0704-0434 support statement (07-11-13)

OMB Information Collection 0704-0434

Radio Frequency Identification (RFID)

SUPPORTING STATEMENT

A. Justification

1. Requirement. This is a request for extension of OMB Control Number 0704-0434, that will expire on July 31, 2013. DoD proposes that OMB extend its approval for use through July 31, 2016. The estimated burden under this clearance is decreased from 31,556 hours to 3,354. The significant decrease is based on the use of actual data pulled from the Wide Area Work-Flow system (WAWF) in place of the previous estimates, which were developed during a period of significant ramp-up for in theater deliveries. 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. Purpose. DoD depots use the information in the advance shipment notice to match the RFID tag data to the corresponding shipment upon arrival. The information collected under 252.211-7006 is necessary because DoD needs the data element in the advance shipment notice to permit association of RFID tag data with the corresponding shipment.

3. Information Technology. 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 https://wawf.eb.mil/.

4. Duplication. 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. Small Business. The collection is not expected to have a significant impact on a substantial number of small businesses. The burden applied to small business is the minimum consistent with applicable laws, Executive Orders, regulations, and prudent business practices.

6. Consequences for Non-Collection. 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. Special Circumstances. There are no special circumstances for collection. Collection of this information is consistent with the guidelines at 5 CFR 1320.5(d)(2).

8. Public Comments and Consultation. Collection is consistent with the guidelines in 5 CFR 1320.6. Public comments were solicited in the Federal Register at 78 FR 20624 on April 5, 2013. No comments were received in response to this notice.

9. Payment to Respondents. No payment or gift will be provided to respondents, other than remuneration of contractors under their contracts.

10. Confidentiality. This information is disclosed only to the extent consistent with prudent business practices, current regulations, and statutory requirements.

11. Sensitive Questions. No sensitive questions are involved.

12. Estimates of Public Burden Hours and Associated Annualized Cost. The following classes of supply delivered to the locations shown below were previously approved under OMB Control Number 0704-0434:

(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 IIIP – Packaged petroleum, lubricants, oils, preservatives, chemicals, and additives.

(4) Class IV – Construction and barrier materials.

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

(6) Subclass of Class VIII – Medical materials (excluding pharmaceuticals, biologicals, and reagents – suppliers should limit the mixing of excluded and non-excluded materials).

(7) 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; and

Delivery Locations: Are listed at http://www.acq.osd.mil/log/sci/RFID_ship-to_locations.html

Logistics and Material Readiness/Supply Chain Integration (LMR/SCI), the OSD Directorate that has ownership of the RFID program, has confirmed that the data utilized in this renewal to reflect the actual submissions in WAWF is consistent with the current collection requirement.

Number of respondents:5,450

Responses per respondent:1,640

Total responses:8,940,996

Hours per response:1.35 seconds

Total burden hours:3,354

Average wages:$16.16

Total public cost:$54,201

The estimated annual burden to the public:

*Number of Shipments	Number of Suppliers	Number of Advance Shipment Notices	Processing Time (Seconds)	Hours	**Burden
1 to 10	1,597	6,448	1,160,640	322	$5,210
11 to 50	1,305	33,547	2,012,820	559	$9,035
51 to 500	1,788	311,822	311,822	87	$1,400
501 to 5000	608	897,489	897,489	249	$4,029
5001 to 15000	81	679,041	679,041	189	$3,048
Over 15000	71	7,012,649	7,012,649	1,948	$31,479
Total	5,450	8,940,996	12,074,461	3,354	$54,201

*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 an FY2012 GS-3, step 5 (equivalent)salary, plus 36.25 percent burden. The estimated annualized cost per hour has increased from $15.50 to $16.16.

13. Estimated Nonrecurring Costs. None.

14. Estimated Annual Cost to the Government. 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. Program Changes. This is a request for extension of a currently approved collection. There no change in the estimates of public burden.

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

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

18. Certification. There are no exceptions to the certification accompanying this Paperwork Reduction Act submission.

B. Collections of Information Employing Statistical Methods.

Statistical methods will not be employed.