Justification for Change

February 2015

Justification for Change:

Regulations for Voluntary Grading, Certification, and Standards - 7 CFR parts 54, 56, 62, and 70.

Authority 7 CFR Part 54, 56, 62, and 70

OMB Number 0581-0128

(Combining PY-32 and LS-313 into a single form LPS-109)

(Combining PY-100 and LS-315 into a single form LPS-110)

The following information provides justification for change to combine the forms PY-32 (Poultry) and LS-313 (Livestock) into a single form LPS-109 (Livestock, Poultry, and Seed) and forms PY-100 (Poultry) and LS-315 (Livestock) into a single form LPS-110 (Livestock, Poultry, and Seed). The PY-32, LS-313, PY-100 and LS-315 are currently approved as OMB 0581-0128. With these changes there is total of 12 hours increase in burden, with no changes to the number of respondents or responses.

The Agricultural Marketing Service (AMS) merged the Livestock and Seed Program and Poultry Programs into the Livestock, Poultry, and Seed Program (LPS). Following this merger the Program merged the Poultry Grading Branch and the Grading and Verification Division into the new Quality Assessment Division (QAD). Following this merger, QAD began merging three information collection packages into one and was successfully completed and approved by OMB on September 24, 2014. The forms PY-32 and LS-313 are both titled “Application for Service” and requests the same basic information from respondents therefore, one form the LPS-109 has been created by merging the information onto one form. The forms PY-100 and LS-315 are both titled “Work Schedule” and requests the same basic information from respondents therefore, one form the LPS-110 has been created by merging the information onto one form. The merger of these forms will allow QAD to eliminate unnecessary forms and any duplication of information.

The regulations in 7 CFR Part 54, 56, and 70 provide a voluntary program for grading, certification and standards of shell eggs, poultry products, rabbit products, meats, prepared meats, and meat products. The regulation in 7 CFR Part 62 - Quality Systems Verification Program (QSVP) is a collection of voluntary, audit based, user-fee funded programs that allow applicants to have program documentation and program processes assessed by QAD auditor(s) and other USDA officials. QSVP is user-fee programs based on the approved hourly rate established under 7 CFR Part 62. AMS also provides other types of voluntary services under these regulations, e.g., contract and specification acceptance services and verification of product, processing, further processing, temperature, and quantity. Because this is a voluntary program, respondents request or apply for the specific service(s) they wish, and in doing so, they provide information on the Application for Service form currently the PY-32 and LS-313 and the Work Schedule form currently the PY-100 and LS-315.

The Application for Service and Work Schedule forms are completed and submitted by applicants requesting QAD services and constitutes authorization for the Program to enter the establishment for the purpose of performing official functions under the regulations 7 CFR Part 54, 56, 62, and 70. It also serves as the legal agreement between the Program and the applicant, wherein the applicant agrees to abide by the applicable regulations and to pay for the services rendered at the hourly rates, as listed in the applicable regulations. In approving the Application for Service and Work Schedule Forms, the Program agrees to provide requested services under the regulations. All approved forms remain in effect indefinitely or until establishments submit new Application for Service and Work Schedule forms.

LPS-109 (previously LS-313 and PY-32) Application for Service:

All portions of the previous forms have been incorporated into the single form, LPS-109 Application for Service. The LPS-109 Application for Service is completed and submitted by a respondent when applying for grading service. It is the written contract/agreement between the Program and the respondent covering services provided under 7 CFR parts 54, 56, 62, and 70. The Office of the General Counsel requires this contract/agreement before the Program can provide voluntary services and allows the Program to collect the fees associated with these services as required by the Agricultural Marketing Act of 1946 (60 Stat. 1087-1091, as amended; 7 U.S.C. § 1621-1627)(AMA).

In making a single form, we are increasing the burden and response on the LS-313 to match the burden and response on the PY-32. Consequently, combining the forms into a single form will result in a slight increase for respondents requesting services covered under 7 CFR Part 54 and 62. The burden hours per response will increase from .10 hour to .25 hour resulting in the total burden hours increasing from 7.8 hours to 19.5 hours. Furthermore, there will be no change in the burden for respondents covered under 7 CFR parts 56 and 70.

LPS-110 (previously LS-315 and PY-100) Work Schedule:

All portions of the previous forms have been incorporated into the single form, LPS-110 Work Schedule. The LPS-110 Work Schedule is completed and submitted by a respondent when applying for grading service and provides the basis for regular and overtime hours of service and for the cost of the hours of voluntary service. It is part of the written contract/agreement between the Program and the respondent covering services provided under 7 CFR parts 54, 56, 62, and 70. The Office of the General Counsel requires a contract/agreement before the Program can provide voluntary services and allows the Program to collect the fees associated with these services as required by the Agricultural Marketing Act of 1946 (60 Stat. 1087-1091, as amended; 7 U.S.C. § 1621-1627)(AMA).

In making a single form, we are increasing the burden and response on the LS-315 to match the burden and response on the PY-100. Consequently, combining the forms into a single form will result in a slight increase for respondents requesting services covered under 7 CFR Part 54. The burden hours per response will increase from .20 hour to .25 hour resulting in the total burden hours increasing from 1 hour to 1.25 hours. Furthermore, there will be no change in the burden for respondents covered under 7 CFR parts 56, 62, and 70.