drills, inspection of SCSRs, and reporting SCSR inventory and SCSR problems required by these emergency mine evacuation regulations are unique to each mine and not duplicative of any existing MSHA requirements.


5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.


To minimize the administrative burden of these emergency mine evacuation regulations, MSHA has provided a training plan addendum for the SCSR donning and transferring procedures, templates for various mine emergency scenarios, and a template checklist for tracking miners' completion of components of mine emergency evacuation training and drills. MSHA provides an online database system for reporting and maintaining the SCSR inventory required by section 75.1714-8.


6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.


Submission of training plans and programs of instruction and certification that training was done provides MSHA, operators, and miners with confidence that training is appropriate and was conducted as necessary, particularly when MSHA is not able to be at the mine. Without adequate training, miners may sustain serious or fatal injuries because they lack the knowledge to properly and safely perform various tasks and activities or to evacuate a mine.


If inspections and monitoring of SCSRs did not occur, this could allow unsafe conditions to go undetected and the SCSRs might be unusable when needed. This would endanger miners' safety.


If operators were not required to submit an SCSR inventory or to notify MSHA when they encounter an SCSR defect, performance problem, or malfunction, MSHA would not have the information needed to notify other mines that may also use the affected SCSRs. This could endanger miners because operators would rely on deficient SCSRs.


7. Explain any special circumstances that would cause an information collection to be conducted in a manner:


requiring respondents to report information to the agency more often than quarterly;

requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;


requiring respondents to submit more than an original and two copies of any document;


requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;


in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;


requiring the use of a statistical data classification that has not been reviewed and approved by OMB;


that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or


requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.


No provisions require more than quarterly reporting. This collection of information is consistent with the guidelines in 5 CFR 1320.5.


8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register of the agency's notice, required by 5 CFR Section 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.


Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.


Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years- even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.


In accordance with 5 CFR 1320.8(d), MSHA will publish the proposed information collection requirements in the Federal Register, notifying the public that these information collection requirements are being reviewed in accordance with the Paperwork Reduction Act of 1995, and giving interested parties 60 days to submit comments. MSHA published a 60-day Federal Register notice on June 17, 2022 (87 FR 36538). MSHA received no public comments.


9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.


MSHA does not provide payments or gifts to the respondents identified in this collection.


10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.


There is no assurance of confidentiality provided to respondents.


11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.


There are no questions of a sensitive nature.



12. Provide estimates of the hour burden of the collection of information. The statement should:


Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.


If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.


All information related to quantities and inspection rates are estimated by MSHA’s Headquarters Enforcement Division based on field experience with different types of mining operations, sizes of mines, and the frequency of inspections dictated by statute. Mine operators provide MSHA Headquarters Enforcement Division the number of mines and employment, and from this information MSHA tracks the number of active and inactive mines and mine types throughout the United States.


Based on 2021 MSHA data, there are approximately 155 active underground coal mines employing an average of about 20,077 miners and an average of 430 active mechanized mining units (MMU). The number of active mines used here is a subset of all mines.


Section 48.3(p) requires each underground coal mine to submit a training plan to address SCSR donning and transfer procedures requiring insertion of the mouthpiece. MSHA used data from the May 2021 Occupational Employment and Wage Statistics (OEWS) published by the Bureau of Labor Statistics (BLS) for hourly wage rates1 and adjusted the rates for benefits2 and wage inflation3. MSHA estimates that to revise the training plan it will take a Safety Director, who earns approximately $91.88 4 per hour, approximately 45 minutes. In addition, a clerical employee, who earns approximately $32.76 5 per hour, is estimated to take 6 minutes to copy and send the revised material.


MSHA estimates that, on average, a training plan revision will be needed approximately once every two years at each underground coal mine. Since 155 active underground coal mines training plan revisions are completed once every two years, and with MSHA standardizing calculation to annual parameters, MSHA divided the 155 mines by two to get the average number of underground mines as 78 mines annually. This frequency includes new mines. Table 1 shows the costs of complying.


Table 1. Estimated Burden Hours and Burden Hours Cost for Section 48.3(p)


Number of Mines

Number of Training Plans Revisions per Mine

Number of Responses

Time per Training Plan (minutes)

Burden Hours

Wage Rate

Burden Hours Costs

Revisions

78

1

78

45

58.5

$91.88

$5,374.98

Filing of Revisions

78

1

78

6

7.8

$32.76

$255.53

Total

 

 

 

 

66

 

$5,631


a Burden Hours Costs = Burden Hours x Wages Rate


Section 75.1502(a) requires each underground coal operator to submit a Mine Emergency Evacuation and Firefighting Program of Instruction to the District Manager of the Coal Mine Safety and Health district in which the mine is located. MSHA estimates that revisions and new submissions of this program of instruction will take a Safety Director, who earns approximately $91.88 per hour, approximately 2 hours and 30 minutes to complete. MSHA also estimates that it takes 6 minutes for a clerical employee, who earns approximately $32.76 per hour, to photocopy and send a program of instruction to the appropriate MSHA District Manager. There are approximately 155 active underground coal mines and MSHA estimates that, on average, a program of instruction revision or new submission will be needed approximately once every two years at each underground coal mine. MSHA divided the 155 mines by two to get the average number of underground mines as 78 mines annually. This frequency includes new mines.


Table 2. Estimated Burden Hours and Burden Hours Costs for Section 75.1502(a)


Number of Mines

Revisions of Mine Evacuation and Fire Fighting Instructions

Number of Responses

Time per Response (minutes)

Burden Hours

Wage Rate

Burden Hours costs

Revisions

78

1

78

150

195

$91.88

$17,916.60

Filing of Revisions

78

1

78

6

7.8

$32.76

$255.53

Total

 

 

 

203

 

$18,172



Section 75.1504(a) requires that a mine emergency evacuation training and drill be conducted once each quarter (4 times per year) for each underground coal miner. Section 75.1504(d), Mine Emergency Evacuation Training and Drills, requires the operator to certify when mine emergency evacuation training or drills are completed. This certification shall include the names of miners participating in the training or drills, the content of the drill, the escapeway traveled, and the scenario used. As of 2021, there were about 20,077 underground coal miners. Each of these underground coal miners would require four certifications per year for the mine emergency evacuation training and drills. MSHA estimates that a Safety Director, who earns approximately $91.88 per hour, takes approximately 9 seconds per certification, by signature and date, for each miner that received the required training.


Under section 75.1504(a)(l), MSHA also estimates that such certification will occur 4 times per year for each foreman traveling Escapeway. In 2021, MSHA records show that there are approximately 430 active MMUs in the nation's underground coal mines. Each MMU requires one foreman for each shift that it is operated. MSHA estimates that each MMU will operate an average of three shifts. MSHA also estimates that there will be an average of one additional foreman for outby or other work associated with each MMU for a total of four foremen per MMU. MSHA estimates that a Safety Director, who earns approximately $91.88 per hour, takes approximately 9 seconds per certification, by signature and date, for each foreman traveling Escapeway that received the required training.


Section 75.1504(c) requires that each miner participate in expectations training once a year. As of 2021, there were about 20,077 underground coal miners. This annual expectations training will result in one certification per underground coal miner per year. MSHA estimates that a Safety Director, who earns approximately $91.88 per hour, takes approximately 9 seconds per certification, by signature and date, for each miner that received the required training.





Table 3. Estimated Burden Hours and Burden Hours Costs for Section 75.1504(d)


Miners Needing Certification

MMUs

Certifications per Year per Miner or Foreman

Responses

Seconds

per

Certification

Burden

Hours

Wage

Rate

Burden

Hours

Costs

Mine emergency evacuation

training and drill Certification

20,077

 

4

80,308

9

200.77

$91.88

$18,446.75

Certification of Foremen

traveling escapeways

4

430

4

6,880

9

17.20

$91.88

$1,580.34

Certification of annual

expectations

20,077

 

1

20,077

9

50.19

$91.88

$4,611.46

Total

 

 

 

107,265

 

268

 

$24,639






Section 75.1504(d)(4) requires operators to provide a copy of the miner's training certification to the miner upon request. MSHA estimates that a clerical employee, earning $32.76 per hour, takes approximately 1.5 minutes to provide the carbonless miners’ copy of the certificate for each request. Mine emergency evacuation training is mine specific and is not transferable to another mine; therefore, there is little incentive for miners to request copies. Based on the last three years of data, MSHA estimates that approximately 5 percent or 1,004 miners (20,077 x 5%) will request copies of their quarterly emergency evacuation training certificates in any given year.


Table 4. Estimated Burden Hours and Burden Hours Costs for Section 75.1504(d)(4)


Total Number Miners Making Request

Certificates

per

year

Responses

Minutes

per

Response

Burden

Hours

Wage

Rate

Burden

Hours

Cost

Copy of Miner

Training Certification

1,004

4

4,016

1.5

100.40

$32.76

$3,289


Section 75.1505 requires operators to provide an accurate, up-to-date Escapeway map at each working section, areas where mechanized mining equipment is being installed or removed, at surface locations where miners congregate, and in each refuge alternative. MSHA estimates that there will be one master Escapeway map per working section MMU that requires updating and copies of this Escapeway map will be used to satisfy the requirements at other locations. These other locations include the one surface location where miners congregate (one location per mine) and each refuge alternative.


MSHA's records show that there are 430 active MMUs, 155 mines, and 681 refuge alternatives for a total of 1,266 locations where Escapeway maps are required. MSHA estimates that Escapeway maps will be updated, on average, on a quarterly basis. MSHA expects that any changes in the SCSR storage locations specified in section 75.1714-5 will be plotted on the Escapeway maps during this quarterly update. MSHA estimates that a supervisor, earning $91.88 per hour, takes approximately 15 minutes to update an Escapeway map. MSHA estimates that a clerical employee, earning $32.76 per hour, takes approximately 6 minutes to make each copy of the Escapeway maps.




Table 5. Estimated Burden Hours and Burden Hours Costs for Section 75.1505


 

Locations

Number of Responses per Location

Number of Reponses

Minutes per Response

Burden Hours

Wage Rate

Burden Hour Costs

Supervisor Map Updates

 

 

 

 

 

 

 

Mines

155

4

620

15

155

$91.88

$14,241.40

MMUs

430

4

1,720

15

430

$91.88

$39,508.40

Refuge Alternatives

681

4

2,724

15

681

$91.88

$62,570.28

Supervisor Total

1,266

 

5,064

 

1,266.00

 

$116,320

Clerical Employee Map Copying

 

 

 

 

 

 

 

Mines

155

4

620

6

62

$32.76

$2,031.12

MMUs

430

4

1,720

6

172

$32.76

$5,634.72

Refuge Alternatives

681

4

2,724

6

272

$32.76

$8,923.82

Clerical Employee Total

1,266

 

5,064


506.40


$16,590

Total

2,535

 

10,128

 

1,772

 

$132,910





Under section 75.1714-3(e), all SCSRs approved by MSHA and NIOSH must be tested in accordance with instructions approved by MSHA and NIOSH. All approved SCSRs currently require quarterly inspection and testing. The information reported in MSHA Form 2000-222 is also a result of this testing and inspection time. Section 75.1714-3(e) requires the certification of the test results by signature and date of the person completing the tests. The inspections are required four times per year and MSHA estimates that a Safety Director, who earns approximately $91.88 per hour, takes approximately 30 minutes to complete the inspection and certify by signature and date. MSHA currently shows 185,127 SCSRs in service in the SCSR inventory database. Table 6 presents the burden this regulation imposes on industry.


Table 6. Estimated Burden Hours and Burden Hours Costs for Section 75.1714-3(e)


Number

of SCSRs

Inspections

per Year

Responses

Minutes per

Response

Burden

Hours

Wage

Rate

Burden Hours

Cost

SCSRs

185,127

4

740,508

30

370,254

$91.88

$34,018,938


Section 75.1714-5 requires the mine operator to indicate the location of all stored SCSRs on the section 75.1200 mine maps and the section 75.1505 Escapeway maps. SCSR storage locations in the Escapeway should rarely change and new storage locations will be added only as the Escapeway is developed. MSHA estimates that plotting these new locations will be done as part of the quarterly update of the Escapeway maps (see section 75.1505 and section 75.1200 Mine map; OMB No. 1219-0073). The burden estimates for these maps include plotting SCSR storage locations. Therefore, no additional reporting burden is estimated for this section.


MSHA Form 2000-222

Under section 75.1714-8(a), operators must provide MSHA an inventory of all SCSRs at each mine. For each mine, the inventory must include mine name, MSHA mine ID number, and mine location. For each SCSR in each mine, the report must include manufacturer, model type, date of manufacture, and serial number. The inventory must be sent to MSHA. MSHA has developed a web-based inventory system that the mine operator may use to comply with this requirement. MSHA also accepts spreadsheet-based inventories and paper forms (MSHA Form 2000-222, “SCSR Inventory and Report”).


SCSRs have an approved service life of 10 to 15 years that varies with the manufacturer of the SCSR. The majority of SCSRs will require refurbishment once or twice during the life of the SCSR. A SCSR refurbished twice would involve a minimum of six record changes. However, some SCSRs will be moved from one mine to another, particularly for smaller operations that have a mine life of less than the service life of the SCSRs. MSHA currently has 185,127 SCSRs in service in the SCSR inventory database. There are about 9,000 e-doc submissions submitted per year, on average. MSHA estimates that on average 5,255 paper record change requests submitted annually. MSHA estimates that a clerical employee, who earns approximately $32.76 per hour, is estimated to take approximately 1 minute to submit an inventory change record for a single SCSR.


MSHA also requires the reporting of any defect, performance problem or malfunction with the use of an SCSR. Historically, MSHA has received a few reports of SCSR problems. MSHA estimates that, on average, approximately 10 SCSR problems will be reported per year. MSHA estimates that a Safety Director, who earns approximately $91.88 per hour, takes approximately 1 hour to prepare and submit an SCSR problem report.


Table 7. Estimated Burden Hours and Burden Hours Costs for Section 75.1714-8(a)


Reports or

Records

Minutes per

Report or

Record

Burden

Hours

Wage

Rate

Hour

Burden

Cost

MSHA Form 2000-222, “SCSR Inventory and Report,” Change Records Submitted

5,255

1

87.58

$32.76

$2,869.12

MSHA Form 2000-222, “SCSR Inventory and Report,” SCSR Problem Reports

10

60

10.00

$91.88

$918.80

Total

5,265

 

98

 

$3,788



A summary of the responses, burden hours and total costs for reporting information under the emergency evacuation rule (Tables 1 through Table 7) is:


Table 8. Summary of Expected Costs of Complying with Emergency Mine Evacuation Regulation

Table

Standard

Respondents

Responses

Burden Hours

Burden Hours Cost

1

48.3(p)

78

78

66

$5,631

2

75.1502(a)

78

78

203

$18,172

3

75.1504(d)

20,077

107,265

268

$24,639

4

75.1504(d)(4)

20,077

4,016

100.40

$3,289

5

75.1505

2,532

10,128

1,772

$132,910

6

75.1714-3(e)

185,127

740,508

370,254.00

$34,018,938

7

75.1714-8/MSHA

Form 2000-222

5,265

5,265

98

$3,788


Totals

155

867,338

372,761

$34,207,366


13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).


The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the timeframe over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.


If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.


Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices.


Maintenance and operations burden costs include copying and mailing plans to the District Manager. MSHA estimates that copying costs are approximately $0.15 per page and mailing costs are approximately $1.50 per document. These cost estimates are:


Table 9. Expected Cost for Copying and Mailing Emergency Mine Evacuation Plans

Standard

Documents

Pages

Copy

Cost per

Page

Copying

Cost

Copy

Cost per

Mail

Mailing

Cost

Total

Cost

Section 48.3(p)

78

10

$0.15

$117.00

$1.50

$117.00

$234.00

Section 75.1502

78

10

$0.15

$117.00

$1.50

$117.00

$234.00

Section 75.1505 (a)

10,128

 

$6.00

$60,768.00

 

 

$60,768.00

Section 75.1714-8 (b)

527

1,062

$0.15

$159.30

$1.50

$790.50

$949.80

Inventory Changes(b)

526

1,052(c)

$0.15

$157.80

$1.50

$789.00

$946.80

Problem Reports(b)

1

10(c)

$0.15

$1.50

$1.50

$1.50

$3.00

Totals

10,811

 

 

$61,161

 

$1,025

$62,186


  1. MSHA estimates that a copy of an Escapeway map costs approximately $6.00.


  1. MSHA estimates that approximately 10 percent of mine operators will submit paper inventory reports rather than using the online database forms.


  1. SCSR inventory changes are estimated to be two pages in length and problem reports are 10 pages.


14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.


Section 75.1502 requires each underground coal operator to submit a Mine Emergency Evacuation and Firefighting Program of Instruction to the District Manager of the Coal Mine Safety and Health district in which the mine is located. MSHA estimates that there are 56 plans submitted annually.


MSHA estimates that revisions and new submissions of this program of instruction will take a GS-12 mining specialist (1822), who earns $65.006 per hour, approximately 1 hour to review and draft an approval letter. MSHA also estimates that it takes approximately 30 minutes for a GS-7 clerical employee (1802), who earns $38.137 per hour to photocopy, send and file, an approval letter to the mine operator.


Federal

Employee

Unloaded

Hourly

Wage

Benefits

Factor

Loaded

Hourly

Wage

Plans or

Letters

Minutes per

Plan Review

Minutes per

Letter

Burden

Cost

Mining Specialist

$45.14

1.440

$65.00

56

60


$3,640.00

Clerical

$26.48

1.440

$38.13

56


30

$1,067.64







Total =

$4,708



15. Explain the reasons for any program changes or adjustments reported on the burden worksheet.


Respondents decreased because the number of respondents (underground coal mines) have decreased. The number of miners also decreased from 29,580 miners to 20,077 miners. Responses are down because they are based on the decreased number of SCSR transactions and respondents are down because there are fewer operating mines and SCSR transactions. The number of SCSR changes were caused by several reasons. Due to mine closings, SCSRs must be taken out of service once the mine has closed. In addition, existing mines are replacing SCSRs that have run past their service lives and have added new SCSRs. New mines are adding their SCSRs to the inventory.


Burden hours decreased because the decrease in respondents lead to a decrease in all other responses and a reduction in the number mine maps. The cost to respondents increased due to a different assumption in the number of map updates (quarterly, instead of annually from previous calculation).


Respondents: Active underground coal mines decreased from 208 to 155

Responses: Decreased from 1,035,909 to 867,338

Burden Hours: Decreased from 431,506 to 372,761

Costs: Increased from $52,298 to $62,186 because of a different assumption



16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.


MSHA does not intend to publish the results of this information collection. However, MSHA will post information about SCSRs on its webpage to assure that operators and miners are informed about SCSR defects, performance problems, and malfunctions.


17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


MSHA will display the expiration date on any instruments.


18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."


There are no certification exceptions identified with this information collection.


B. Collection of Information Employing Statistical Methods


The collection of this information does not employ statistical methods.

1 Options for obtaining OEWS data are available at item “E3. How to get OEWS data. What are the different ways to obtain OEWS estimates from this website?” at https://www.bls.gov/oes/oes_ques.htm.


2 The benefit multiplier comes from BLS Employer Costs for Employee Compensation accessed by menu at http://data.bls.gov/cgi-bin/srgate or directly with http://download.bls.gov/pub/time.series/cm/cm.data.0.Current. Insert the data series CMU2030000405000D and CMU2030000405000P, Private Industry Total benefits for Construction, extraction, farming, fishing, and forestry occupations, which is divided by 100 to convert to a decimal value. MSHA used the latest 4-quarter moving average 2021Qtr1 - 2021Qtr4 to determine that 32.8 percent of total loaded wages are benefits. MSHA computes the benefit multiplier with a number of detailed calculations, but it may be approximated with the formula and values 1 + (benefit percentage/(1-benefit percentage)) = 1+(.328/(1-.328)) =1.487.


3 Wage inflation is the change in Series ID: CIS2020000405000I; Seasonally adjusted; Series Title: Wages and salaries for Private industry workers in Construction, extraction, farming, fishing, and forestry occupations, Index.  (https://data.bls.gov/cgi-bin/srgate ; 2021Qtr4/2021Q2=147.3/144.3=1.021).


4 For the Safety Director hourly wage rate, MSHA used the employment weighted average of the 90th percentile hourly wage for 3 safety engineering, specialist, and technical occupations from the BLS May 2021 OEWS data, using Standard Occupational Classification (SOC) major group code 17 and 19 in North American Industry Classification System (NAICS) occupational code 212100, Coal Mining. The weighted average 90th percentile rate was adjusted for benefits and inflation to obtain a fully loaded rate of $91.88 ($60.52 Unloaded Wage x 1.487 Benefits Adjustment x 1.021 Inflation Adjustment). All subsequent uses of $91.88 represent Safety Director hourly wage rate. For all wage rates, MSHA uses the relevant precision throughout the calculation to avoid compound rounding errors and rounds at the final rate value. Displayed intermediate calculation values are presented to explain the calculation and are representative but the final rate value reflects the correct rounding and final estimate.


5 For the Clerical hourly wage rate, MSHA used the employment weighted average of mean hourly wage for 3 clerical occupations from the BLS May 2021 OEWS data, using SOC major group code 43 in NAICS occupational codes in NAICS occupational code 212100, Coal Mining. The weighted average rate was adjusted for benefits and inflation to obtain a fully loaded rate of $32.76 ($21.58 x 1.487 x 1.021). All subsequent uses of $32.76 represent Clerical hourly wage rate.

6 The wage rates shown here come from the Office of Personnel Management (OPM) September 2021 FedScope data cube, http://www.fedscope.opm.gov/. Average salary was obtained for the appropriate grade and occupation for DOL-MSHA employees. In order to include the cost of benefits, this annual average salary was multiplied by a federal benefits scaler of 1.440 computed from MSHA’s 2023 budget submission. The final hourly wage rate was derived by dividing the adjusted annual average salary by 2,087 hours (hourly rate = FedScope Salary x 1.435 ÷ 2,087); $94,198 x 1.440 ÷ 2,087 = $65.00. Data search qualifiers: Agency=DLMS, Occupation=1822, GSEG=GS12.

7 See footnote 6 for calculation description ($38.13 = $55,264 x 1.440 ÷ 2,087).

Data search qualifiers agency=DLMS occupation=1802, GSEG=GS06.

7


File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File Title8/24/12
AuthorBouchet, Nicole - MSHA
File Modified0000-00-00
File Created2025-05-19

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