Justification

Justification.doc

Defense Federal Acquisition Regulation Supplement (DFARS); Radio Frequency Identification Advance Shipment Notices

OMB: 0704-0434

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OMB Case 0704-0434

SUPPORTING STATEMENT



A. JUSTIFICATION


1. This is a request for extension of the information collection requirements currently approved under OMB Control Number 0704-0434. The estimated burden under this clearance remains unchanged at 31,556 hours.


This information collection requirement pertains to information DoD contractors must submit in the advance shipment notice to DoD for shipments requiring passive Radio Frequency Identification (RFID). DoD considers the RFID to be a strategic imperative, necessary to deliver supplies to the warfighter more quickly, while increasing visibility of materiel throughout the supply chain. The automated and sophisticated end-to-end supply chain, DoD is dependent upon the technology at the point of origin, the DoD commercial supplier.


2. DoD depots uses the information in the advance shipment notice to match the RFID tag data to the corresponding shipment upon arrival.


The information is collected under 252.211.7006 is necessary to because DoD needs the data element in the advance shipment notice to permit association of RFID tag data with the corresponding shipment.


3. Improved information technology is used to the maximum extent practicable. Contractors must use electronic means to submit the advance shipment notice in accordance with the procedures located at http://www.dodrfid.org/asn.htm.

4. As a matter of policy, DoD reviews the Federal Acquisition Regulation to determine whether adequate language already exists. This information collection does not duplicate any other requirement.


5. The information collection associated with small businesses is the minimum consistent with applicable laws, Executive Orders, regulations, and prudent business practices.


6. An advance shipment notice is required prior to any shipment of materiel containing RFID tag data. Less frequent collection of this information would not permit prompt association of the RFID data with the corresponding shipment and, therefore, would impair visibility of DoD assets.


7. Collection is consistent with the guidelines in 5 CFR 1320.5(d). The information is not collected in a manner that requires an explanation of special circumstances.


8. Public comments were solicited in the Federal Register on November 19, 2009, as required by 5 CFR 1320.8(d). No comments were received.


9. There will be no payment or gifts to respondents, other than remuneration of contractors under their contracts.


10. The information collected will be disclosed only to the extent consistent with prudent business practice, current regulations, and statutory requirements. No assurance of confidentiality is provided to respondents.


11. No sensitive questions are involved.


12. The following classes of supply delivered to the locations shown below were previously approved under OMB Control Number 0704-0434:


Classes of Supply (As defined in DoD 4140.1-R, DoD Supply Chain Materiel Management Regulation, AP1.1.11, except that bulk commodities are excluded from this requirement):


(1) Subclass of Class I - Packaged operational rations.


(2) Class II - Clothing, individual equipment, tentage, organizational tool kits, hand tools, and administrative and housekeeping supplies and equipment.


(3) Class VI - Personal demand items (non-military sales items).


(4) Class IX – Repair parts and components including kits, assemblies and subassemblies, reparable and consumable items required for maintenance support of all equipment, excluding medical-peculiar repair parts.


Delivery Locations:


(1) Defense Distribution Depot, Susquehanna, PA.


(2) Defense Distribution Depot, San Joaquin, CA.


A final rule published February 12, 2007 at 72 FR 6480 included additional commodities and locations that required the RFID requirements to the packaging of the following classes of supply to be delivered to the following locations:


Classes of Supply (As defined in DoD 4140.1-R, DoD Supply Chain Materiel Management Regulation, AP1.1.11, except that bulk commodities are excluded from this requirement):


(1) Class IIIP - preservatives, chemicals and additives.


(2) Class IV – Construction and barrier materials.


(3) Subclass of Class VIII – Medical Materials (excluding Pharmaceuticals, Biologicals, and Reagents).


Delivery Locations:


(1) Defense Distribution Depot, Albany, GA.


(2) Defense Distribution Depot, Anniston, AL.


(3) Defense Distribution Depot, Barstow, CA.


(4) Defense Distribution Depot, Cherry Point, NC.


(5) Defense Distribution Depot, Columbus, OH.

(6) Defense Distribution Depot, Corpus Christi, TX.


(7) Defense Distribution Depot, Hill, UT.


(8) Defense Distribution Depot, Jacksonville, FL.


(9) Defense Distribution Depot, Oklahoma City, OK.

(10) Defense Distribution Depot, Norfolk, VA.


(11) Defense Distribution Depot, Puget Sound, WA.


(12) Defense Distribution Depot, Red River, TX.


(13) Defense Distribution Depot, Richmond, VA.


(14) Defense Distribution Depot, San Diego, CA.


(15) Defense Distribution Depot, Tobyhanna, PA.


(16) Defense Distribution Depot, Warner Robins, GA.


(17) Air Mobility Command Terminal, Charleston Air Force Base, Charleston, SC.


(18) Air Mobility Command Terminal, Naval Air Station, Norfolk, VA.


(19) Air Mobility Command Terminal, Travis Air Force Base, Fairfield, CA.


There is no change in the estimate of public burden hours since the last submission in 2006. The estimated annualized cost per hour has increased from $13.30 to $15.50 based on FY 2009 General Schedule salary table.

Number of respondents: 25,500


Responses per respondent: 3,981


Total responses: 101,515,500


Hours per response: 1.12 seconds


Total burden hours: 31,556


Average wages: $15.50


Total public cost: $489,118.00


The estimated annual burden to the public:




*Number of Shipments



Number of Suppliers

Number of Advance Shipment Notices


Processing Time (Seconds)




Hours




**Burden

10

2,550

25,500

4,590,000

1,275

$ 19,762.50

50

2,550

127,500

7,650,000

2,125

32,937.50

500

11,475

5,737,500

5,737,500

1,594

24,707.00

5,000

5,100

25,500,000

25,500,000

7,083

109,786.50

15,000

2,550

38,250,000

38,250,000

10,625

164,687.50

25,000

1,275

31,875,000

31,875,000

8,854

137,237.00

Total

25,500

101,515,500

113,602,500

31,556

$489,118.00


* Processing time for 10 shipments in “Total # of Shipments/Year” were estimated to require 180 seconds of additional processing time based on manual entry of the data element via the website. Processing time for 50 shipments in “Total # of Shipments/Year” were estimated to require 60 seconds of additional processing time based on manual entry of the data element via the website. Processing time for 500, 5,000, 15,000 and 25,000 shipments in “Total # of Shipments/Year” were estimated to require one second of additional processing time based on automatic electronic transmittal of the data.


** Based on a GS-3, step 5 (equivalent)salary, plus 32.45 percent burden.


13. We do not estimate any annual cost burden apart from the hour burdens in items 12.


14. We estimate that it will not take the Government any additional time to review the advance shipment notices, because the matching of shipment information with RFID tag numbers on the advanced shipment notices will automatically be completed by computers.


15. This estimate of public burden hours remain the same.


16. Results of this information collection will not be published.


17. We do not seek approval to not display the expiration dates for OMB approval of the information collection.


18. There are no exceptions to the certification statement identified in Item 19 of OMB Form 83-I.


B. Collections of Information Employing Statistical Methods


Statistical methods will not be employed.


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