The Occupational Safety and Health Administration (OSHA), part of the U.S. Department of Labor, published a notice in the Federal Register on December 17, 2025, seeking public comments on its proposal to extend approval from the Office of Management and Budget (OMB) for information collection requirements in the Manlifts Standard. This standard, codified at 29 CFR 1910.68(e), mandates periodic inspections and recordkeeping for manlifts, which are vertical conveyor systems used to transport workers in industrial settings. The notice, appearing in Volume 90, Number 240, invites input by February 17, 2026, to assess the ongoing need and burden of these paperwork obligations. This development underscores OSHA's efforts to balance regulatory enforcement with minimizing administrative costs on employers, as required by the Paperwork Reduction Act of 1995 (PRA). It highlights the agency's commitment to worker safety amid evolving workplace technologies, potentially affecting thousands of businesses that rely on manlifts for elevated access.
Background on the Manlifts Standard and Regulatory Framework
Manlifts, often described as endless belt elevators, serve as a means for personnel to move between floors in facilities like warehouses, mills, and manufacturing plants. The Manlifts Standard originated from the Occupational Safety and Health Act of 1970 (OSH Act), which empowers OSHA to establish rules preventing occupational injuries and illnesses. Under 29 U.S.C. 657, the agency can require employers to collect and maintain information essential for enforcement and safety improvements.
The PRA, enacted in 1995 and codified at 44 U.S.C. 3501 et seq., requires federal agencies to obtain OMB approval for information collections that impose paperwork burdens on the public. This process involves periodic reviews to ensure requirements are necessary, minimize burdens, and avoid duplication. OSHA's current OMB approval for the Manlifts Standard, under Control Number 1218-0226, is set to expire, prompting this extension request. Historically, similar extensions have been granted after public consultation, as seen in prior renewals for standards like the Hazardous Waste Operations and Emergency Response rule, where stakeholder input refined burden estimates.
Key players include OSHA's Directorate of Standards and Guidance, led by figures like Belinda Cannon, who is named in the notice for further information. Employers in sectors using manlifts, such as construction and agriculture, are primary respondents, with an estimated 3,000 affected annually. Worker advocacy groups and business associations often participate in comment periods, offering perspectives on practical implementation.
Key Information Collection Requirements
The Manlifts Standard specifies two main paperwork elements designed to verify equipment safety. First, employers must conduct inspections at least every 30 days, covering components like steps, belts, pulleys, brakes, and limit switches, with weekly checks on the switches alone. These inspections aim to detect issues such as worn gears or misalignment that could lead to falls or mechanical failures.
Upon completion, a certification record must be prepared, including the inspection date, the inspector's signature, and the manlift's serial number or identifier. As stated in the notice, 'A certification record of the inspection must be prepared upon completion of the inspection.' This record assures employers, workers, and OSHA that the equipment remains in safe condition, directly supporting the OSH Act's goal of preventing accidents.
Second, these records must be disclosed to OSHA compliance officers during audits. The notice emphasizes that this provides 'the most efficient means for the compliance officers to determine that an employer is complying with the Standard.' No operation or maintenance costs are associated, but the time burden is significant, with OSHA estimating 37,800 hours annually across 36,000 responses.
Proposed Actions and Burden Estimates
OSHA proposes to retain the current burden without changes, maintaining 37,800 hours for inspections and recordkeeping. This calculation assumes an average time per response that varies but averages about one hour per monthly inspection per manlift, based on 3,000 respondents each handling multiple units. The notice details, 'The total number of responses remains the same at 36,000 for the number of inspections certifications maintained annually.'
This extension aligns with PRA mandates to reduce burdens, particularly for small businesses, as noted in 29 U.S.C. 657. OSHA invites comments on automated methods to streamline collections, reflecting technological advancements like digital recordkeeping apps used in other safety standards.
Special Issues for Public Comment
The notice highlights four areas for input: the necessity of the requirements for OSHA's worker protection functions, the accuracy of burden estimates, the quality and utility of collected information, and ways to minimize burdens through technology. For instance, it asks, 'Whether the proposed information collection requirements are necessary for the proper performance of the agency's functions to protect workers, including whether the information is useful.'
Perspectives vary. Employers might argue for reduced frequency if data shows low incident rates, citing Bureau of Labor Statistics reports on fall-related injuries. Worker representatives could emphasize the records' value in preventing fatalities, referencing cases like the 2018 OSHA citation against a grain elevator operator for manlift violations. Legal precedents, such as the U.S. Court of Appeals decision in Secretary of Labor v. Westward Ho! (1980), affirm OSHA's authority to mandate such inspections without undue burden.
Potential Implications and Perspectives
Short-term implications include possible adjustments to the standard based on comments, potentially easing compliance for small firms. Long-term, this could influence broader OSHA policies on digital reporting, aligning with initiatives like the agency's Injury Tracking Application.
Different viewpoints exist without consensus. Business groups, such as the National Federation of Independent Business, often seek burden reductions, while unions like the United Steelworkers advocate for stringent enforcement to protect vulnerable workers. Political forces, including congressional oversight of regulatory costs under the Congressional Review Act, may shape outcomes. No direct judicial challenges to this extension are evident, but related cases underscore the balance between safety and administrative efficiency.
In summary, OSHA's request continues a vital safety mechanism while inviting refinement. Potential next steps involve submitting comments via regulations.gov, followed by OSHA's summary to OMB for approval. Ongoing debates may center on integrating technology to cut hours without compromising safety, addressing challenges like varying employer sizes and enforcement consistency. Future trajectories could include revised estimates if comments reveal inaccuracies, ensuring the standard evolves with workplace needs.
