United States General Accounting Office

GAO Testimony

Before the Committee on Small Business

U.S. Senate

For Release on Delivery

Expected at

9:30 a.m. EDT

Wednesday

June 4, 1997

PAPERWORK REDUCTION

Governmentwide Goals

Unlikely To Be Met

Michael Brostek

Associate Director, Federal Management and Workforce

Issues

General Government Division

GAO/T-GGD-97-114

Summary 

Paperwork Reduction: Governmentwide

Goals Unlikely to Be Met

The paperwork burden that the federal government imposes on the public,

commonly measured in terms of “burden hours,” was estimated to total

6.7 billion hours in fiscal year 1996, down slightly from the 6.9 billion-hour

estimate for 1995. Some paperwork, of course, is necessary and can serve

a useful purpose. Nevertheless, agencies have a responsibility to keep the

amount of paperwork as low as possible consistent with carrying out their

missions.

Congress enacted the Paperwork Reduction Act of 1995 to impose

discipline on the management of paperwork requirements. Among other

things, the act requires the Office of Management and Budget’s (OMB)

Office of Information and Regulatory Affairs to set a goal of at least a

10-percent reduction in governmentwide paperwork burden for fiscal

years 1996 and 1997, a 5-percent reduction goal for each of the next 4

fiscal years, and annual agency goals that reduce burden to the “maximum

practicable opportunity.”

In assessing progress toward achieving these goals, it is appropriate to

recognize that the basic data used to measure paperwork burden has

important limitations. For instance, considerable uncertainty exists about

whether the Internal Revenue Service’s (IRS) paperwork burden-hour

estimate—which has recently accounted for about 75 percent of the

government’s estimated total paperwork burden—is overstated. These

limitations need to be borne in mind when gauging burden and progress in

reducing it.

On January 13, 1997, OMB instructed agencies to establish goals and

timetables to achieve, by the end of fiscal year 1998, a cumulative burden

reduction of 25 percent. This goal does not require the annual reductions

contemplated by the act, but, if accomplished, could result in a similar

reduction by the end of fiscal year 1998.

However, primarily because IRS expects its paperwork burden-hour

estimate to decline a total of about 2 percent over the fiscal year 1996-1997

period, it appears unlikely that the federal government as a whole will

meet the cumulative 25-percent reduction contemplated by the act by the

end of fiscal year 1998. In addition to IRS, GAO looked specifically into two

other agencies’ progress. Environmental Protection Agency (EPA) officials

said they will not achieve a 25 percent net reduction by the end of fiscal

year 1998, while Occupational Safety and Health Administration (OSHA)

officials said they expect to meet this reduction goal.

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Goals Unlikely to Be Met

All three agencies—IRS, EPA, and OSHA—indicated that the statutory

framework that underlies their regulations and/or continued actions by

Congress requiring the agencies to produce regulations were major

impediments to eliminating paperwork burden.

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Statement 

Paperwork Reduction: Governmentwide

Goals Unlikely to Be Met

Mr. Chairman and Members of the Committee:

I am pleased to be here today to update our testimony before the

Committee last year regarding the implementation of the Paperwork

Reduction Act of 1995, as amended.1

 As you requested, I will focus today

on three issues: (1) the Office of Management and Budget’s (OMB) efforts

to fulfill its responsibilities under the act, particularly its responsibility for

establishing and overseeing governmentwide and agency-specific

paperwork reduction goals; (2) the likelihood of the government and

particular agencies meeting those goals; and (3) any impediments the

government faces in reaching the goals. At your request, we addressed

these issues by reviewing selected aspects of the act’s implementation at

OMB and three agencies—the Internal Revenue Service (IRS), the

Environmental Protection Agency (EPA), and the Occupational Safety and

Health Administration (OSHA). Participants at the 1995 White House

Conference on Small Business said these three agencies imposed the most

significant paperwork burdens on small businesses.

Background Before discussing the results of our review, I believe some background

information would provide useful context. The Paperwork Reduction Act

of 1995 amended and recodified the Paperwork Reduction Act of 1980, as

amended. The 1995 act reaffirmed the principles of the original act and

gave new responsibilities to OMB and executive branch agencies. Like the

original statute, the 1995 act requires agencies to justify any collection of

information from the public by establishing the need for and ability to use

the information, estimating the burden that the collection will impose on

the respondents, and showing that the collection is the least burdensome

way to gather the information.

The act also reauthorized the Office of Information and Regulatory Affairs

(OIRA) within OMB. Under the act, OIRA has overall responsibility for

determining whether agencies’ proposals for collecting information

comply with the act.2

 Agencies must receive OMB approval for each

information collection request before it is implemented. OIRA also is

required to keep Congress “fully and currently informed” of the major

1

Paperwork Reduction: Burden Reduction Goal Unlikely To Be Met (GAO/T-GGD/RCED-96-186,

June 5, 1996).

2

The act requires the Director of OMB to delegate the authority to administer all functions under the

act to the Administrator of OIRA but does not relieve the OMB Director of responsibility for the

administration of those functions. Approvals are made on behalf of the OMB Director. In this

testimony, we generally refer to OIRA or the OIRA Administrator wherever the act assigns

responsibilities to OMB or the Director.

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Goals Unlikely to Be Met

activities under the act and must report to Congress on agencies’ progress

in reducing paperwork. To do so, OIRA develops an Information

Collection Budget (ICB) by gathering data from executive branch agencies

on the total number of “burden hours” OMB approved for collections of

information for the agency at the end of the fiscal year and agency

estimates of the burden for the coming fiscal year.3

Finally, the 1995 act made several changes in federal paperwork reduction

requirements. For example, it requires OIRA to set a goal of at least a

10 percent burden reduction governmentwide for each of fiscal years 1996

and 1997, a 5 percent governmentwide burden reduction goal in each of

the next 4 fiscal years, and annual agency goals that reduce burden to “the

maximum practicable opportunity.”4

Some Paperwork Is

Necessary

I also believe it is important to point out that some paperwork is necessary

and can serve a useful purpose. Information collection is one method by

which regulatory agencies carry out their missions to, for example, collect

taxes, keep workplaces safe, and clean the environment. Without some

such information, IRS would not know the amount of tax owed by the

taxpayer, and EPA and OSHA would not know whether the intent of

statutes such as the Clean Air Act and the Occupational Safety and Health

Act is being achieved. However, under the act, agencies do have a

responsibility to keep the amount of paperwork as low as possible.

OMB and Agencies

Set Burden Reduction

Goals

During the past year, OIRA published what its officials said were

governmentwide and agency-specific burden reduction goals.

Subsequently, OMB established multiyear governmentwide and

agency-specific burden reduction goals that could, if implemented,

accomplish the burden reductions that the Paperwork Reduction Act of

1995 envisioned would occur by the end of fiscal year 1998.

Goal-Setting Is Useful but

Caution Needed Due to

Imprecise Data

Before discussing the specifics of OMB and agencies’ goal-setting efforts,

it is appropriate to recognize that the basic data used to gauge paperwork

burden have important limitations. Although the paperwork reduction

concepts in the Paperwork Reduction Act of 1995 are a useful framework

3

Although OIRA consults with agencies in the preparation of their ICB submissions and refers to this

data collection process as a “budget,” OIRA’s information collection budget does not limit the number

of burden hours an agency is permitted to impose in the way that a financial budget limits

expenditures.

4

The original act contained burden reduction goals, but they had expired.

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Goals Unlikely to Be Met

for imposing discipline on the government’s management of paperwork

requirements affecting the public, users of paperwork burden-hour

estimates should proceed with caution. Estimating the amount of time it

will take for an individual to collect and provide information or how many

individuals an information collection will affect is not a simple matter.

Therefore, the degree to which agency burden-hour estimates reflect real

burden and the factors that cause changes to the estimates are often

unclear. For example, as I will discuss in more detail later, considerable

uncertainty exists about the accuracy of IRS’ paperwork burden-hour

estimate—which has recently accounted for about 75 percent of the

government’s estimated total paperwork burden. IRS’ estimates may be off

by as much as billions of burden hours and to the extent that the estimates

are off, the estimates used to gauge progress in meeting the goals of the

Paperwork Reduction Act would also be significantly flawed.

Nevertheless, these are the best indicators of paperwork burden available,

and we believe that they can be useful as long as their limitations are

borne in mind.

OIRA Published ICB

Containing Agencies’

Burden-Hour Estimates

Last year I testified that as of the end of May 1996, OIRA had not set any

burden reduction goals. However, OIRA staff told us at that time that OIRA

would establish a governmentwide burden reduction goal of 10 percent for

fiscal year 1996 in a then soon-to-be-published ICB. They also said that

agency goals would reflect the end of fiscal year 1996 burden-hour

estimates that the agencies would provide in their ICB submissions, unless

changed as a result of OIRA review.

OIRA published the ICB for fiscal year 1995 in August 1996. The ICB stated

that the act “set an annual government-wide goal for the reduction of total

information collection burden of 10 percent during each of fiscal years

1996 and 1997 and 5 percent during each of fiscal years 1998, 1999, 2000,

and 2001.” OIRA officials told us that they believe this statement satisfied

the act’s requirement that OIRA establish governmentwide burden

reduction goals.

In the August 1996 ICB, federal departments and agencies estimated that

their burden-hour totals at the end of fiscal year 1996 (less than 2 months

later) would average less than 1 percent below the end of fiscal year 1995

totals.5

 OIRA does not believe there is a contradiction between the

5

The agencies estimated that the total number of burden hours would decline from 6.90 billion hours

on September 30, 1995, to 6.85 billion hours on September 30, 1996. Data from the Regulatory

Information Service Center as of May 1997 indicates the agencies ended fiscal year 1996 with

6.75 billion burden hours.

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Goals Unlikely to Be Met

governmentwide burden-hour reduction goal of 10 percent for fiscal year

1996 and the fact that the agency-specific goals for that year averaged less

than 1 percent. OIRA officials believe this apparent contradiction can

occur because the act specifies that individual agencies’ goals should

reduce information collection burdens to the “maximum practicable

opportunity.” The sum of these maximum practicable agency goals may

not total to 10 percent governmentwide. Nevertheless, we believe that it is

logical to assume that agency-specific goals would be the means by which

the governmentwide goal would be achieved. We also believe that the 1995

act’s legislative history indicates that Congress contemplated a connection

between the governmentwide and agency-specific goals.6

OMB Has Set a 25 Percent

Burden Reduction Goal

On January 13, 1997, OMB issued Bulletin 97-03, which instructed

executive departments and agencies to prepare and implement an ICB for

fiscal year 1996 and an Information Streamlining Plan (ISP). The bulletin

said each agency’s ISP should include “goals and timetables to achieve, by

the end of (fiscal year) 1998, a cumulative burden reduction of 25 percent

from its (fiscal year) 1995 year-end level, consistent with the

governmentwide burden reduction goals in the Paperwork Reduction Act

of 1995.” The bulletin also said that each agency should identify in its ISP

submission specific administrative changes, program restructures,

regulatory reinventions, and legislative proposals that would reduce its

total paperwork burden on the public and streamline the paperwork it

imposes.

OIRA staff said that progress toward the 25-percent goal will be measured

against agency burden-hour estimates as of September 30, 1995, and that

agency and governmentwide reductions would have to take into account

any burden-hour additions that occurred while the reductions were taking

place. For example, if an agency was able to reduce its September 30,

1995, paperwork burden by 25 percent, but new regulations that the

agency issued during that period added the equivalent of an additional

10 percent, the agency would get credit for having accomplished only a

15 percent reduction in burden hours.

OMB’s goal of reducing the number of burden hours by 25 percent by the

end of fiscal year 1998 could, if accomplished, achieve a similar reduction

to what the act contemplated through its requirement that OIRA set goals

6

The act’s conference report states that “individual agency goals negotiated with OIRA may differ

depending on the agency’s potential to reduce the paperwork burden such agency imposes on the

public. Goals negotiated with some agencies may substantially exceed the Government-wide goal,

while those negotiated with other agencies may be substantially less.”

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of 10 percent for fiscal years 1996 and 1997 and 5 percent for 1998. OIRA

officials told us that the 3-year goal was established because paperwork

reductions typically take several years to implement, and therefore a

multiyear goal was more workable.

OIRA officials said that as of the end of May 1997, most of the agencies

had submitted their ISPs and that OIRA staff were reviewing their

submissions. They also said they were scheduling hearings to review the

ISPs with top officials in each agency and anticipated that the hearings

would be completed by the end of June 1997.

Measuring Progress

Toward the Goal

In previous years, OIRA used ICB information to assess agencies’ progress

in reducing paperwork burden. Changes in burden-hour estimates from

year to year were classified as caused by either “program changes” or

“adjustments.” Program changes were defined as additions or reductions

to existing paperwork requirements imposed either through new statutory

requirements or an agency’s own initiative. Adjustments were changes in

burden estimates that were caused by factors other than changes in the

actual paperwork requirements, such as changes in the population

responding to a requirement or agency reestimates of the burden

associated with a collection of information. OIRA counted both program

changes and adjustments when calculating an agency’s burden-hour

baseline at the end of each fiscal year. OIRA did not count changes due to

adjustments in determining whether an agency had achieved its burden

reduction goal.

OIRA officials told us that they will continue to use information from the

ICBs in judging agencies’ progress toward the goal of reducing burden by

25 percent by the end of fiscal year 1998. The ICB for fiscal year 1996 is

currently scheduled to be published in June 1997. OIRA officials also told

us that they will measure and report on both program changes and

adjustments, but they have not decided whether to count adjustments

when judging agencies’ accomplishments. If OIRA decides to count

adjustments, agencies could meet their 25 percent burden reduction goals

by reestimating the burden of their existing information collections.

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Goals Unlikely to Be Met

Recent Changes in

Paperwork Burden

Suggest Burden

Reduction Goals

Unlikely to Be Met

OMB’s January 13, 1997, bulletin stated that “agencies have made

substantial progress in reducing paperwork burden” since the original

Paperwork Reduction Act was enacted in 1980. However, the

governmentwide burden-hour estimate actually rose substantially during

that period. Figure 1 shows changes in reported burden-hour estimates

governmentwide and at IRS between September 30, 1980, and

September 30, 1996. The figure also shows IRS’s estimate of its

burden-hour total at the end of fiscal year 1997 that was presented in its

ICB submission for fiscal year 1996.

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Goals Unlikely to Be Met

Figure 1:

GAO Trends in Estimated Paperwork Burden 

Governmentwide and for IRS

Total government (no projection for FY 1997)

IRS projection for FY 1997

IRS

80 82 84 86 88 90 92 94 95 96 97

0

1

2

3

4

5

6

7

8

Burden hours (in billions)

Note: Data are as of September 30 each year.

Source: Regulatory Information Service Center and Department of the Treasury.

As you can see, the governmentwide burden-hour estimate rose from

about 1.5 billion hours in 1980 to more than 6.7 billion hours in 1996.

However, the near tripling of the governmentwide burden-hour estimate

during fiscal year 1989 was primarily because IRS adopted a new

methodology for computing burden, which increased its paperwork

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Goals Unlikely to Be Met

estimate by about 3.4 billion hours. In each year since fiscal year 1989, IRS’

estimated paperwork burden has accounted for more than three-quarters

of the governmentwide total. Because the current estimate of IRS’

paperwork burden is such a large portion of the governmentwide estimate,

increases or decreases in IRS’ estimated number of burden hours have

had—and may in the future have—a dramatic effect on the

governmentwide estimate.

The governmentwide 6.7 billion burden-hour estimate for 1996 is down

from just over 6.9 billion hours in 1995. Notably, this decline occurred

despite the fact that IRS’s burden-hour estimate rose slightly between 1995

and 1996 (from 5.28 billion hours to 5.30 billion hours).7

 In general,

however, reducing the burden imposed by IRS will be an important

component of any governmentwide effort to reduce paperwork burden.

Figure 2 shows the month-by-month changes in the estimated

governmentwide paperwork burden between September 30, 1995, (the day

before the 1995 act’s effective date) and April 30, 1997 (the most recent

date for which data were available). The figure also shows what the

burden-hour totals would have been if the agencies had achieved the

10 percent reductions contemplated in the act for fiscal years 1996 and

1997 and the required additional 5 percent reduction for fiscal year 1998.

7

OIRA officials noted that except for IRS, the paperwork estimate for the rest of the government

declined by more than 10 percent during the act’s first year of implementation.

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Goals Unlikely to Be Met

Figure 2:

GAO

9/95 3/96 9/96 3/97 9/97 3/98 9/98

0

1

2

3

4

5

6

7

8

Burden hours (in billions)

Changes in Estimated Governmentwide

Burden and Burden Reduction Goals

10% reduction

10% reduction

5% reduction

Month by month estimated burden

Reduction goals

Note: Data are as of the end of each month.

Source: Regulatory Information Service Center and GAO.

The figure shows that as currently measured, the federal government had

not achieved the 10-percent reduction in burden hours contemplated by

the act by the end of fiscal year 1996. Also, because IRS expects to achieve

only a 1-percent reduction in its burden total by the end of fiscal year 1997,

and because IRS officials told us that they anticipated achieving another

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Goals Unlikely to Be Met

1-percent reduction by the end of fiscal year 1998, it appears unlikely that

the federal government as a whole will meet the 25-percent reduction

contemplated by the act by the end of fiscal year 1998. If IRS cannot

reduce its burden-hour total by more than 2 percent between fiscal years

1995 and 1998, achieving a 25-percent reduction in the governmentwide

burden-hour total during that period would require that all other federal

departments and agencies virtually eliminate their information collections.

Specific Burden

Reduction Actions at

IRS, EPA, and OSHA

and Likelihood of

Agencies Reaching

Their Goals

We examined the ICB and ISP submissions for IRS, EPA, and OSHA to

determine what actions they said they have taken to reduce their

estimated paperwork burden and whether the agencies believe they will

meet the 25 percent burden reduction goal by the end of fiscal year 1998.

Although all three agencies indicated they had undertaken numerous

burden reduction efforts, the agencies differed in the degree to which they

expected those efforts to reduce their burden-hour estimates.

IRS Said It Has Taken

Actions but Cannot

Achieve the 25 Percent

Burden Reduction Goal

IRS’s draft ISP submission describes a number of actions the agency said it

has taken to reduce its information collection burden. For example, IRS

said it produced a set of streamlined instructions for its Form 1040,

switched over 400,000 filers from Schedule C to Schedule C-EZ, and

deleted 20 entries from Form 1040 and its instructions that resulted in a

reduction of nearly 60 million burden hours. In another change, IRS said

that it was raising the threshold for which a receipt is required for

substantiation of a business expense for travel from $25 to $75, reducing

the burden on taxpayers by an estimated 12.4 million hours.

However, after reviewing its 15 largest information collections as of

September 30, 1995, IRS said it was unable to identify burden reductions

that would allow it to achieve a 25-percent reduction in its baseline of

5.3 billion hours. As I mentioned earlier, the agency estimated that its total

information collection burden by September 30, 1997, will decline by

about 1 percent from the previous year. However, IRS estimated its

information collection total would still stand at nearly 5.25 billion hours.

IRS officials told us that the agency would probably be able to accomplish

another 1-percent reduction in its burden-hour totals by September 30,

1998.

In its draft ISP, IRS said it could not reach the 25 percent burden reduction

goal because its major information collections

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Goals Unlikely to Be Met

“request information that is mandated by the Internal Revenue Code and which IRS needs

to collect the required amount of individual and corporate income tax revenue. Reducing

the paperwork burden of these items would make it more difficult, if not impossible, to

administer the Internal Revenue Code. We will continue to search for new opportunities to

reduce burden, but the only way to achieve major burden reduction is to simplify the tax

laws.”

However, in considering such simplifications, Congress must weigh

several, sometimes competing, issues. These include the revenue

implications of any change, the goal to promote equity and fairness, and

the desire to achieve certain social and economic goals. Achieving a

balance among these issues while making it easier for taxpayers to comply

presents a significant challenge to Congress.8

IRS officials also told us that many of the burden reduction efforts the

agency has made are not reflected in the burden-hour estimates because

they are not counted. For example, they said that 32 notices and letters

that were previously sent out 22 million times a year were eliminated this

year, reducing taxpayer burden and saving IRS over $17 million. They said

that this burden reduction was not reflected in IRS’s burden-hour

estimates because the notices and letters that were eliminated were not

subject to the Paperwork Reduction Act. They also said that some

taxpayers are not taking full advantage of IRS initiatives to reduce burden,

such as TeleFile and electronic submission of tax information. As noted

later in my testimony, IRS is working on a new methodology to measure

taxpayer burden.

EPA Says It Has Taken

Actions but Will Not

Achieve the 25 Percent

Burden Reduction Goal

EPA has had its own effort to reduce paperwork that began before the

Paperwork Reduction Act of 1995 took effect.9

 However, despite this effort

and actions designed to meet the burden reduction goals contemplated in

the act, EPA said it will not achieve a 25 percent net reduction of its fiscal

year 1995 information collection burden by the end of fiscal year 1998.

According to its draft ISP, a primary focus of EPA’s burden reduction

efforts has been on the agency’s 21 information collections with the

greatest estimated burdens. Of these, EPA said 16 will have their burdens

reduced significantly by the end of fiscal year 1998, and 2 others will be

8

Tax System Burden: Tax Compliance Burden Faced by Business Taxpayers (GAO/T-GGD-95-42,

Dec. 9, 1994).

9

Environmental Protection: Assessing EPA’s Progress in Paperwork Reduction (GAO/T-RCED-96-107,

Mar. 21, 1996).

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reduced by the end of the decade. For example, EPA said the burden

associated with its Discharge Monitoring Reports would be reduced by

nearly 4.7 million hours. EPA said that the information collections

associated with its September 30, 1995, total estimated paperwork burden

of 104.1 million hours would be reduced by 21.8 million hours by the end

of fiscal year 1998—a 21-percent reduction. EPA also said that it would

reduce 4.1 million hours from new additions to the baseline, so its total

projected reduction was 25.9 million hours.

However, EPA’s draft ISP also said that these reductions would be more

than offset by 30.3 million burden hours added during this period. EPA

estimated in its draft ICB that its burden as of September 30, 1997, would

be more than 115 million hours. (See fig. 3.) EPA’s draft ISP estimated that

its total paperwork burden by September 30, 1998, would be 108.5 million

hours—a decrease from the 1997 estimate but an increase of about

4 percent from the fiscal year 1995 baseline. However, EPA noted that this

estimate did not include “a potentially large increase related to the Safe

Drinking Water Consumer Confidence Report.”

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Figure 3:

GAO Changes in EPA's Estimated Burden 

Hour Total Since 1980

80 82 84 86 88 90 92 94 95 96 97 

0

20

40

60

80

100

120

140

Burden hours (in millions)

EPA

EPA projection for FY 1997

Note: Data are as of the end of each month.

Source: Regulatory Information Service Center and EPA.

EPA’s draft ISP said the increases in its estimated burden hours between

fiscal years 1995 through 1998 were driven by four factors: (1) 5.5 million

burden hours associated with the Toxic Release Inventory’s Form R that

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had not been counted in the past;10 (2) recalculations of burdens for

existing information collections (e.g., a 2.4 million hour increase for the

Hazardous Waste Manifest); (3) nearly 14 million hours added in support

of expanded community-right-to-know efforts;11 and (4) new regulations

under the Clean Air Act Amendments and other rules.

OSHA Says Its Actions Will

Achieve the 25 Percent

Burden Reduction Goal

In contrast to IRS and EPA, OSHA said it has already made substantial

progress toward achieving a 25-percent reduction in its fiscal year 1995

paperwork burden estimate. As figure 4 shows, OSHA’s paperwork burden

estimate increased dramatically just prior to the 1995 act’s effective date.

This increase occurred because OSHA and other agencies were trying to

get proposed information collections approved before the new act took

effect on October 1, 1995. However, the Department of Labor’s ICB

submission indicated that OSHA had reduced its September 30, 1995,

baseline of 207.6 million hours by 25.1 million hours (12 percent) as of

September 30, 1996, and estimated that OSHA would be able to reduce its

total by another 17.3 million hours by September 30, 1997. If so, OSHA will

have reduced its total paperwork burden by more than 42 million hours—a

20-percent decrease from its fiscal year 1995 baseline. OSHA officials told

us that they expect the agency to achieve the 25 percent burden reduction

goal by the end of fiscal year 1998.

10The 1993 appropriations bill for EPA (P. L. 102-389) effectively provided an exemption from the

Paperwork Reduction Act for EPA’s Form R until such time as revisions to the form are made in

accordance with law. OMB subsequently dropped this information collection from its ICB tracking

system when its information collection clearance expired. The recent revision of Form R and the

reinstatement of OMB clearance for this collection will add 5.5 million hours to EPA’s burden-hour

total but will not impose any additional burden on the public because the form was used continuously

throughout this period.

11Right-to-know requirements involve the disclosure of health and environmental information to the

public and are contained in such statutes as the Safe Drinking Water Act, the Emergency Planning and

Community Right-to-Know Act, and the Residential Lead-based Paint Hazard Disclosure Act.

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Figure 4:

GAO Changes in OSHA's Estimated Burden 

Hour Totals Since 1980

OSHA

OSHA projection for FY 1997

80 82 84 86 88 90 92 94 95 96 97

0

50

100

150

200

250

Burden hours (in millions)

Note: Data are as of the end of each month.

Source: Regulatory Information Service Center and the Department of Labor.

The Department of Labor’s draft ICB and ISP identified a number of

specific actions that it said caused the sharp decline in burden hours. For

example, the documents indicated that OSHA had achieved an estimated

18 million-hour reduction in its paperwork burden as a result of changes to

its Process Safety Management standard. They also indicated that OSHA

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had reduced the burden associated with its Hazardous Waste Operations

and Emergency Response standard from 18.7 million hours to about

2.2 million hours.

Nevertheless, the draft ISP also indicated that burden reductions for a

number of its standards would not be possible without statutory change.

For example, the ISP said that OSHA’s review of one of its standards “did

not identify any method of reducing paperwork that does not

simultaneously increase significant risk. OSHA is precluded from taking

any regulatory action that will increase such risk.” The ISP also noted that

OSHA’s Lead in Construction and Hazardous Waste Operations and

Emergency Response rules were congressionally mandated and “would

require the consent of Congress to revise.”

Impediments to

Reaching Burden

Reduction Goals

Although each of their burden reduction experiences differed, IRS, EPA,

and OSHA all indicated in their ICB or ISP submissions that the statutory

framework that underlies their regulations and/or continued actions by

Congress requiring the agencies to produce regulations were major

impediments to eliminating paperwork burden. As I mentioned earlier, IRS

said that it cannot reach the 25 percent burden reduction goal of

eliminating more than 1 billion burden hours of paperwork under the

current statutory framework and still carry out its mission. The agency

said paperwork reductions of that scale are possible only through a major

simplification of the tax laws. EPA said that its burden reduction efforts

have allowed the agency’s baseline to remain relatively constant “despite

the passage of new legislation and the increasing call by the public for

additional information.” The Department of Labor said “reductions in

information collection requirements which are statutorily mandated can

only be achieved through legislative changes” and subsequently identified

several such instances in OSHA regulations.

As I mentioned earlier, information collection is one method by which

agencies carry out their missions, and those missions are established by

Congress through legislation. If agencies’ paperwork requirements are

truly statutorily mandated, then burden-hour reductions of the magnitude

envisioned by the act may not be achievable without changes in the

legislation underlying those requirements. However, we have not assessed

the extent to which the paperwork burden that agencies impose is directly

attributable to statutory requirements and, therefore, is out of the

agencies’ control. Even though a statute may require an agency to take

certain actions, the agency may have discretion regarding whether

Page 18 GAO/T-GGD-97-114
Statement 

Paperwork Reduction: Governmentwide

Goals Unlikely to Be Met

paperwork requirements need to be imposed and, if so, the manner or

frequency with which the information is collected. For example, although

several statutes require employers to provide training to employees, OSHA

may have discretion to determine whether employers need to generate

paperwork to demonstrate their compliance with these provisions.

Another factor that we believe affects agencies’ ability to meaningfully

reduce paperwork burden is the difficulty agencies have experienced in

measuring that burden. The paperwork metric agencies currently use is

“burden hours,” which is supposed to reflect how long it takes

respondents to complete agencies’ information collections. However, the

frequency with which agencies reestimate their burden-hour totals and the

magnitude of those adjustments indicate that those measurements are far

from precise.

For example, the huge increase in the governmentwide burden-hour total

in 1989 was a consequence of IRS reestimating the burden associated with

its information collections. However, a recent analysis of the methodology

that formed the basis of the 1989 reestimate concluded that IRS may now

be significantly overstating businesses’ paperwork burden.12 IRS recently

drafted a statement of work for a new study of IRS tax compliance burden,

but the results of that study will probably not be available for several

years. If the study confirms that IRS’s current burden-hour estimates are,

in fact, significantly overstated, the agency’s and the governmentwide

burden-hour totals could fall back to their pre-1989 levels—far below the

burden reduction goals contemplated in the act. However, because only

the measurement system would have been altered, the actual paperwork

burden felt by the public would remain unchanged.

Mr. Chairman, this completes my prepared statement. I would be pleased

to answer any questions.

(410127)

12In the early 1980s, IRS commissioned Arthur D. Little, Inc., to develop a methodology to estimate the

burden each tax form imposed on taxpayers. In a paper prepared for a 1996 Brookings Institute forum,

Professor Joel Slemrod concluded that the Little methodology overstated business taxpayer

paperwork burden by a factor of five. IRS officials said that after working with analysts in the Office of

Tax Analysis in the Department of the Treasury, Professor Slemrod now believes the appropriate

adjustment factor for business taxpayer paperwork burden is about 3.8.

Page 19 GAO/T-GGD-97-114
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