1651-0006 Supporting Statement 2016

1651-0006 Supporting Statement 2016.doc

Application & Approval to Manipulate, Examine, Sample or Transfer Goods

OMB: 1651-0006

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Supporting Statement

Application and Approval to Manipulate, Examine, Sample or

Transfer Goods

1651-0006



A. 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.


CBP Form 3499, "Application and Approval to Manipulate, Examine, Sample or Transfer Goods," is used as an application to perform various operations on merchandise located at a Customs and Border Protection (CBP) approved bonded facility. This form is filed by importers, consignees, transferees, or owners of merchandise, and is subject to approval by the port director. The data requested on the form identifies the merchandise for which action is being sought and specifies the operation is to be performed. The form may also be approved as a blanket application to manipulate goods for a period of up to one year for continuous or repetitive manipulation. CBP Form 3499 is provided for by 19 U.S.C. 1562, and 19 CFR 158.43c, 19.8, 19.11 and is accessible at: http://forms.cbp.gov/pdf/CBP_Form_3499.pdf.

  1. 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 collected on Form 3499 is used by CBP to ensure that the examination, sampling, repacking or transferring of merchandise is performed under CBP supervision so that the appropriate amount of revenue is collected.


  1. 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.


This form is automated as part of the Document Image System. Document Image System (DIS) allows trade users to electronically submit images of documentation required by CBP or PGAs during the import and export process into ACE. This documentation includes general forms such as commercial invoices, packing lists, invoice working sheets, as well as forms to support cargo release (e.g., government issued identification, vehicle titles, and certificates). Trade users may also use DIS to submit agency specific forms such as licenses, permits, or regulatory certificates.

  1. 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 elsewhere.


  1. 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 a significant impact on small businesses.

  1. Describe 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.


If the information were collected less frequently, CBP would not be able to enforce regulatory requirements and ensure that the appropriate amount of revenue is collected.


  1. Explain any special circumstances


This information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(c)(2).


  1. 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 dated September 09, 2016 (Volume 81, Page 62519) on which no comments were received, and on November 29, 2016 (Volume 81, Page 85993) on which no comments have been received.


  1. 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.


  1. 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 (80 FR 49256) will be included in this ICR. No assurances of confidentiality are provided to respondents.


  1. 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 personal or sensitive nature.


  1. 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

RESPONSES


TIME PER

RESPONSE


Form 3499



15,114


2,519


60


151,140


6 minutes

(.1 hours)


Public Cost

The estimated cost to the respondents is $454,780.26. This is based on the estimated burden hours (15,114) multiplied by (x) the average loaded hourly wage rate for importers ($30.09). CBP calculated this loaded wage rate by first multiplying the Bureau of Labor Statistics’ (BLS) 2015 median hourly wage rate for Cargo and Freight Agents ($20.13), which CBP assumes best represents the wage for importers, by the ratio of BLS’ average 2015 total compensation to wages and salaries for Office and Administrative Support occupations (1.4799), the assumed occupational group for importers, to account for non-salary employee benefits.1,2 CBP then adjusted this figure, which was in 2015 U.S. dollars, to 2016 U.S. dollars by applying a 1.0 percent annual growth rate to the figure, as recommended by the U.S. Department of Transportation’s value of travel time guidance.3


  1. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.


There are no recordkeeping, capitalization or start-up costs associated with this collection.


  1. 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 these records is $964,273.20. This is based on the number of responses that must be reviewed (151,140) multiplied by (x) the time burden to review and process each response (.1 hours) = 15,114 hours multiplied by (x) the average hourly loaded rate for a CBP Officer ($63.80)4 = $964,273.20.


  1. Explain the reasons for any program changes or adjustments reported in Items 12 or 13 of this Statement.


There has been no increase or decrease in the estimated annual burden hours previously reported for this information collection. There are no changes to the information collected or to CBP Form 3499.

  1. 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.


  1. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


CBP will display the expiration date for OMB approval of this information collection.

  1. Explain each exception to the certification statement.


CBP does not request an exception to the certification of this information collection.


  1. Collection of Information Employing Statistical Methods


No statistical methods were employed.



1 Source of median wage rate: U.S. Bureau of Labor Statistics.  Occupational Employment Statistics, “May 2015 National Occupational Employment and Wage Estimates, United States- Median Hourly Wage by Occupation Code: 43-5011.”  Updated March 30, 2016.  Available at http://www.bls.gov/oes/2015/may/oes435011.htm. Accessed June 1, 2016. 

2 The total compensation to wages and salaries ratio is equal to the calculated average of the 2015 quarterly estimates (shown under Mar., June, Sep., Dec.) of the total compensation cost per hour worked for Office and Administrative Support occupations ($24.9475) divided by the calculated average of the 2015 quarterly estimates (shown under Mar., June, Sep., Dec.) of wages and salaries cost per hour worked for the same occupation category ($16.8575). 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 – March 2016, “Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 2004-2016 by Respondent Type: Office and administrative support occupations.” June 9, 2016. Available at http://www.bls.gov/ncs/ect/sp/ececqrtn.pdf. Accessed June 14, 2016.

3 Source: U.S. Department of Transportation, Office of Transportation Policy. The Value of Travel Time Savings: Departmental Guidance for Conducting Economic Evaluations Revision 2 (2015 Update), “Table 4 (Revision 2-corrected): Recommended Hourly Values of Travel Time Savings.” April 29, 2015. http://www.transportation.gov/sites/dot.gov/files/docs/Revised%20Departmental%20Guidance%20on%20Valuation%20of%20Travel%20Time%20in%20Economic%20Analysis.pdf. Accessed June 1, 2016.

4 CBP bases this wage on the FY 2016 salary and benefits of the national average of CBP Officer positions, which is equal to a GS-12, Step 4. Source: Email correspondence with CBP’s Office of Administration on June 27, 2016.

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File Modified2016-12-27
File Created2016-06-07

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