Waxman, Charlotte

I agree that privacy is an important issue and as LCO I take every precaution to safeguard the information on certified payrolls. But, I think that not having the addresses and social security numbers on at least one payroll would work a hardship on individuals who are attempting to monitor for compliance. It is my understanding that upon request for the purposes of an audit or investigation the contractor would furnish the SSN and addresses. It has been my experience that contractors under investigation are not normally cooperative and obtaining SSN and addresses would not be an easy thing to do. I would like to also offer that after a period of years or due to catastrophic circumstances (such as a hurricane) records can be lost or misplaced and this information would not be retrievable. I recently furnished copies of a contractor’s payrolls to said contractor because his records were destroyed in Hurricane IKE and he needed employee information which was on the payroll. If the addresses and SSN had not been on the payrolls this information would have been lost. I have worked as a Labor Compliance Officer in excess of 30 years on approximately 700 projects funded by EDA, USDA, HUD, DOA, ORCA and the TX Water Development Board. Being in the field, so to speak, is different. There are times that having an address is important and critical. I do not schedule "on-site employee interviews" as I feel this would defeat the purpose of the interview. Often, my unscheduled interviews are fruitless because the "full crew" is not working or perhaps no one is working. I have often relied on employee questionnaires which I mail to the employees. I would not be able to do this if I did not have an address. I realize that it is not DOL's concern that employees have valid social security numbers, but I think that Homeland Security should be as important as preserving privacy. Pilot programs such as SAVE are being sponsored for Verification Information and I encourage the contractors who are working on federally funded projects to join such programs. As a compliance officer, I take every step necessary to safeguard the payroll records furnished for monitoring and I follow HUD’s guidelines as outlined in LRL 2006-02. In regards to Paperwork Reduction, I think that if contractors were able to “save” DOL’s fillable payroll WH-347, repetitious insertion of information could be eliminated and paperwork would be reduced.