Supporting Statement for the Standard for Automatic Residential Garage Door Operators
OMB Control Number 3041-0125
The Consumer Product Safety Commission is responsible for the enforcement of the mandatory federal regulation “Safety Standard for Automatic Residential Garage Door Operators” (16 CFR, Part 1211). This standard requires all automatic residential garage door operators manufactured and sold in the U.S. on or after January 1, 1993, to conform to the entrapment protection requirements developed by Underwriters Laboratories, Inc. (UL 325), including subsequent revisions.
The recordkeeping requirements of the standard (16 CFR, Part 1211.31 attached) became effective on January 21, 1993. According to these requirements, written certification records must be maintained for a period of at least three years from the date of certification of each residential garage door operator subject to the standard. These certificates are based on a test of each operator or on a “reasonable testing program.” These records must be available upon request to any designated officer or employee of the Commission upon request in accordance with section 16(b) of the CPSA, 15 U.S.C. 2065(b).
Automatic residential garage door operators are continually being introduced into the market, either by established manufacturers and importers or new manufacturers and importers. Therefore, the Commission seeks approval to continue the recordkeeping requirements without change.
CPSC will use the information obtained from the requested records to assess the current level of compliance with the entrapment provisions of the standard for automatic garage door operators. Also, we will use information we obtain at a given firm in any appropriate legal action(s) initiated, if the firm or its product(s) fail to comply with the entrapment provisions of the standard. The recordkeeping requirements will enable the Commission to identify industry-wide
problems and address them prior to the report of related incidents associated with noncomplying products.
Manufacturers and importers subject to the regulation may use any improvements in information technology that they deem suitable for compiling and maintaining the records required by the regulation.
Information collected by the Commission during this enforcement activity is not collected by any other agency, organization, or individual. There is no similar information available.
In the August 2015 proposed update of the mandatory rule, the Commission noted that all known firms met the UL certification requirements; UL certification is considered sufficient evidence of compliance with the mandatory rule. Thus, the requirements do not impose significant impacts on small businesses.1
The Commission relies on the recordkeeping provisions of the UL standard to monitor compliance with the rule. Without the recordkeeping requirements, the level of compliance would be unknown. The lack of written test records would require an increase in Federal government inspections and sample collections for testing to determine the industry’s compliance with the standard.
There may be special circumstances in which respondents will be requested to prepare a written response involving the collection of information within fewer than 30 days after receipt of the request. These circumstances apply when the CPSC Compliance staff is trying to determine preliminarily whether a defect is present in an automatic residential garage door operator, and whether that defect rises to the level of a substantial product hazard under Section 15 of the Consumer Product Safety Act (CPSA), 15 U.S.C. 2064. Firms are typically given 10 working days to respond to our request for information.
A Federal Register Notice announcing the renewal of this clearance was published June 23, 2025, 90 FR 26560. One out of scope comment was received.
CPSC staff participates in the Underwriters Laboratories, Inc. (UL) Standards Technical Panel for UL 325, the Standard for Door, Drapery, Gate, Louver, and Window Operators and Systems. UL 325 is industry-supported and has guided meaningful garage door operator product safety advances over many years, helping to mitigate entrapment and injury hazards.2
Not applicable.
All records cited as being confidential remain confidential according to the Commission’s procedures under the Freedom of Information Act. These procedures are provided in 15 U.S.C. 1015.
Not applicable. There are no questions of a sensitive nature.
CPSC staff has identified 17 respondents. These firms conduct performance tests and maintain records based on the test results in order to maintain UL certification and verify compliance with the rule. Staff estimates that each respondent will spend 40 hours annually (35 hours for testing and 5 hours for recordkeeping) on the collection of information related to the rule. Therefore, the total estimated burden is 680 hours (17 firms × 40 hours).
The total annual cost of the testing burden is estimated to be about
$45,101, based on an hourly rate of $75.80 as total compensation for management, professional, and related occupations in goods-producing private industries (17 firms × 35 hours × $75.80); the annual cost of recordkeeping is estimated to be about $3,472 based on an hourly rate of $40.85 for sales and office workers (17 firms × 5 hours × $40.85 = $3,472.25).2 Thus, the total cost associated with the testing and recordkeeping burden is about $48,573 ($45,101 + $3,472). This estimate includes professional and clerical time that may be spent to retrieve product data from automated or other records systems, explain firm practices/policies intended to assure compliance with the standard, or accompany Commission personnel during inspections.
There are no costs to respondents beyond those presented in Section
A.12. There are no other operating, maintenance, or capital costs associated with the collection.
Approximately 1.5 staff months for agency employees to examine and evaluate the information could be required for compliance activities. The estimated annual cost to the federal government is based on performance of the work by employees paid at a GS-12 Step 5 pay rate employee, $114,923. According to the most recent Employer Costs for Employee Compensation, this represents approximately 67.8 percent of total compensation for management, professional and related occupational groups.3 Therefore, total compensation for an employee at the GS-12 Step 5 pay rate will have an annual value of about
$169,503 (or approximately $14,125 per month). The annual cost to the federal government of the collection of information is therefore estimated to be about $21,188 ($14,125 × 1.5 months = $21,187.50).
2 U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” December 2024, Table 4. Private industry workers by occupational and industry group: https://www.bls.gov/news.release/archives/ecec_03142025.pdf
3 U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,” December 2024, Table 2, https://www.bls.gov/news.release/archives/ecec_03142025.pdf
No change has been made to the collection of information in the Safety Standard for Automatic Residential Garage Door Operators since it was last approved by OMB.
Not applicable.
Not applicable.
Not applicable.
1 Domestic manufacturers of “other miscellaneous electrical equipment” (NAICS code
335999) with fewer than 500 employees; and merchant wholesalers (including importers) of “durable goods” (NAICS Subsector 423) with fewer than 100 employees.
2 https://ulse.org/insight/standards-and-engagement-standards-matter-automatic-garage-door-standards-helping-keep/
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Preferred Customer |
| File Modified | 0000-00-00 |
| File Created | 2025-09-19 |