2900-0587 justification

Supporting Statement for Department of Veterans Affairs (VA)

Acquisition Regulation (VAAR) Clause 852.211-70,

Service Data Manual,

OMB No. 2900-0587

A. Justification

1. This Paperwork Reduction Act submission seeks renewal of Office of Management and Budget approval No. 2900-0587 for collections of information for both commercial and non-commercial item, service, and construction solicitations and contracts using clause 852.211-70, Service Data Manual. In the original approval, this clause was numbered 852.210-70. The clause number has been changed to 852.211-70 with no other changes.

2. VAAR clause 852.211-70, Service Data Manual, is used when VA purchases technical medical equipment and devices or mechanical equipment. The clause requires the contractor to furnish both operator’s manuals and maintenance/repair manuals with the equipment provided to the Government. This clause sets forth those requirements and sets forth the minimum standards those manuals must meet to be acceptable. Generally, this is the same operator's manual furnished with each piece of equipment sold to the general public and the same repair manual used by company technicians in repairing the company's equipment. The cost of the manuals is included in the contract price or listed as separately priced line items on the purchase order. The operator's manual will be used by the individual actually operating the equipment to ensure proper operation and cleaning. The repair manual will be used by VA equipment repair staff to repair the equipment.

3. Collection efforts do not involve the use of automation. There are no plans to use information technology to collect this data. The information is specific to each item of equipment and the information must accompany the delivery of the equipment. Offerors are required to provide specific information, unique to the product that they are offering, to show how that product is operated and maintained. However, the information could be furnished on disk or other electronic media.

4. There are no duplicated efforts. Each reporting situation is unique and the data that must be submitted is unique to the product being offered for sale to the Government.

5. There is no significant impact on small businesses.

6. Failure to collect the information would have a negative impact on VA. Without the information, VA would be purchasing equipment for which it would not have proper operating instructions. This could be hazardous to VA employees and to VA patients. In addition, without maintenance manuals, VA would be unable to make repairs to the equipment.

7.

a. The information is needed for each product offered rather than quarterly. The information is specific to the product offered and unique to that particular solicitation.

b. The information is submitted for each produce offered. The time for response is the same as the time for delivery of the equipment, which may be fewer than 30 days, especially for lower dollar value contracts or for commercial items. The information is normally standard company operating and service manuals and does not require any special preparation.

c. For most equipment procurements, two copies of the maintenance manual and two copies of the operating manual will be required. One set will remain with the equipment, while the other set will go to the biomedical engineer/maintenance shop for use in repairing the equipment at that location. When a procurement will result in the initial purchase of a particular make and model of an item of equipment, the purchase order will require the contractor to furnish three additional copies of the operating and maintenance manuals to VA’s Service and Reclamation Division for use in maintaining the equipment from that location.

d. There are no records retention requirements.

e. This is not a statistical survey.

f. This does not require the use of statistical data classification.

g. This does not include a pledge of confidentiality. However, if requested by the contractor, VA will agree to protect the material from unauthorized disclosure.

h. This does not require the submission of proprietary information. However, should a contractor believe the information is proprietary, VA will agree to protect the material from unauthorized disclosure.

8. Notice regarding use of this clause in all applicable solicitations was published in the Federal Register on March 18, 2010, page 13210. There were no comments received.

9. No payments or gifts will be provided.

10. No assurances of confidentiality will be provided to respondents. However, should a contractor believe the information is proprietary, VA will agree to protect the material from unauthorized disclosure.

11. The request for information does not include any questions of a sensitive nature.

12.

a. Estimated number of respondents: 15,000.

b. Estimated frequency of responses: One response for each contract awarded.

c. Estimated average burden per collection: 10 minutes.

d. Estimated total annual reporting burden: 2,500 hours.

e. Estimated annualized cost: $37,500 (2,500 hours at $15 per hour).

13.

a. There are no capital costs or operating or maintenance costs.

b. Costs are not expected to vary widely.

c. There are no equipment costs.

14. Estimated annualized cost to the Government: $12,800 (2,500 hours at $10 per hour plus $300 printing costs). The information is evaluated upon receipt. If acceptable, no further action is required.

15. There are no program changes.

16. The results will not be published.

17. This request seeks approval to not display the expiration date for OMB approval. This is an on-going requirement. VA has a continuing need for this information in order to operate and repair equipment purchased. VA expects to continue use of this clause indefinitely and an expiration date would only tend to confuse the public.

18. This submission does not contain any exceptions to the certification statements.

B. Collection of Information Employing Statistical Methods: Statistical methods will not be employed.