OMB# 1205-0342
Supporting Statement for U.S. Department of Labor ETA Form 9042A, Petition for Trade Adjustment Assistance and Alternative Trade Adjustment Assistance; ETA Form 9042A-1, Solicitud De Asistencia Para Ajuste; ETA 9043a, Revised Business Confidential Data Request; ETA 8562a, Revised Business Confidential Customer Survey; ETA 9118 Revised Business Confidential Non Production Questionnaire.
A. Justification:
This revision will consolidate all the data collection requests related to the Trade Adjustment Assistance (TAA) and Alternative Trade Adjustment Assistance (ATAA) petition investigation process. This includes the collections currently under 1205-0342 (ETA Form 9042A Petition for Trade Adjustment Assistance and Alternative Trade Adjustment Assistance, ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey, and ETA 9118 Business Confidential Non Production Questionnaire). ETA 9018 is no longer used and is eliminated from the current collection. In addition, ETA 9118 Business Confidential Non Production Questionnaire, currently approved under 1205-0447, will be consolidated under 1205-0342. As a result of this consolidation, OMB 1205-0447 will be cancelled upon approval of OMB 1205-0342.
Section 221 (a) of Title II, Chapter 2 of the Trade Act of 1974, as amended by the Trade Act of 2002, authorizes the Secretary of Labor and the Governor of each State to accept petitions for certification of eligibility to apply for adjustment assistance. The petitions may be filed by a group of workers, its certified or recognized union or duly authorized representative, employers of such workers, one-stop operators or one-stop partners. ETA Form 9042A, Petition for Trade Adjustment Assistance and Alternative Trade Adjustment Assistance, and its Spanish translation, ETA Form 9042a-1, Solicitud De Asistencia Para Ajuste, establish a format that may be used for filing such petitions. Regulations regarding petitions for worker adjustment assistance may be found at 29 CFR 90.
The ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey and ETA 9118 Business Confidential Non-Production Questionnaire are undertaken in accordance with Sections 222, 223 and 249 of the Trade Act of 1974, as amended by the Trade Act of 2002, which require the Secretary of Labor to certify groups of workers as eligible to apply for worker trade adjustment assistance (TAA). A determination of eligibility is reached after reviewing all the information obtained for each petition for worker adjustment assistance filed with the Department. The information collected in these data collections is necessary for the Secretary to specifically determine to what extent, if any, increased imports have impacted the selling market of petitioning workers’ firm, or a shift in production outside the United States, and thus determine whether the statutory criteria of eligibility to apply for TAA and ATAA are met.
The collection of the information in ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey, and ETA 9118 Business Confidential Non-Production Survey is mandatory. Section 249 of the Trade Act of 1974 provides the Secretary of Labor Subpoena authority to collect this or any information necessary to issue a worker group determination.
The information contained in a properly executed ETA Form 9042A or 9042A-1 will provide the basis for which the Governor and the U.S. Department of Labor will accept a petition. Within 40 days of receipt of the petition, the Department of Labor will determine if the petition meets statutory criteria, and if so, issue to workers covered by the petition a certification of eligibility to apply for assistance. Without the petition, there would be no orderly application process to apply for trade adjustment assistance, resulting in erroneous or incomplete and/or illegible handwritten petitions, which in turn would cause considerable delays in processing of the petitions.
The information obtained by the use of the ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey, and ETA 9118 Business Confidential Non-Production Questionnaire is used by the investigative workgroup of the Division of Trade Adjustment Assistance (DTAA). The findings present an objective set of facts to the Director of the DTAA, other Employment and Training Administration (ETA) officials and the Secretary of Labor with which to make timely decisions regarding whether imports of products like or directly competitive with those produced by the petitioning workers’ firm contributed importantly to its sales, production, and employment declines, and in turn, determine whether the petitioning workers meet the statutory criteria for eligibility to apply for TAA and ATAA.
The ETA 9042a is available to the public on the internet at www.doleta.gov/tradeact. Petitioners usually submit the petition simultaneously to the Department of Labor and to the State agency via mail or FAX transmission. In addition, an electronic petition filing application has been developed that will allow for users to go to the DTAA website, complete the application online, sign the petition electronically and then click a button that will result in simultaneous transmission of the petition to both the Department of Labor and the relevant State agency. It should be noted that the electronically filed petition application will not replace the paper petition, but will be available to provide an additional paperless option for those users who prefer it.
All five forms include places to provide electronic e-mail addresses in sections where contact information is requested. The use of electronic mail will facilitate quicker, more effective communication with respondents being asked to provide follow-up information, and provides an alternate method of contacting individuals when out-of-date or incorrect contact information is provided. This also moves toward meeting the Department’s goal of a paperless workplace.
DTAA currently sends the ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey, and ETA 9118 Business Confidential Non-Production Questionnaire primarily by e-mail or fax, or in circumstances where this equipment is not available to respondent, by first class or registered mail. The data collection constitutes part of the legal case file/administrative record maintained for each case investigation, and requires the signature of the official of the firm completing the form. Electronic signatures are acceptable.
For ETA Form 9042A Petition for Trade Adjustment Assistance and Alternative Trade Adjustment Assistance, ETA 9043a, Business Confidential Data Request, ETA 9118 Business Confidential Non Production Questionnaire, and ETA 8562a Business Confidential Customer Survey, no duplication exists. There is no similar information available.
The collection of this information does not significantly impact small business or small entities.
In order to minimize the burden placed on small businesses or other small entities by the 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey, ETA 9118 Business Confidential Non-Production Questionnaire, DTAA staff assist, by telephone, firms or entities experiencing difficulty in completing the questionnaire.
The petition and its Spanish translation are designed with the intent to be as simple as possible, taking only a few minutes to complete, and generally to be filled out by workers, employers or firm representatives.
Under provisions of the Trade Act of 2002, only 40 days are allowed, from the receipt of the workers' petition to make a determination of worker eligibility to apply for TAA and ATAA. In order for the 40-day statutory time limit to be met, DTAA must not only issue the Business Confidential Data Requests, Business Confidential Customer Surveys and Business Confidential Non-Production Questionnaires in successive order, but must obtain responses as quickly as possible after receipt of the petition. Thus, if the surveys were conducted less frequently, the Secretary would not be able to make the determinations as required by law.
The ETA Form 9042A Petition for Trade Adjustment Assistance and Alternative Trade Adjustment Assistance and its Spanish translation are consistent with the guidelines in 5 CFR 1320.5.
The ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey, and ETA 9118 Business Confidential Non-Production Questionnaire are not consistent with the guidelines in 5 CFR 1320.5, because the requested information is to be returned in less than 30 days. This is necessary in order to meet the 40-day statutory requirement discussed in Item number 6 above. Frequently, several different forms must be administered within the same 40 day period. Since these data collections are undertaken sequentially, respondents need to complete and return the form in less than 30 days.
The public has been given an opportunity to review and comment through the Federal Register notice process. The notice appeared on July 10, 2008. Comments were requested by September 8, 2008. The Department received no comments.
Based on past experience with all these forms, the format and content has been found to be acceptable and relatively easy to use by the respondents. The type and amount of information requested has been determined to be the minimum amount necessary to conduct a timely investigation.
9. There is no payment to respondents.
10. ETA 9042A does not contain personal or confidential data. Any information supplied by the respondent on 9043a, 8562a, and 9118 will be used by the Department to decide on applications for TAA and ATAA certifications. With the exception of the ETA-9042a, all information received by DTAA is treated as "business confidential" information (29 CFR 90.33, 5 U.S.C. 552, 18 U.S.C. 1905, 29 CFR part 70).
11. There are no questions of a sensitive nature.
12.INFORMATION COLLECTION #I: INVESTIGATIVE DATA COLLECTION REQUIREMENTS FOR THE TRADE ACT OF 1974 AS AMENDED BY THE TRADE ACT of 2002 ETA-9042a and 9042A-1 PETITION
It is estimated that in calendar year 2009 the Department will receive approximately 2,200 ETA-9042a petition forms. Since receipt of this form will trigger the issuance of all subsequent forms authorized under OMB 1205-0342, this number (2,200) is used as part of the calculation in establishing the burden hours and costs for all of the forms.
During the year, it is estimated that each ETA 9042A or ETA 9042A-1 (Spanish version) will require an average time burden of 25 minutes per petition. This total includes the estimated 20 minutes that it will take the respondent to complete the petition, and an additional 5 minute burden per petition for state agencies, including time to review petition for completeness.
2,200 respondents x 25 minutes = 55000 minutes or 917 hours
The annual cost to respondents for submitting the TAA and ATAA petition is estimated at $21,542. The petition form may be filed by 3 workers, a union representative, a company official or a community based organization. Therefore, the salaries could range from about $5.00 for a minimum wage employee to $300 per hour for a CEO, with an estimated average of $25.00.
The annual cost for the 2,200 petitions for State agency review is estimated at $3,217. This estimate is based on estimates on the $17.58 average hourly earnings for managerial and professional workers as reported in the Employment and Earnings Journal.
The annual cost for the 2,200 petitions for petitioners is estimated at $18,315. The petition form may be filed by 3 workers, a union representative, a company official or a community based organization. Therefore, the salaries could range from about $5.00 for a minimum wage employee to $300 per hour for a CEO, with an estimated average of $25.00.
SUMMARY OF BURDEN COST TO RESPONDENTS
2,200 respondents x 20 minutes x $25.00 per hour = $18,333
2,200 State reviews x 5 minutes x $17.58 per hour = $ 3,223 Total = $21,556
BREAKOUT OF FOUR TYPES OF RESPONDENTS WHO FILL OUT ETA-9042a
The table below further delineates the distribution of hour burden by breaking out categories of people filling out TAA petitions (ETA-9042A and 9042aA-1). In 2007, the latest year for which we have such data, a management information system (MIS) maintained by the Department of Labor for the purpose of tracking petition activity, calculated that 902 company officials, 594 groups of three or more workers, 440 state and local workforce staff, and 264 union officials representing workers filled out a petition:
Type of Petitioner |
Percent of Total |
Number of Respondents |
Type of Audience |
(Number)/Percent Type of Audience |
Company Official |
41% |
902 |
Private Sector |
(1166) 53% |
Unions |
12% |
264 |
||
State/Local Workforce Staff |
20% |
440 |
Public Sector |
(440) 20% |
3 or more workers |
27% |
594 |
Individuals or Households |
(594) 27% |
TOTAL |
100% |
2200 |
|
100% |
NOTE: A similar table is not provided for the subsequent information collections below because all forms in Information Collection #II are filled out by company officials or their representatives and are mandatory.
INFORMATION COLLECTION #II: BUSINESS CONFIDENTIAL DATA REQUEST, NON-PRODUCTION QUESTIONNAIRE, CUSTOMER SURVEY
An ETA 9043a is submitted to the company about 75% of the time when an ETA 9042a or ETA 9042a-1 is received; the form is used in instances where the petitioning worker group produces a product. To estimate the burden hours, DTAA used a random sample of past responses to TAA confidential data responses. It is estimated that the revised form 9043a should take 3.5 hours per response. Using the average, ETA estimates a total of 5,775 hours in response time.
(3.5 hours X 1,650 responses = 5,775 hours)
In order to determine the annualized cost, DTAA first noted the job titles of a sample of respondents to questionnaires. The majority of the respondents were employed in the administrative office of the firm. Next, estimates of their hourly earnings were determined by using the Occupational Outlook Handbook 2006-07. The earnings per hour ranged from an estimated $12.00 for bookkeepers, $18.00 for accountants, to $24.00 for business lawyers. DTAA estimates the average hourly earnings for these categories are $18.00, resulting in a total annualized cost to the 1,650 respondents of $103,950.
SUMMARY OF BURDEN COST TO RESPONDENTS
ETA 9043a ($18.00 per hour X 3.5 hours X 1,650 responses = $103,950)
Using a sample of cases requiring customer surveys, DTAA approximates that about 4 customer surveys will be sent for each ETA 9042a under investigation, leading to a total of 8,800 survey questionnaires to be sent. (Four customers reducing purchases from the subject firm represents an average number used to represent the subject firm’s sales decline). This estimate is upward biased as it considers the number of surveys sent to customers, not the number of respondents.
DTAA used a random sample of responses to a question on the form itself, asking the amount of time spent filling out the form, on the survey to calculate the hour burden. The hour burdens ranged from 1 to 6 hours with a sample mean of 1.78 hours, a median of 1.25 hours and a standard deviation of approximately 1.46 hours, per respondent. Using the average, DTAA estimates a total burden of approximately 15,664 hours for the 8,800 firms. It should be noted, however, that this total substantially overstates the time spent on the surveys since, unlike the Business Confidential Data Request, not all surveys are completed and returned. (Data are not available on the return rate for the surveys.)
(1.78 hours X 8,800 responses = 15,664 hours)
In order to determine the annualized cost, DTAA first noted the job titles of a sample of respondents to surveys. The majority of the respondents were employed in the administrative office of the firm. Next, estimates of their hourly earnings were determined by using the Occupational Outlook Handbook 2006-07. The earnings per hour ranged from an estimated $12.00 for bookkeepers, $18.00 for accountants, to $24.00 for business lawyers. DTAA estimates the average hourly earnings for these categories are $18.00, resulting in a total annualized cost to the 8,800 respondents of $281,952.
SUMMARY OF BURDEN COST TO RESPONDENTS
ETA 8562a ($18.00 per hour X 1.78 hours X 8,800 responses
= $281,952)
ETA 9118
An ETA 9118 Non Production Questionnaire is submitted to the company for each TAA petition filed on behalf of worker groups that exclusively provide a service, which represents about 25% of all ETA 9042a forms submitted on behalf of worker groups in 2007 (550 out of 2,200). To estimate the burden hours, DTAA believes the time necessary to complete an ETA 9118 Non Production Questionnaire is comparable to the 9043a Business Confidential Data Request, or 3.5 hours.
(3.5 hours X 550 responses = 1,925 hours)
In order to determine the annualized cost, DTAA first noted the job titles of a sample of respondents to questionnaires. The majority of the respondents were employed in the administrative office of the firm. Next, estimates of their hourly earnings were determined by using the Occupational Outlook Handbook 2006-07. The earnings per hour ranged from an estimated $12.00 for bookkeepers, $18.00 for accountants, to $24.00 for business lawyers. DTAA estimates the average hourly earnings for these categories are $18.00, resulting in a total annualized cost to the 550 respondents of $34,650.
SUMMARY OF BURDEN COST TO RESPONDENTS
ETA 9118 ($18.00 per hour X 3.5 hours X 550 responses
= $34,650)
13. There are no capital or start-up costs involved in the collection of the data for the petition form. The burden hours associated with editing, analyzing, validating in inputting the data are described in Item 12.
14. The annualized cost to the Federal Government for the ETA 9042A is $0.39 per petition, which is based on the actual unit petition cost to print and/or duplicate ($0.02) and distribute ($0.37) the petitions. Multiplying the cost of the petition by the number of respondents totals $858.
The annualized cost of the 9043a to the federal government is estimated at $3.24, or 5 minutes of staff time at a rate of $27 an hour. This estimate is based on the assumption that updating the relevant time periods on the form, printing and sending the questionnaire, requires five minutes of staff time at an approximate salary of $27 per hour.
The annualized cost to the federal government for each 8562a questionnaire is estimated at $3.24 for each form, or a total of $733. This is based on the assumption that it takes approximately 5 minutes of staff time, at a salary estimated at $27.00 per hour.
Cite/ Reference |
Staff Salary/Cost |
Number of responses |
Total |
ETA 9042A & ETA 9042A-1 |
$.39
|
2200 |
$858 |
ETA 9043a |
$3.24
|
1,650 |
$5,346 |
ETA 8562a
|
$3.24
|
8,800 |
$28,512 |
ETA 9118 |
$3.24
|
550 |
$1,782 |
TOTALS |
|
|
$36,498 |
This revision consolidates the data previously collected under two OMB numbers: 1205-0342 and 1205-0447. The ETA 9042A has an alternate online petition filing that includes additional instructions and a modified format, but the data elements collected and the verbiage used to collect the data remain the same. ETA 9043a Business Confidential Data Request, ETA 8562a Business Confidential Customer Survey and ETA 9118 Business Confidential Non Production Questionnaire have minor revisions designed to improve usability of the forms and to incorporate information that is essential to making determinations on TAA group eligibility.
Specific changes to forms include:
ETA 9042A (Electronic Petition Filing Application)
In this application, the petition instructions and data form are formatted to appear on several screens rather than the three pages that comprise the current petition format. This altered format is a necessary foundation for the future evolution of the application that will provide the capability for petition data to auto populate a petition database, thereby saving on manual data entry labor.
Two added instruction sections have been added to instruct users:
On fields that are required in order to file a valid petition. These required fields correspond to asterisks on the electronic petition that, if not completed, will result in an error screen. The user will also be prevented from moving forward in the application until they have completed the required fields.
On helpful online filing tips, including the disabling of the “back” buttons on the screens, options for attaching additional supporting documentation, and the identification of “help” tags to guide the user in providing requested responses.
In the electronic petition filing, modification of Section One of the petition corresponds to the response provided from the question that asks about the “type” of petitioner filing the petition as identified in the first question that appears on the petition. If the petition is filed by a company official, the data element asking for a professional title will be required rather than optional. If the petition is filed by workers, the application requires the identification and contact information for the statutory minimum of 3 petitioners. If the petitioner identifies him or herself as a union representative, then they must provide the name of the union that they represent. These modifications will help to guarantee that a valid petition is filed.
Help tags have been added to provide useful clarification and examples of data required, thereby minimizing the need for subsequent communication between the Department of Labor and the petitioner(s) regarding the data provided.
The ability to upload electronic files as supporting documentation to the data provided in the petition that is up to 2MB in MS Word, MS Excel, or PDF.
Prior to petition submission, an editable screen appears that will allow the user to view all of the information provided in the petition filing, along with the capability to make modifications as necessary, prior to submission.
In place of the manual signature available in the current petition format, a checkbox has been added at the end of the petition application to serve as an electronic signature. Checking the box signifies the user’s attestation as to the veracity of the information provided, including the identity of the petitioner(s) listed on the petition.
An additional screen that appears following successful submission of the petition, which:
Confirms the submission of the petition and subsequent transmission to the Department of Labor and relevant state agency,
Summarizes the TAA notification process in cases where the petition results in a group eligibility certification and identifies that TAA individual eligibility criteria must be established by applying through the local career one-stop center, and
Provides options for emailing copies of the petition, a strongly worded suggestion that the user print the petition and sign in manually in case of audit, and a link that allows the user to start a new (separate) petition.
ETA 9043a, ETA8562a, and ETA 9118
Information that provides context to the data request, including the date of compliance (usually 5 days from the date of the form transmission) along with the name and contact information of the DTAA investigator responsible for assessing the petitioning worker group’s eligibility.
Identification of specific countries responsible for company imports. This change was made to accommodate frequent Congressional inquiries regarding the sources of foreign trade that lead to TAA certifications.
Confidentiality Statement. This will expedite the process of data collection, since confidentiality is one of the issues addressed by the company officials.
A statement “Under penalty of law, I declare that to the best of my knowledge and belief the information I have provided is true, correct, and complete.” is on a current Petition Form and has been added to all the forms for consistency. It would also help the DTAA defend that the respondent is accountable for the information provided to the Department.
ETA 9043a only
Section 3 Organization Structure. This will help the investigator more clearly identify the worker group as defined in Section 113 (A)(a) and identify any linkages to other affiliated facilities that might be import impacted or already TAA certified.
Section 4 includes a request for North American Industry Classification System (NAICS) code. This information is necessary to better define the product and imports. It is also used to track the impacted trade-specific products in the Department’s database and other non-Department aggregate databases.
More detailed information regarding the period in which potential layoffs have occurred or will occur within the petitioning worker group. This will allow DTAA to more accurately assess whether the TAA group eligibility criterion of employment declines stipulated in Section 113 of the Trade Reform Act of 2002 have happened or will happen within the relevant period of the investigation.
Two open ended questions designed to elicit the specific reasons for layoffs and for any declines in sales or production performed by the petitioning worker group. These added clarifications are essential to helping DTAA establish whether employment and/or sales production declines have a causal link to increased imports or a shift in production, as mandated by the TAA group eligibility requirements found in Section 113 of the Trade Reform Act of 2002.
Section 7 Subject Location Exports is designed for analysis of customer purchases and more accurate import impact on production as required in Section 113 (2)(A)(ii)and (iii) of the Trade Act.
Section 8 is expanded to add information for two additional customers. This will reduce the time for collecting additional customer base if necessary and will allow a more detailed customer survey in order to establish import impact as outlined in Section 113 of the Trade Act.
Section 9 is specifically related to the ATAA program and is intended to reveal whether the worker group meets the eligibility requirement for ATAA found in Section 246 of the Trade Act, as amended.
ETA 9118
Six simple yes/no questions designed to establish whether service workers are under control of an unaffiliated production firm that is trade affected and therefore may be eligible for TAA group certification.
The changes proposed in this ICR will not affect the individual participant burden but the information collection budget will decline by 3,234 hours due to declining activity.
Notes on Total Number of Respondents for ETA 9042A, ETA 9043a, ETA 9118 and ETA 8562a
In connection with the proposed revision to OMB 1205-0342, there are three points worth noting in connection with the number of respondents and responses, as well as change in hour burden, indicated in the proposed revision. The first point clarifies why the number of “unique” respondents in the proposed revision differs from the total number of responses in two of the forms. The second point addresses incorrect respondent calculations that were identified in previous submissions for OMB 1205-0342, resulting in apparent inconsistency with the current proposed revision. The third point provides the exact calculations that result in the specific changes to the total hour burden for the proposed revision in comparison to the previously approved collection.
CLARIFICATION #1
The ETA 9042A Petition for Trade Adjustment Assistance and Alternative Trade Adjustment Assistance serves as the initiating document in all investigations for TAA group eligibility, and is completed and submitted by unique respondents. Similarly, the customers that complete the ETA 8562a do not complete any of the other forms authorized under OMB 1205-0342. As a result, the number of responses for each of these forms matches the number of respondents.
In contrast, it is estimated that 40% of the respondents to the ETA-9043a and the ETA-9118 are not unique respondents. That is because historical data shows that 40% of ETA 9042a petition forms are completed and submitted by the companies that employ the petitioning workers, and these same companies will be required to complete either the ETA-9043a or the ETA-9118 (depending on whether the petitioning worker group produced a product or performed a service).
Because 40% of the respondents that complete the 9042a will also complete ETA-9043a or ETA-9118, there is a resultant reduction in the number of respondents indicated for these two forms. The reduction is established by multiplying 2,200 (petitions received) by 60% (the proportion of unique respondents to the ETA-9043a and ETA-9118 combined).
Further, the ETA 9043a is completed by companies whose petitioning worker groups produce a product, while the ETA 9118 is completed by completed by companies whose worker groups provide a service. Historical data shows that 75% of all petitions submitted are on behalf of workers producing a product, and the remaining 25% of petitions represent worker groups that provide a service. This leads to a calculation that multiplies the 1320 unique respondents for the two forms combined by .75 and .25, respectively, in order to obtain the unique number of respondents for each of the two forms.
2200 x .60 = 1320 unique respondents for ETA 9043a and ETA 9118 combined
1320 x .75 = 990 respondents for ETA 9043a
1320 x .25 = 330 respondents for ETA 9118
The table below incorporates the numbers above in order to provide:
a comparison of responses and unique respondents for each form, and
relevant data that reveals how the total burden hours is a direct result of the formula:
# of responses x average time per response = hour burden
Cite/ Reference |
Responses |
Respondents |
Average Time per Response |
Total Requested Burden |
ETA 9042a & ETA 9042A-1 |
2,200 |
2200 |
0.4166 hours (25 minutes) |
917 hours |
ETA 9043a and ETA 9118 (combined total) |
2,200 |
1320* |
|
|
ETA 9043a |
1,650 |
990** |
3.5 hours |
5,775 hours |
ETA 9118 |
550 |
330*** |
3.5 hours |
1,925 hours |
ETA 8562a |
8,800 |
8,800 |
1.78 hours |
15,664 hours |
TOTALS |
13,200 |
12,320 |
|
24,281 hours |
* 1320 is 60% of 2200
** 990 is 75% of 1320
*** 330 is 25% of 1320
The reviewer will note that the ETA-9042A and the ETA 8562a have the same number of respondents as responses, while the ETA 9043a and the ETA 9118 do not.
CLARIFICATION #2
The number of respondents and responses in the current revision do not correlate to similar numbers for the 1205-0342 revisions that were published in November of 2005, as reflected in the previous Notice of Action for this collection. In the previous revision referenced, the total number of respondents and responses for all of the collections authorized by OMB 1205-0342 was counted as the total number of respondents for the ETA-9042a alone, thereby excluding counts for respondents and responses of the other forms included in the collections. As a result of this incorrect method of calculation, the number of respondents and responses in this revision is dramatically higher than the total of respondents and responses listed in the previous two submissions.
It should be emphasized that the burden hours in the 2005 submission was accurately calculated from correctly tabulated numbers provided in the supporting statement. Further, the change in burden hours in the proposed revision is the exclusive result of declining activity.
CLARIFICATION #3
The precise manner in which the declining activity affects the decreased number of burden hours is provided through the table below. The data table below makes clear:
how the estimated hour burden for each form results from the formula:
Responses (A) x Time Per Response (B) = Total Hour Burden (C),
how a tally in the hour burden provided in column (C) for each of the individual forms are summed to provide the total hour burden for both the previously approved 1205-0342 and the proposed revision, and
the resulting differences in the total hour burden for each of the two collections.
PROPOSED COLLECTION |
PREVIOUS COLLECTION |
||||||
|
A |
B |
C |
A |
B |
C |
|
Cite/ |
Responses |
Time Per Response |
Hour Burden |
Responses* |
Time Per Response |
Hour Burden |
|
ETA 9042a & ETA 9042A-1 |
2,200 |
0.4166 hours (25 minutes) |
917 |
3,030 |
0.4166 hours (25 minutes) |
1,262.5 |
|
ETA 9043a |
1,650 |
3.5 hours |
5,775 |
4,100 |
3.5 hours |
14,350 |
|
ETA 9118 |
550 |
3.5 hours |
1,925 |
NOT PREVIOUSLY PART OF OMB 1205-0342 |
N/A |
||
ETA 8562a |
8,800 |
1.78 hours |
15,664 |
6,560 |
1.78 hours |
11,677 |
|
ETA 9018 |
CANCELLED |
CANCELLED |
CANCELLED |
75 |
3.00 |
225 |
|
TOTALS |
13,200 |
|
24,281 hours |
|
|
27,515 hours |
|
* The response counts listed in this column correlate with the numbers provided in the Supporting Statement of the previous information collection request, and are different from the figures approved by OMB in the self-same collection; specifically, 3,030 total responses reflected in the Notice of Action for the 2005 approval. The discrepancy is the result of an error in the previous collection.
As the table above indicates, the difference in the total burden hours reflects a net reduction of 3,234 burden hours for the proposed revision:
27,515 (previous) – 24,281 (proposed) = 3,234
16. There are no plans to publish the data for this collection of information.
17. The expiration date for OMB approval of the information collection will be displayed on the report form.
There are no exceptions to Item 18.
18b. No statistical methods have been used for the collection of the data.
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| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |