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SUPPORTING STATEMENT - OMB NO. 0579-0000

NATIONAL VETERINARY ACCREDITATION PROGRAM

August 19, 2009

Upon approval and activation of this new information collection, APHIS will retire 0579-0032.

RESPONSE TO COMMENT FILED ON THE PROPOSED RULE:

The previous ICR Reference Number is 200606-0579-002. A summary of all comments related to the new information collection requirements in the proposed rule and any changes made in response to these comments can be found in the draft final rule (uploaded in ROCIS). In response to OMB’s comment, APHIS has combined VS 1-36B and C into VS 1-36A; however, the burden hours have not changed because APHIS is still collecting information from the same 30,000 respondents. Currently, APHIS is only asking for the approval of one form

(VS 1-36A). A copy of VS 1-36A is uploaded in ROCIS.

A. Justification

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 Animal Health Protection Act (AHPA) of 2002 is the primary Federal law governing the protection of animal health. The law gives the Secretary of Agriculture broad authority to detect, control, or eradicate pests or diseases of livestock or poultry. The Secretary may also prohibit or restrict import or export of any animal or related material if necessary to prevent the spread of any livestock or poultry pest or disease. The AHPA is contained in Title X, Subtitle E, Sections 10401-18 of P.L. 107-171, May 13, 2002, the Farm Security and Rural Investment Act of 2002.

Disease prevention is the most effective method for maintaining a healthy animal population and for enhancing the United States’ ability to compete in the world market of animal and animal product trade.

The Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of Agriculture is the Agency charged with carrying out this disease prevention mission. However, because APHIS does not have sufficient numbers of Federal personnel to perform all of the disease prevention work that must be done, APHIS relies heavily on assistance from private veterinarians to perform specified functions.

APHIS administers the National Veterinary Accreditation Program. This voluntary program certifies private veterinary practitioners to work cooperatively with Federal veterinarians and State animal health authorities.

Producers who export animals rely on the expertise of accredited veterinarians to help ensure that exported animals will not introduce diseases into another State or country. The accreditation program has served the animal industry well for many years and remains integral to its future growth.

More than 60,000 active accredited veterinarians are currently listed in the national database. Accredited veterinarians are instrumental in increasing the capability of VS to perform competent health certifications and to maintain extensive disease surveillance and monitoring.

Regulations concerning the National Veterinary Accreditation Program are located in Title 9, Code of Federal Regulations. Part 161 of Subchapter J deals specifically with the requirements and standards for accredited veterinarians and the suspension and revocation of accreditation.

APHIS is amending these regulations to establish two accreditation categories in place of the current single category, to require accredited veterinarians to complete supplemental training modules, to require accredited veterinarians to receive written approval from APHIS prior to performing accredited duties in a different State, and to require renewal of accreditation every 3 years. These proposed changes are designed to increase the training and awareness of accredited veterinarians in the areas of disease surveillance, disease prevention, and preparedness for animal health emergencies in the United States.

Enhancing APHIS’ National Veterinary Accreditation Program in this way will necessitate revisions to the Application for Veterinary Accreditation.

APHIS is asking the Office of Management and Budget (OMB) to approve its use of these information collection activities for 3 years.

2. Indicate how, by whom, how frequently, 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.

Application for Veterinary Accreditation (VS Form 1-36A)

Veterinarians wishing to apply to APHIS for accredited status must complete and submit this form. The form requires the veterinarian’s name, the name of the veterinary school or college from which the applicant graduated and the year of graduation, the date veterinary accreditation orientation was completed and the State where it was completed, the applicant’s business address and mailing address, the applicant’s office number and home telephone number, the name of the county where the applicant is practicing, the type of practice (cattle, equine, small animal), the States in which the applicant is licensed to practice, and the applicant’s signature. Veterinarians renewing their accreditation, changing their contact information, or becoming re-accredited also completed this form.

This form has now been revised to require the applicant to indicate whether he/she is applying for Category 1 or Category II accreditation. Category I Accreditation is limited in scope to companion animals (pets) and related activities, while Category II Accreditation encompasses all animal species and accredited activities.

Category I accredited veterinarians would be certified to participate in disease surveillance activities and to issue international health certificates and domestic certificates for interstate movement of companion animals. APHIS believes this new category will give veterinarians who are interested in becoming accredited some additional flexibility. The responsibilities of Category II accredited veterinarians would be similar to the accreditation responsibilities as described under the current regulations.

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.

A fillable VS Form 1-36A will be made available on the VS Web site. The form can then be signed and mailed to the appropriate APHIS office.

APHIS is also developing a new module in their existing Veterinary Services Process Streamlining Information System where veterinarians will be able to fill out and electronically submit VS Form 1-36A directly to VS.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

The information that APHIS collects is not available from any other source. APHIS is the only Federal Agency that operates a National Veterinary Accreditation Program.

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

APHIS has no small entities involved with this information collection.

6. Describe the consequence 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 the information was collected less frequently or not collected, APHIS efforts to more aggressively prevent diseases and maintain a healthy animal population and enhance the U.S.’s ability to compete in the world market of animals and animal product trade. Because APHIS does not have sufficient numbers of Federal personnel to perform all of the disease prevention work that must be done, APHIS relies heavily on assistance from private veterinarians to perform specified functions.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

This information collection is conducted in a manner consistent with the guidelines established in 5 CFR 1320.5.

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 2009, APHIS engaged in productive consultations with the following individuals concerning the information collection activities associated with this program:

Jane Rowe

American Dairy & Goat Association

1114 Tupper Hall, University of California

Davis, California 95616

[email protected]

Peggy Logsdon

National Institute for Animal Agriculture

1910 Lyda Avenue

Bowling Green, Kentucky 42104

[email protected]

Dr. Alice Johnson

National Turkey Federation

1225 New York Ave. NW, Suite 400

Washington, DC 20005

(202) 898-0100

[email protected]

APHIS’ proposed rule (APHIS 2006-0093) was published in the Federal Register on Thursday, June 1, 2006, pages 31109-31121, with a 60-day comment period. During, that time, APHIS received 23 comments from interested members of the public. In response to those comments, APHIS published a supplemental proposed rule (APHIS 2006-0093) on February 27, 2007, pages 8634-8639, with the following changes: adjusted the scope of Category I and Category II accreditation, required initial accreditation training for all veterinarians seeking accreditation, required newly accredited veterinarians to renew their accreditation within 3 years of the initial accreditation training, and reduced the amount of training required for renewal of accreditation. During the second 60-day comment period, APHIS received another 15 comments from interested members of the public. APHIS is addressing these final comments in the final rule. A draft copy of the final rule is uploaded in ROCIS.

APHIS’ System of Records Notice (SORN) for the National Veterinary Accreditation Program (40 FR 38917-38918) is still valid until retired or replaced. APHIS is currently working on revising this SORN. The main difference between the current SORN and the proposed SORN is that APHIS is no longer going to be collecting social security numbers. Once the proposed SORN is published, OMB will receive a copy.

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration 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.

This information collection activity will ask no questions of a personal or sensitive nature.

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.

•Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

See APHIS Form 71. Burden estimates were developed from discussions with veterinarians who will be completing the form associated with this program.

•Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

APHIS estimates the total annualized cost to these respondents to be $904,200. APHIS arrived at this figure by multiplying the hours of estimated response time (30,000 hours) by the estimated average hourly wage of the above respondents ($30.14).

$30.14 is the hourly rate derived from the U.S. Department of Labor; Bureau of Labor Statistics May 2008 Report - Occupational Employment and Wages in the United States. See http://www.bls.gov/news.release/ocwage.t03.htm

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). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There is zero annual cost burden associated with capital and start-up costs, operation and maintenance expenditures, and purchase of services.

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

The annualized cost to the Federal government is estimated at $1,849,973. (See APHIS Form 79.)

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 are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to publish information it collects in connection with this program.

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.

Not applicable. APHIS will display the expiration date

18. Explain each exception to the certification statement identified in the "Certification for Paperwork Reduction Act."

APHIS can certify compliance with all provisions of the Act.

B. Collections of Information Employing Statistical Methods

There are no statistical methods associated with the information collection activities used in this program.