Accreditation of Commercial Testing Laboratories and Approval of Commercial Gaugers
1651-0053
A. Justification
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.
Commercial laboratories seeking accreditation or approval must provide the information specified in 19 CFR 151.12 to Customs and Border Protection (CBP), and Commercial Gaugers seeking CBP approval must provide the information specified under 19 CFR 151.13. This information may be submitted on CBP Form 6478. After the initial approval and/or accreditation, a private company may "extend" its approval and/or accreditation to add facilities by submitting a formal written request to CBP. This application process is authorized by Section 613 of Public Law 103-182 (NAFTA Implementation Act), codified at 19 U.S.C. 1499, which directs CBP to establish a procedure to accredit privately owned testing laboratories. The information collected is used by CBP in deciding whether to approve individuals or businesses desiring to measure bulk products or to analyze importations. Instructions for completing these applications are accessible at:
http://www.cbp.gov/about/labs-scientific/commercial-gaugers-and-laboratories. CBP Form 6478 is accessible at: http://www.cbp.gov/sites/default/files/documents/CBP%20Form%206478_0.pdf.
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.
This collection of information is used by CBP in deciding whether to approve individuals or businesses desiring to measure bulk products or to analyze importations.
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, 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.
There are fewer than 100 submissions per year for this information collection so it would not be cost effective to automate it. Respondents mail in their completed application.
4. 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.
This information is not duplicated in any other place or any other form.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not have an impact on small businesses or other small entities.
6. Describe consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
The collection of the information is critical in establishing the applicant's credentials so CBP can decide whether the applicant is qualified to test and analyze importations.
7. Explain any special circumstances.
This information is collected in a manner consistent with the guidelines of 5 CFR 1320.5(d)(2).
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.
Public comments were solicited through two Federal Register notices published on March 16, 2016 (Volume 81, Page 14120) and on June 17, 2016 (Volume 81, Page 39680) on which no comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
There is no offer of a monetary or material value for this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
A PIA for the Automated Commercial Environment (ACE) dated July 31, 2015, and a SORN for the Import Information System, dated August 17, 2015 (Vol. 80, Page 49256) will be included in this ICR. No assurances of confidentiality are provided to respondents.
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.
There are no questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information.
INFORMATION COLLECTION |
TOTAL ANNUAL BURDEN HOURS
|
NO. OF RESPONDENTS |
NO. OF RESPONSES PER RESPONDENT |
TOTAL ANNUAL RESPONSES
|
TIME PER RESPONSE
|
Reporting |
10 |
8 |
1 |
8 |
75 minutes (1.25 hours)
|
Record Keeping |
180 |
180 |
1 |
180 |
1 hour
|
Total
|
190 |
|
|
|
|
CBP lowered the number of responses to from 100 to 8, and raised the number of record keepers from 100 to 180 based on recent estimates.
Public Cost
The estimated cost to the respondents is $11,487.40. This is based on the estimated burden hours (190) multiplied by (x) the average loaded hourly wage rate for warehouse operators ($60.46). CBP calculated this loaded wage rate by multiplying the Bureau of Labor Statistics’ (BLS) 2014 median hourly wage rate for Transportation, Storage, and Distribution Managers ($41.06), which CBP assumes best represents the wage for warehouse operators, by the ratio of BLS’ average 2014 total compensation to wages and salaries for Management, Business, and Financial occupations (1.4725), the assumed occupational group for warehouse operators, to account for non-salary employee benefits.1,2
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There is an application fee for accreditation/approval. The fee of $575 multiplied (x) the number of respondents (8) = $4600.
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.
The estimated annual cost to the Federal Government associated with the review of the applications and records is $3003.7. This is based on the number of responses (8) that must be reviewed multiplied by (x) the time to review and process each application (2 hours) = 16 hours multiplied by (x) the average hourly loaded rate of a general CBP employee ($55.91)1 = $894.5.
Plus the time to conduct audit spot checks: the number of audits conducted per year (60) multiplied by (x) the time to conduct each audit (2 hours) = 120 hours multiplied (x) by the average hourly loaded rate of a general CBP employee ($55.91) = $6709.2.
Minus the application fee of $575 multiplied by (x) the number of respondents (8) = $4600. To summarize $894.5 + $6709.2 - $4600 = the Government cost ($3003.7).
15. Explain the reasons for any program changes or adjustments reported in Items 12 or 13 of this Statement.
CBP lowered the number of responses to from 100 to 8, and raised the number of record keepers from 100 to 180 based on recent estimates. There are no changes to the information collected.
16. For collection of information whose results will be published, outline plans for tabulation, and publication.
This information collection will not be published for statistical purposes.
17. If seeking approval to not display the expiration date, explain the reasons that displaying the expiration date would be inappropriate.
CBP will display the expiration date for OMB approval of this information collection.
18. “Certification for Paperwork Reduction Act Submissions.”
CBP does not request an exception to the certification of this information collection.
No statistical methods were employed.
1 CBP bases this wage on the salary and benefits of the national average of general, non-CBP Officer/frontline CBP positions, which is equal to a GS-12, Step 5. Source: Email correspondence with CBP’s Office of Administration on June 25, 2015.
1 Source of median wage rate: U.S. Bureau of Labor Statistics. Occupational Employment Statistics, “May 2014 National Occupational Employment and Wage Estimates, United States- Median Hourly Wage by Occupation Code: 11-3071.” Updated March 25, 2015. Available at http://www.bls.gov/oes/2014/may/oes113071.htm. Accessed June 15, 2015.
2 The total compensation to wages and salaries ratio is equal to the calculated average of the 2014 quarterly estimates (shown under Mar., June, Sep., Dec.) of the total compensation cost per hour worked for Management, Business, and Financial occupations (62.67) divided by the calculated average of the 2014 quarterly estimates (shown under Mar., June, Sep., Dec.) of wages and salaries cost per hour worked for the same occupation category (42.56). Source of total compensation to wages and salaries ratio data: U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation. Employer Costs for Employee Compensation Historical Listing March 2004 – December 2015, “Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 2004-2015 by Respondent Type: Management, business, and financial occupations.” June 10, 2015. Available at http://www.bls.gov/ncs/ect/sp/ececqrtn.pdf. Accessed June 15, 2015.
| File Type | application/msword |
| File Title | Supporting Statement |
| Author | Preferred Customer |
| Last Modified By | MEGAN, FREDERICK |
| File Modified | 2016-06-28 |
| File Created | 2016-02-22 |