Ss 0196

Self-Certification Medical Statement

Supporting Statement

OMB Clearance 0579‑0196

JUSTIFICATION May 2008

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.

The United States Department of Agriculture is responsible for ensuring consumers that food and farm products are moved from producer to consumer in the most efficient, dependable, economical, and equitable system possible.

5 CFR Part 339 authorizes an agency to obtain medical information about the applicant's health status to assist management in making employment decisions concerning positions that have specific medical standards or physical requirements in order to determine medical/physical fitness. The Marketing and Regulatory Programs (MRP) of the U.S. Department of Agriculture (USDA) hires individuals each year in commodity grading and inspection positions. These positions involve arduous duties and work under dusty conditions, around moving machinery, slippery surfaces, and high noise level areas. A potential employee may have direct contact with meat, dairy, fresh or processed fruits and vegetables, and poultry products intended for human consumption and/or cotton and tobacco products intended for human use. This information collection is necessary to make a preliminary determination as to physical fitness and ability of the candidate to perform these duties of the position.

Denial of the information would greatly hamper the Agency’s recruiting capability and adversely affect management’s ability to facilitate hiring, placement, and utilization of qualified individuals into positions that have specific medical standards and physical requirements.

The data is needed in order to obtain information from the applicant about his/her health and fitness in order to perform the duties of the position and assist management in making employment decisions concerning positions that have specific medical standards and physical requirements.

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.

The information collected from the prospective employees assists MRP program officials, administrative personnel, and servicing Human Resources offices in determining an applicant’s physical fitness and suitability for employment in positions with approved medical standards and physical requirements and direct contact with meat, dairy, fresh or processed fruits and vegetables, and poultry intended for human consumption and cotton and tobacco products intended for consumer use. These positions involve arduous duties, proximity to moving machinery, slippery surfaces, and exposure to high noise levels.

The following is the only form that MRP uses for this employment process.

MRP-5, Self-Certification Medical Statement

The MRP-5 form is required from applicants regarding their fitness for employment. This information will determine whether the applicants can perform the position duties for which they are applying.

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.

The type of information to be collected and the manner in which the information is to be presented are not currently amenable to use on electronic information technology. There is no technology currently available which can eliminate or reduce the need for the information to be completed by the applicant.

MRP Form 5 was not a transaction determined by APHIS to be practicable for automation under GPEA.

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.

APHIS is the only Federal agency responsible for collecting the personal data of a perspective employee’s physical fitness for the position of which they are applying.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB‑83‑1), describe any methods used to minimize burden.

APHIS has no small entities involved with this information collection.

6. Describe the consequences 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.

If this collection was not conducted, APHIS would not be able to accurately determine the physical and/or mental fitness for the position which the applicant has applied and still meet the provisions of the Act. This information is collected only once.

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

This information collection is consistent with the guidelines established in 5 CFR 1320.6.

8. 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 recordkeeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, soliciting comments on the information collection prior to submission to OMB.

In 2008, APHIS held a productive consultation with the following individual in connection with the information collection activity associated with this program:

Dr. Oleh Jacykewycz

USDA Medical Officer

(202) 720‑3893

On Tuesday, February 5, 2008, APHIS published in the Federal Register, a 60-day notice seeking public comments on its plans to request a 3-year renewal of this collection of information. No comments from the public were received.

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

This information collection activity involves no payments or gifts to respondents.

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

No additional assurance of confidentiality is provided with this information collection. However, the confidentiality of information is protected under 5 U.S.C. 552a.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

It is necessary to assess the physical fitness of an applicant by the responses obtained on the Self Certification Medical Statement in order to make a preliminary determination if a medical condition exists which impedes a physical or mental ability to efficiently perform the essential functions of the position without hazard to himself/herself or others.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

See APHIS Form 71 for hour burden estimates.

• Provide estimates of annualized cost to respondents for the hour burdens

for collections of information, identifying and using appropriate wage rate categories.

The total cost to the respondents was estimated by multiplying their average hourly

wage by the total number of hours needed to complete the work.

$15.00 x 100 hours = $1,500

$15.00 is the hourly rate derived from the U.S. Department of Labor, Bureau of Labor Statistics, June 2005 Report-National Compensation Survey: Occupational Wages in the United States, August 2006. See http://www.bls.gov/ncs/ocs/sp/ncb10832.pdf.

13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information, (do not include the cost of any hour burden shown in Items 12 and 14).

There is no additional cost burden to the respondents or recordkeepers.

14. Provide estimates of annualized cost to the Federal Government. Provide a description f the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The estimated total cost for the Federal Government is $3,494.45. See APHIS Form 79.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the 0MB Form 83‑I.

There is an adjustment increase of 50 burden hours. This was due to an increase in the number of respondents to the Self-Certification Medical Statement.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

There are no plans to publish the data for statistical use.

17. If seeking approval to not display the expiration date for 0MB approval of the information collection, explain the reasons that display would be inappropriate.

If forms were to be discarded because of an outdated OMB expiration date, but were otherwise usable, higher printing costs would be incurred by the Federal Government. Therefore, APHIS is seeking approval to not display the OMB expiration date on its forms.

18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act.”

APHIS is able to certify compliance with all provisions under the Act.