Supporting_Statement_for_Paperwork_Reduction_Act_June_17_(3)

NIJ Body Armor Compliance Testing Program

June 13, 2008

Supporting Statement for Paperwork Reduction Act:

1. Justification

   1. This collection of information will be undertaken as part of the NIJ Body Armor Compliance Testing Program (CTP), which is authorized pursuant to the Homeland Security Act of 2002, relevant portions as codified at 6 U.S.C. 162(b)(4) and 6 U.S.C. 162(b)(6)(B). This act authorizes NIJ/Office of Science and Technology “to establish and maintain performance standards in accordance with the National Technology Transfer and Advancement Act of 1995 for, and test and evaluate law enforcement technologies that may be used by, Federal, State, and local law enforcement agencies.” The collection of this information is necessary for the operation of the CTP which governs the testing and evaluation of body armor for law enforcement officers.

   2. This is a new collection, and NIJ will use this information to determine compliance of body armor models with NIJ Standard-0101.06, Ballistic Resistance of Body Armor.

   3. At implementation of the newly enhanced CTP, the information will be collected in paper form. However, as soon as NIJ has an electronic system operational, collection will be done electronically in a web-based form via www.justnet.org.

   4. This is a new collection, and this information is not already available. The design of the forms ensures that there is no duplicate information requested.

   5. This information collection will not have a significant economic impact on a substantial number of small entities.

   6. The operation of the CTP would not be possible without this information collection. The information requested has been minimized as much as possible yet still enabling NIJ to perform all activities required to ensure body armor is safe, reliable, and meets performance requirements.

   7. The only special circumstances relevant to the CTP are detailed below:

      • CTP Applicants (armor manufacturers) are required to submit three forms (the Ballistic Body Armor Model Application and Build Sheet, the Declaration for Ballistic Body Armor, and the CTP Conformity Assessment Follow-Up Agreement) for each individual model submitting for testing through the CTP. These are not submitted at a regular interval but only when the applicant decides to submit a new model for testing.

      • Respondents are required to maintain records for a minimum of 5 years.

      • Respondents are required to commit to keeping proprietary information confidential.

      • Respondents agree to share armor model build sheets and testing results with the CTP, and the CTP has procedures for maintaining confidentiality of that information.

   8. Emergency approval of the CTP forms has been requested from OMB. The details of the revised standard were finalized in May 2008, and the forms could not be completed until then. Even though the standard is finished, testing to it cannot begin until these forms are approved for use. The CTP ensures that the body armor approved for Federally-subsidized purchase by law enforcement agencies around the country complies with the latest safety standards. Time is of the essence because manufacturers and labs are currently operating under an interim standard that is less effective at testing whether body armor will hold up over time under conditions of everyday wear. A federal register notice for the CTP forms has been submitted, and NIJ will carefully consider all input resulting from the public review. NIJ has routine contact with all body armor stakeholders to share information and solicit feedback. For example, a stakeholder workshop was held in May to describe the revised standard and CTP, and all stakeholder questions/comments were recorded and are being addressed by NIJ.

   9. There are no payments or gifts to respondents.

   10. No assurances of confidentiality are provided in the CTP forms.

   11. There are no questions of a sensitive nature as described in this question.

   12. The estimated number of respondents is 60, and the estimate time for completing each form is detailed below:

CTP Applicant Agreement: Estimated 50 respondents; 1 hour each;

Ballistic Body Armor Model Application and Body Armor Build Sheet: Estimated 50 respondents (estimated 250 responses) at 30 minutes each;

Declaration for Ballistic Body Armor: Estimated 50 respondents (estimated 250 responses) at 15 minutes each;

CTP Conformity Assessment Follow-up Agreement: Estimated 50 respondents (estimated 250 responses) at 15 minutes each;

NIJ-Approved Laboratory Application and Agreement: Estimated 8 to 10 respondents at 1 hour each.

The information requested on the forms is information that is already maintained by the respondents, and no new information must be generated to complete the forms. Therefore, the estimated time is based on the time required to read and complete the forms.

13. There are no start up or capital costs associated with this information collection because the information requested is already maintained by the respondents. There is an estimated cost increase in testing costs for the CTP applicants (armor manufacturers) due to increased testing required by the revised standard; however, this cost is unrelated to this information collection.

14. The information system for receiving and managing the information is already in place, and no additional staff members are anticipated at this time.

15. This is a new collection necessary for operation of the CTP and fulfilling its purpose to ensure that body armor used by law enforcement and corrections personnel is safe, is reliable, and meets the requirements of the standard.

16. The information collected will not be published or released in any way, except as may be required by federal law. A list of NIJ-approved test labs and a list of compliant armor models will be published on www.justnet.org.

17. This is not applicable.

18. There are no exceptions to the certification statement; however, it is noted that item 19 (i) on the 83I does not apply to this information collection.

1. Collection of Information Employing Statistical Methods

No statistical methods are being employed in this information collection.