PAPERWORK REDUCTION ACT SUBMISSION UNDER 5 CFR PART 1320
INFORMATION COLLECTION 2133-0535, Elements of Request for Course Approval
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.
Section 109 of the Maritime Transportation Security Act of 2002 (MTSA) (P.L. 107-295) required the Secretary of Transportation to develop “standards and curriculum to allow for the training and certification of maritime security professionals.” The Secretary of Transportation delegated this mandate to the Maritime Administration (MARAD) and the United States Merchant Marine Academy, which developed the required standards and curriculum. To assist parties implementing the education and training provisions of the MTSA, MARAD, in conjunction with the U.S. Coast Guard, developed a voluntary program of maritime security course approval. This program, in which course providers submit their course curricula and descriptions of their operations for review, provides a means through which providers may have their courses approved as incorporating the standards and curriculum developed under Section 109 of the MTSA.
This collection satisfies the Secretary of Transportation’s National Security goal.
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.
The information provided is used by the Maritime Administration and the United States Coast Guard to review maritime security training courses and determine if they meet the standards and curriculum developed under Section 109 of MTSA. MARAD uses the information to monitor courses available nationwide.
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. Also describe any consideration of using information technology to reduce burden.
MARAD has established a system for electronic submission of information by course providers. Communication regarding the status of submissions and the granting or denial of certification is conducted electronically. Almost all submissions have been sent electronically; however, there is an alternative method of manual submission used by respondents for whom electronic submission would constitute a burden.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in item 2 above.
MARAD had never collected information from maritime security training course providers before. It has been determine that the data being requested from the applicants is unique to the program. There is no duplication.
5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
Several businesses or other small entities are among the respondents to this collection. To minimize the burden of providing the information to be collected, MARAD uses electronic submission procedures. Furthermore, the content of the information collection will be based on widely available model courses that provide explicit guidance on the content expected in applications for course approval.
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 the burden.
If this collection is not conducted maritime security personnel who must comply with the regulations will lack key information on where to obtain this training. The MTSA regulations require training for maritime security personnel. This information collection program facilitates the training of maritime security personnel by informing facility and vessel operators which training course providers meet the MTSA Section 109 training and curriculum standards.
7. Explain any special circumstances that would affect the manner of information collection.
Explain any special circumstances that would cause an information collection to be
conducted in a manner:
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 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.
There are no special circumstances that require the collection of information to be conducted in a manner described above.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
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 record-keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
MARAD published a 60-day notice and request for comments on this information collection in the Federal Register on June 25, 2014 (79 FR 36120, No. 122), indicating comments should be submitted on or before August 25, 2014. No comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
Respondents are not provided with any payment or gift for this information collection.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
There are no assurances of confidentiality provided to respondents as part of this information collection.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and 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.
The collection does not include any questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The statement should:
o Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated burden and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
o 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.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in item 14.
Responses Total Hours Total
Number of Per Responses Per Hours
Respondents Respondent Annually Response Annually
50 x 1.5 = 75 75 x 10 = 750
We estimate that each response will require 10 hours to complete: nine hours for drafting the request and assembling the accompanying material, and one hour to type, edit, and transmit the request. We assume that personnel equivalent to the levels of GS-12, at approximately $36.23 per hour, and GS-7, at approximately $20.43 per hour, will complete the request.
Cost Burden: 50 responses (9hrs x $36.23/hr +1hr x $20.43/hr) = $17,325
13. Provide an estimate 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).
There are no costs associated with this collection in addition to those described in Item 12.
14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from items 12, 13, and 14 in a single table.
The total annual cost to the Federal Government for processing the collection is estimated as follows:
Requests for course approval are processed by a private company, contracted with by the Maritime Administration. The value of this contract is $55,787.50. As the contractor handles all aspects of course approval, including reviewing requests, establishing a system for electronic submission, and conducting any necessary on-site visits, the cost of the contract constitutes the entire cost burden to the federal government.
15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB Form 83-I.
Since the last approval of this collection, there has been an increase in the number of providers whom submitted Maritime Security Training courses for approval.
16. For collections of information whose results are planned to be published for statistical use, outline plans for tabulation, statistical analysis, and publication. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates and other actions.
Not applicable. There are no plans to publish the results of the information collection for statistical purposes or for any other use.
17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
Not applicable. MARAD is not seeking such approval.
Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.
Not applicable. There are no exceptions to the certificate statement.
| File Type | application/msword |
| Author | yfields |
| Last Modified By | USDOT User |
| File Modified | 2014-11-14 |
| File Created | 2014-11-14 |