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SUPPORTING STATEMENT-OMB NO. 0579-0020

U.S. ORIGIN HEALTH CERTIFICATE

Terms of Clearance: In accordance with 5 CFR 1320, the information collection is approved for a period of 3 years. However, prior to submitting this collection for renewal, APHIS will review and evaluate the feasibility and practicality of implementing an electronic entry system for these forms that do not require the original signature and do not travel with shipments. APHIS should include this evaluation and a timeline for implementation in the renewal request.

APHIS is working on a pilot. The pilot involves a new “template” which will replace the forms listed in this information collection as well as a few others. This new template is fully electronic and housed in a system. APHIS developed the template and is adapting an existing electronic system and obtaining OMB approval (a new information collection is on the way). The template follows the World Trade Organization standards and has been approved by the governments of Canada, Taiwan, and China to name a few. This pilot will also incorporate APHIS’ new digital signature product. APHIS anticipates this pilot to be functioning within the next year.

2014

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

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 the 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.

The export of agricultural commodities, including animals and animal products, is a major business in the United States and contributes to a favorable balance of trade. As part of its mission to facilitate the export of U.S. animals and products, the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Veterinary Services (VS) maintains information regarding the import health requirements of other countries for animals and animal products exported from the United States. Disease prevention is the most effective method for maintaining a healthy animal population and for enhancing APHIS’ ability to compete in the world market of animal and animal product trade.

To ensure a favorable balance of trade, APHIS is seeking OMB approval to continue the use of the following burden items for an additional 3 years: 1) VS Form 17-140; 2) VS Form 17-140A; 3) VS Form 17-145; 4) Undue Hardship-Animals; 5) Application for Approval of Inspection Facility-Environmental Certification; 6) Opportunity to Present Views Concerning Withdrawal of Facility Approval; 7) Notarized Statement; and 8) Recording Modifications.

2. Indicate how, by whom, 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.

APHIS will use the following information collection activities to meet certification requirements of other countries for the export of animals from the United States.

U.S. Origin Health Certificate, VS 17-140, VS 17-140A, and VS 17-140B

The U.S. Origin Health Certificate is used in connection with the exportation of animals to foreign countries, and is completed by an authorized APHIS veterinarian using information obtained from owners or exporters of the animals. The information collected is used to establish that the animals are moved in compliance with USDA regulations, to verify that the animals destined for export are listed on the health certificate by means of an official identification, and to verify to the consignor and consignee that the animals being offered for export are healthy. The U.S. Origin Health Certificate also contains the results of various tests conducted on the animals (such as tests for tuberculosis or brucellosis) and the dates the tests were conducted. In addition, all goats and sheep intended for export from the United States must be identified by USDA-approved ear tags or tattoos. Goats and sheep destined for export to Canada or Mexico for immediate slaughter may be identified by flock brands. These ID’s must be recorded on the U.S. Origin Health Certificate that accompanies the animals to the receiving country.

The collection of this information helps prevent unhealthy animals from being exported from the United States, thereby preventing the international dissemination of animal diseases. The collection of this information is also necessary to satisfy the import requirements of the receiving countries, thereby facilitating trade between the United States and other regions of the world.

In addition to requiring certifications that attest to the health of individual animals, receiving countries may also require that the pre-export facilities in the United States be inspected, that procedures at the facility be approved, and that the animals be transported in cleaned and disinfected vehicles. Certifications that these conditions have been met are contained in the U.S. Origin Health Certificate. If these certifications were not provided, other countries would not accept animals from the United States.

U.S. Origin Health Certificate for the Export of Horses from the United States to Canada (VS Form 17-145)

This certificate is used in connection with the exportation of U.S. horses to Canada and is completed by accredited veterinarians using information obtained from owners and exporters of the animals. The information collected is used to establish that the animals are moved in compliance with USDA regulations, to verify that the animals listed for export are listed on the health certificate by means of an official identification, and to verify to the consignor and consignee that the animals being offered for export are healthy. The collection of this information helps prevent unhealthy animals from being exported from the United States, thereby preventing the international dissemination of animal diseases. The collection of this information is also necessary to satisfy the import requirements of Canada.

Undue Hardship-Animals

In special cases, certain ports (other than those officially designated in 9 CFR 91.14 as official ports of embarkation) may be designated as ports of embarkation by APHIS when the exporter can demonstrate, in writing, that the animals to be exported would suffer undue hardship if moved to an official port of embarkation. The explanation of undue hardship can be submitted to APHIS via letter, fax, or e-mail.

Application for Approval of Inspection Facility-Environmental Certification

Applications for approval of an export inspection facility must contain basic information such as the facility’s location, size, cleaning and disinfection procedures, testing and treatment capabilities, and other critical information. The application is completed by the facility operator and must be accompanied by a certification from local environmental authorities stating that the facility complies with all applicable State or local regulations or ordinances, and the requirements (if any) of the U.S. Environmental Protection Agency, in connection with the disposal of animal wastes. The facilities already have these compliance certificates as a result of doing business. These certification statements can be submitted to APHIS via fax or email.

Opportunity to Present Views Concerning Withdrawal of Facility Approval

APHIS can deny or revoke its approval of an export inspection facility, but must first send the facility’s operator a written notice at least 60 days before the date of the proposed revocation or denial. The facility operator can give APHIS a written explanation as to why approval should not be denied or revoked. This explanation can be submitted to APHIS via letter, fax, or email.

Notarized Statement

The owner or master of an ocean vessel used to export livestock from the United States must ensure that the vessel’s air supply system is such that each animal compartment is subject to an appropriate air exchange rate. A notarized statement to this effect must be obtained from the engineering company that designed the vessel’s air supply system, and this statement must be presented to an APHIS inspector when the vessel is used for the first time, or after the vessel has undergone substantive changes that might affect the air exchange rate in animal compartments.

Recording Modifications

Rail (wooden) stanchions used for pens aboard an ocean vessel for cattle or horses must be placed a certain distance apart and properly secured to the ship’s bulwark to ensure the safety and comfort of the animals during export. The method of securing and bracing these stanchions may be modified as approved by the underwriter of the cargo bureau and the APHIS inspector. Written information concerning these modifications must be provided to APHIS by the owner or master of an ocean vessel used to export livestock from the United States, on request, via hard copy, fax, or email.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, 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.

Currently, original signatures are required for the VS-Forms 17-140, 17-140A, 140B, and 17-145. The originals travel with the shipment; therefore, these forms are not candidates for electronic submission at this time.

However, APHIS is working on a pilot. The pilot involves a new “template” which will replace the forms listed above as well as a few others. This new template will be fully electronic and housed in a system. APHIS is in the process of developing the template, adapting an existing electronic system, and obtaining OMB approval. This new template will also incorporate APHIS’ new digital signature product.

The notarized statement that must be submitted to APHIS concerning the adequacy of a vessel’s air exchange rate can be emailed or faxed to APHIS.

The undue hardship letter, environmental certification statements that must accompany applications for facility approval, letters to contest a denial or revocation of facility approval, and records of vessel modifications can be emailed or faxed to APHIS.

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 in connection with the exportation of animals from the United States, including information contained on the U.S. Origin Health Certificate, is exclusive to APHIS’ mission of ensuring the health status of U.S. animals sent to other countries. It is not available from any other source.

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

The information APHIS collects is the minimum needed to ensure that U.S. exporters meet the minimum import requirements of other countries. Ten percent of the respondents to this collection are small businesses.

6. Describe the consequences 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.

The U.S. Origin Health Certificate, the proper identification of animals for export, and the approval of export inspection facilities in the United States are critical components of APHIS’ export program. Without these information collection activities, APHIS would be unable to certify the health status of animals exported from the United States to other countries. Without this certification, the United States would be unable to compete in the world market of animal trade.

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.

• requiring respondents to report informa­tion to the agency more often than quarterly;

• requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any docu­ment;

• requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years;

• in connection with a statisti­cal sur­vey, that is not de­signed to produce valid and reli­able results that can be general­ized to the uni­verse of study;

• requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB;

• that includes a pledge of confiden­tiali­ty that is not supported by au­thority estab­lished in statute or regu­la­tion, that is not sup­ported by dis­closure and data security policies that are consistent with the pledge, or which unneces­sarily impedes shar­ing of data with other agencies for com­patible confiden­tial use; or

• requiring respondents to submit propri­etary trade secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law.

No special circumstances exist. This information collection is conducted in a manner consistent with the guidelines established in 5 CFR 1320.6.

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.

APHIS engaged in productive consultations with the following individuals concerning its use of the information collections employed in the export of animals from the United States:

Greg Tyler

Vice President of Marketing

U.S.A. Poultry & Egg Export Council

2300 W. Park Place Blvd., Suite 100

Stone Mountain, GA 30087

770-413-0006

Paul Rodgers

Director of Policy

American Sheep Industry Association

Route 2, Box 94

Ronceverte, WV 24970

304-647-9981

Dr. Paul Sundberg

Senior Vice President – Science and Technology

National Pork Board

1776 NW 114^th Street

Des Moines, IA 50325

515-223-2764

On Friday, January 17, 2014, (pages 3163-3164), APHIS published in the Federal Register, a 60-day notice seeking public comments on its plans to request an extension of approval of this information collection. During that time, APHIS received one comment from the American Association of Exporters and Importers. Their comment was about making some of the forms electronic. APHIS is currently working on a pilot. The pilot involves a new “template” which will replace the three official forms in this information collection. This template will be fully electronic and housed in an electronic system. APHIS is in the process of developing the template, adapting an existing electronic system, and gaining OMB approval.

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

remuneration 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 and attitudes, religious beliefs, and others that are 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.

APHIS asks 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.

Respondents are the owners and facility operators for sheep, goats, and horses; accredited veterinarians; live animal exporters; and owners or masters of an ocean vessel. APHIS estimates the total annualized cost to these respondents to be $619,026.65. APHIS arrived at this figure by multiplying the total burden hours (17,611 hours) by the estimated average hourly wage of the above respondents ($35.15). The average hourly rate is derived from the U.S Department of Labor; Bureau of Labor Statistics May 2013 Report–National Compensation Survey: Occupational Employment and Wages, May 2012.

Owners of and facility operators for sheep, goats, and horses: $26.67 per hour [median, farmers, ranchers, and facility operators]

Owners or masters of an ocean vessel: $33.95 [median, owners or masters of an ocean vessel]

Accredited veterinarians: $44.83 per hour [median, accredited veterinarians]

13. Provide estimates of the total annual cost burden to respondents or record keepers 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.

No annual cost burden is associated with capital and startup costs, maintenance costs, and purchase of services in connection with this program.

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 estimated cost for the Federal Government is $1,135,031.44. (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.

	Requested	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate	Change Due to Potential Violation of the PRA	Previously Approved
Annual Number of Responses	72,755	0	1	0	0	72,754
Annual Time Burden (Hr)	17,611	0	1	0	0	17,610
Annual Cost Burden ($)	0	0	0	0	0	0

The total burden hours increased 1 hour and the total number of responses increased by 1 response due to adding 1 response to the Notarized Statement burden item as a placeholder. APHIS still hasn’t received a response even though it is offered and is in the regulations. In the last submission, APHIS had a zero. In addition, the number of respondents decreased from 2,056 to 1,393 due to double-counting in previous submissions (no actual change in the burden).

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to tabulate or publish the information APHIS is collecting.

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.

VS 17-140 is used in several other information collections; therefore, it is not practical to include an OMB expiration date because of the various expiration dates for each collection. APHIS is seeking approval to not display the OMB expiration date on this form.

APHIS will display the expiration date for VS Form 17-145, VS 17-1401A, and VS 17-140B.

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

APHIS is able to certify compliance with all the provisions of the Act.

B. Collections of Information Employing Statistical Methods

Statistical methods are not used in this information collection.

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