OMB UPC Supporting Statement and Burden Grid Final Document 6-24-08

NUPC SUPPORTING STATEMENT AND BURDEN GRID

1. Explain the circumstances that make the collection of information necessary.

Food and Nutrition Service (FNS) is authorized by The Child Nutrition and WIC Reauthorization Act of 2004 –S.2507 to establish a “National Universal Product Code (NUPC) database for use by all State agencies carrying out the program.” In response to this mandate, FNS, of the U.S. Department of Agriculture (USDA) has developed a NUPC database to serve as an electronic national repository of Women, Infant, and Children (WIC) eligible foods that have been authorized or approved by FNS and/or WIC State agencies.

2. Indicate how, by whom, and for what purpose the information is to be used.

The NUPC database will help meet FNS Objective 2.2, improved efficiency of program administration, by allowing product manufacturers and State agencies to access a central repository of product information necessary to support State agency Electronic Benefits Transfer (EBT) implementations for the WIC Program. The system will enable product information sharing for the State agencies and participating manufacturers. System benefits include more efficient review of potential candidate food items by State agencies, reduced duplication in product entry, and standardized output reporting in electronic formats suitable for incorporation into stakeholder automated systems. Also, with an automated review of each product, the application will ensure that the products are reviewed against program regulations to ensure compliance with nutrition standards.

Approximately 1,000 manufacturers, 40 WIC State agency staff in 20 WIC State agencies, and 3 FNS employees will use the new NUPC database for the first three year reporting period. After the first three year period, FNS expects the number of WIC State agencies and manufacturers to slowly increase each year.

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.

The NUPC database will help streamline the handling of product information for State agencies, retailers and manufacturers; allow more consistent oversight of WIC approved items; reduce the electronic processing needed by State agencies; standardize the way retailers obtain WIC UPC information; and make it easier for State agencies to begin using EBT processing by reducing the need to visit food retailer locations to gather UPC and other product information.

The NUPC database will allow manufacturers to submit product details to the central database for consideration by participating WIC State agencies when they approve products for use. The NUPC database application process will pass a screening against Federal standards automatically. The application will then allow State agencies to manage their approvals of WIC items and UPC’s in one central place.

This information is automated in a fill-able and file-able format accessed via the web. Therefore, this collection is in compliance with the E-Government Act 2002 and Government Paperwork Elimination Act (GPEA) 1998. The address to access the NUPC database is: https://wicupc.fns.usda.gov.

4. Describe efforts to identify duplication.

There are no similar data collection efforts.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

No data are being collected from small businesses or other small entities. There will be no impact on small businesses or other small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently.

This is a mandated need. Not meeting this need would violate The Child Nutrition and WIC Reauthorization Act of 2004. The purpose of this new data collection process is to reduce the current burden on both manufacturers and WIC State agencies. Allowing manufacturers to submit their food product data electronically for review and authorization eliminates mailing costs and decreases the amount of time it takes for WIC State agencies to receive the product for review and authorization. Included in the NUPC database application are business validation rules that each product must pass before the product can be submitted into the database. These business validation rules help reduce the number of non-eligible products being submitted for review and decreases the amount of time WIC State agencies must spend reviewing and approving products.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner that is inconsistent with 5 CFR 1320.6.

Collection is consistent with 5 CFR 1320.6.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice. Summarize public comments received in response to the notice and describe actions taken by agency.

The 60-day notice for the “WIC National Universal Produce Code” was published on September 27, 2007, on pages 54892 and 54893 of the Federal Register, Volume Number 72.

The Federal Register Notice was published and was available for comment to the public for a period of 60 days. One comment was received which caused FNS to increased the number of responses from 131 to 819.

(a) Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, etc. Explain efforts to consult with representatives of those from whom information is to be obtained at least once every 3 years.

WIC State agencies and manufacturers were consulted throughout the NUPC database planning and development stage. Several meetings were conducted to demonstrate the system to assure it was designed to meet all needs and requirements. WIC State agencies and manufacturers will be consulted via conference calls and email if there is a need for modifications to the data collection format.

9. Explain any decision to provide any payment or gift to respondents.

No payment or gift to respondents is being provided.

10. Describe any assurance of confidentiality provided to respondents.

The NUPC database will not collect any personal identifiers.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other manners that are commonly considered private.

There are no questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

12. Provide estimates of the hour burden of the collection of information.

(a) Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

The total number of respondents for this collection is expected to be approximately 1,040 annually. The annualized burden hour is 1,938 which are estimated in the table below. The burden hour for each respondent type varies in the tables below:

A.12-A Estimates of Burden Hours

• It is estimated that approximately 1,000 manufacturers will spend approximately 5 minutes per product entering an average of 10 products in Year 1. In years 2 and 3 they will spend approximately 2.5 minutes updating about half of the products in the database. Therefore the average time for manufacturers to input products for all 3 years is 2.5 minutes.

• It is estimated that 20 WIC State agencies with two users each (40 users) will spend approximately 5 minutes per product entering an average of 1,200 products the first year and each year will spend 2.5 minutes uploading/downloading products monthly (12 downloads per respondent/year). In years 2 and 3 they will spend approximately 2 minutes updating about half of the products and spend the same 2.5 minutes uploading/downloading the revised products per month. The ongoing updating burden in years 2 and 3 will become a maintenance task instead of a higher burden to initially populate the database.

Type of Respondent	Description of activity	Number of Respondents	Number of responses annually per Respondent	Total annual responses (c x d)	Estimate of Burden Hours per response	Total Annual Burden Hours (e x f)
Manufacturers	Entering products in database	1,000.00	7.00	7,000.00	0.0835000	584.5000000
WIC State Agency Users	Entering products in database	40.00	800.00	32,000.00	0.0416600	1,333.1200000
	Monthly uploading and downloading products	40.00	12.00	480.00	0.0416600	19.9968000
Annualized burden		1,040.00	819.00	39,480.00		1,937.6168000

Provide estimates of annualized cost to respondents for the hour burdens for collections of information.

• Estimates of annualized costs to the respondents are based on an hourly wage rate for the following two respondent categories: WIC State Agency User and Manufacturers. National median wage estimates are used and the source for the wage data is the Bureau of Labor Statistics, May 2005 National Industry-Specific Occupational Employment and Wage Estimates, Median Hourly Wages.

The estimated total annualized hourly cost to respondents is $3,003.73.

Description of the Collection Activity	Number of Respondents	Estimated Total Annual Burden on Respondents (Hours)	Estimated Average Income per Hour	Estimated Cost to Respondents
Manufacturers	1000	0.29225	$21.35	$6,239.54
WIC State Agency Users	40	3.841	$18.04	$2,771.67
3 Year Annualized Cost	1040			$9,011.20
Annual Cost				$3,003.73

13. Provide an estimate of the annual cost burden to respondents or record keepers resulting from the collection of information. Cost estimates should be split into two components: a total capital and start-up costs.

No other cost burden to respondents or record keepers is required for this data collection. Respondents will not be required to keep any record information since the information will be stored in the NUPC database and respondents will not need to procure any equipment, software or other services in order to submit data into NUPC.

14. Provide estimates of annualized cost to the Federal government.

The estimated annualized cost to the Federal government is approximately $20,162.36. This estimate is based on the following:

Annual server maintenance and enhancements: $ 20,000.00

3 Federal employees (GS-07 $18.04/hour) $ 162.36

Subtotal: $ 20,162.36

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of the OMB Form 83-1.

This is a new information collection.

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

There are no plans to tabulate or publish anything in connection with this information collection.

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

The Agency is seeking approval not to display the OMB expiration date for OMB approval of this information collection. To display the expiration date would mean the automated collection would require a system upgrade, which may make the collection unavailable to users for a period of time. Also, the continued changing of this date each time the collection is approved may cause confusion to the respondent, who may think changes have been made to the data elements.

18. Explain each exception to the certification statement identified in item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.

There are no exceptions to the certification statement being requested.

5