0579-0165 2017 Ss

May 12, 2017
SUPPORTING STATEMENT
IMPORTATION OF HORSES, RUMINANTS, SWINE, AND DOGS;
INSPECTION AND TREATMENT FOR SCREWWORM
OMB NO. 0579-0165
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.
The Animal Health Protection Act (AHPA) of 2002 is the primary Federal law governing the protection
of animal health. The law gives the Secretary of Agriculture broad authority to detect, control, or
eradicate pests or diseases of livestock or poultry. The Secretary also may prohibit or restrict import or
export of any animal or related material if necessary to prevent the spread of any livestock or poultry pest
or disease. The AHPA is contained in Title X, Subtitle E, Sections 10401-18 of P.L. 107-171, May 13,
2002, of the Farm Security and Rural Investment Act of 2002.
Disease prevention is the most effective method for maintaining a healthy animal population and
enhancing APHIS’ ability to compete in the world market of animal and animal product trade. The
regulations under which APHIS conducts its disease prevention activities are contained in Title 9,
Chapter 1, Subchapter D, Parts 91 through 99 of the Code of Federal Regulations. These regulations
govern the importation of animals, birds and poultry, certain animal and poultry products, and animal
germplasm.
Screwworm is a pest native to tropical areas of South America, the Indian subcontinent, Southeast Asia,
tropical and sub-Saharan Africa, and the Arabian Peninsula, and causes extensive damage to livestock and
other warm-blooded animals. Screwworm was eradicated from the United States in 1966. However, in
July 1999, and again in February and March 2000, screwworm larvae were found in horses imported into
the United States from Venezuela and Argentina. Screwworm was also detected in 1997, 2007, and 2010
in dogs imported into the United States from Panama, Trinidad and Tobago, and Venezuela.
APHIS regulations ensure that horses, ruminants, swine, and dogs imported into the United States from
regions of the world where screwworm is known to exist are inspected and, if necessary, treated for
screwworm infestation. These animals must also be accompanied to the United States with a health
certificate stating that the above actions were taken. APHIS requires four documents to import horses,
ruminants, swine, and dogs from regions where screwworm is known to exist: an application for import
or in-transit permit (VS 17-129); a health certificate signed by a Federal veterinarian of the exporting
country; a declaration of importation with the importer, broker, and final destination information
(VS 17-29); and a quarantine reservation.
APHIS is asking OMB to approve, for an additional 3 years, its use of these information collection
activities in connection with its program to prevent the introduction of screwworm into the United States.

2. Indicate how, by whom, how frequently, 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.
APHIS uses the following information activities to ensure that horses, ruminants, swine, and dogs
imported into the United States from regions of the world where screwworm is known to exist are
inspected and, if necessary, treated for screwworm infestation.
Application for Import or In-Transit Permit (VS Form 17-129); (9 CFR 93.301(j), 9 CFR 93.304)
(Business) - Anyone wishing to import ruminants or swine into the United States must apply for a permit
via the completion and submission of a VS Form 17-129, Application for Import or In-Transit Permit.
The form is also required for the importation of horses from regions affected with contagious equine
metritis and for horses imported from Central America and the West Indies (9 CFR 93.304 and 9 CFR
93.319, respectively). The form is not required for the importation of dogs. The importer must describe
the type, number, and identification of the animals or products to be exported. It must also list the country
of origin, intended date and location of arrival, routes of travel, and destination of the animals or products.
The permit can only be used for the animals listed on the application. APHIS uses this information to
track, identify, and monitor animals and products entering the United States and to safeguard U.S.
livestock.
APHIS also uses the information in the permit application to issue to the importer a VS Form 17-135,
U.S. Permit to Import, which includes statements of import requirements with which the importer must
comply to import the animals specified. APHIS completes VS Form 17-135 to eliminate burden on the
public. The issued permit is valid for 14 days for horses, ruminants, and swine.
Request for Health Certificate; (9 CFR 93.301 (j), 9 CFR 93.404(a), 9 CFR 93.505(a),
9 CFR 93.600(a)(1)) (Foreign Government) (Business) - Importers are responsible for requesting
health certificates from foreign veterinary government officials for the animals to be exported to the
United States.
Health Certificates; (9 CFR 93.301 (j), 9 CFR 93.404(a), 9 CFR 93.505(a), 9 CFR 93.600(a)(1))
(Foreign Government) - Horses, ruminants, swine, and dogs entering the United States from regions
where screwworm is known to exist must be accompanied with a health certificate completed, signed, and
issued by a full-time salaried veterinary official of the exporting country. The certificate must state that
the animals have been thoroughly examined, that they have been treated with ivermectin, that any visible
wounds have been treated with coumaphos, and that the animals appear to be free of screwworm within
5 days of exportation. APHIS inspectors review the health certificates to ensure imported animals are in
compliance with U.S. regulations. APHIS does not require the importer to maintain records of this form.
For imported dogs that will be used for handling livestock, the health certificates must also state the dogs
were tested and, if necessary, treated for cestodes within 5 days of exportation to the United States. The
health certificates help APHIS safeguard U.S. livestock against screwworm infestation.
Declaration of Importation (VS 17-29); (9 CFR 93.301, 9 CFR 93.405, 9 CFR 93.505) (Business) Importers must prepare VS Form 17-29, Declaration of Importation, to declare the animals they are
bringing into the United States. Collected by (or provided from APHIS to) U.S. Customs officials, the
declarations of importation contain information on the port of entry; name and address of the importer;
name and address of the broker; number, breed, species, and purpose of import; and the name and
location of the animals’ recipient. The form alerts APHIS that certain animals will be entering the
United States and assists APHIS in preventing the entry of foreign animal diseases.

Quarantine Reservation, (9 CFR 93.301, 9 CFR 93.411, 9 CFR 93.504) (Business) - Brokers or
importers are responsible for contacting APHIS-approved quarantine facilities to reserve quarantine space
for horses, ruminants and swine imported into the United States. Reservations may be requested by mail,
email, or fax to the facility, and the requests must include the date and time of arrival, number and species
of animals, and form of payment for quarantine services. APHIS works closely with the quarantine
facilities to monitor the availability and use of quarantine space for imported animals.

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.
VS Forms 17-29 and 17-129 are available in fillable PDF format from the USDA APHIS forms website at
https://www.aphis.usda.gov/aphis/resources/forms/ct_vs_forms. Completed forms can then be submitted
by fax, mail, or email, or resaved in PDF and uploaded into the U.S. Customs and Border Protection’s
(CBPs) Automated Commercial Environment (ACE) Secure Data Portal. APHIS is involved with the
Government-wide utilization of the International Trade Data System (ITDS) via ACE to improve business
operations and further Agency missions. This will allow respondents to submit the data required by CBP
and its Partner Government Agencies (PGAs), such as APHIS, through a Single Window concept.
APHIS is also establishing a system known as e-File for CARPOL (Certification, Accreditation,
Registration, Permitting, and Other Licensing) activities. This new system will strive to automate some of
these information collection activities. The system is still being developed and business processes
continue to be identified and mapped.
The VS Form 17-29 also can be processed via the VS Process Streamlining (VSPS) data entry system
(https://vsapps.aphis.usda.gov/vsps/public/Login.do). The VS Form 17-129 also can be processed via
APHIS ePermits at http://www.aphis.usdu.gov/permits/login_epermits.shtml.
Foreign health certificates require original signatures and official stamps or seals and thus are not
candidates for electronic submission at this time.
Quarantine reservation requests may be submitted in writing via mail, email, or fax to the APHISapproved quarantine facility.

4. Describe efforts to identify duplication. Show specifically why any similar information already
available cannot be used or modified for use for the purpose described in item 2 above.
The information APHIS collects in connection with this program is the absolute minimum necessary to
effectively ensure animals imported from certain regions pose a negligible risk of introducing screwworm
into the United States. APHIS is the only U.S. agency responsible for preventing the introduction of
exotic animal diseases and parasites into the United States; the information is not available from any other
source.

5. If the collection of information impacts small businesses or other small entities, describe any
methods used to minimize burden.
APHIS has determined that approximately 98 percent of the business respondents to this information
collection are small businesses. The burden outlined in Question 2 above are the absolute minimum
processes for gathering the information required by USDA. Importers are responsible for completing the
forms or requests as they are the only entities with access to the information required to complete them.

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 burden.
If the information was collected less frequently or not collected at all, APHIS would not be able to ensure
horses, ruminants, swine, and dogs imported into the United States are not infested with screwworm. Less
frequent information collections would allow a screwworm incursion to be much more likely, severely
damaging the U.S. equine, cattle, and swine industries who would be financially burdened by the
consequential loss of critical export trade.

7. Explain any special circumstances that require the collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5.
• 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 of 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.
No special circumstances exist that would require this collection to be conducted in a manner inconsistent
with the general information collection guidelines in 5 CFR 1320.5.

8. 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 recordkeeping,
disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported. If
applicable, provide a copy and identify the date and page number of publication in the Federal
Register of the agency's notice, soliciting comments on the information collection prior to
submission to OMB.
APHIS engaged in productive consultations with the following individuals in connection with the
importation of animals and their inspection and treatment for screwworm:
Selwyn Wallace
IRT USA
1525 Kautz Road, Suite 1600
West Chicago, IL 60185
310-306-0262
Louis J. Marino
Alex Nichols Agency
3800 Hampton Rd
Oceanside, NY 11572
516-678-9100
Chris Santarelli Mersant Intl. Ltd.
Worldwide Horse Transporters
158-12 Rockaway Blvd.
Jamaica, NY 11434
347-632-3004
On Monday, January 23, 2017, APHIS published in the Federal Register on pages 7791 and 7792 a
60-day notice seeking public comments on its plans to request a 3-year renewal of this collection of
information. No comments from the public were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of
contractors or grantees.
This information collection activity involves no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
No additional assurance of confidentiality is provided with this information collection. However, the
confidentiality of information is protected under 5 U.S.C. 552a.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior
or 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.
This information collection activity asks no questions of a personal or sensitive nature.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of
respondents, frequency of response, annual hour burden, and an explanation of how the burden
was estimated.
See APHIS Form 71.
• Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories.
APHIS estimates the total annualized cost to the respondents to be $26,951.93. Respondents are full-time
salaried veterinary officers of the exporting regions and animal importers. APHIS arrived at this figure by
multiplying the total burden hours (827) by the estimated average hourly wage of the respondents ($32.59).
The average hourly wage for respondents show above ($32.59) was determined by taking the average of
hourly rates for foreign veterinary officers ($41.71) (http://www.salaryexpert.com), and importers ($23.47)
(http://www.bls.gov/oes/current/oes_stru.htm).

13. Provide estimates 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).
The cost estimates should be split into two components: (a) a total capital and start-up cost component
annualized over its expected useful life; and (b) a total operation and maintenance and purchase of
services component.
No annual cost burden is associated with capital and startup costs, operation and maintenance expenditures,
and purchase of services. There are user fees associated with import permit applications, quarantines, and
inspections.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the
method used to estimate cost and any other expense that would not have been incurred without this
collection of information.
See APHIS Form 79. The estimated annualized cost to the Federal Government is $322,443.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the
OMB Form 83-l.

Requested

Annual Number
of Responses
Annual Time
Burden (Hr)

Change Due
Program
Program
Change Due
to
Change Due Change Due
to Potential
Adjustment
to New
to Agency
Violation of
in Agency
Statute
Discretion
the PRA
Estimate

Previously
Approved

5,359

0

3,422

0

0

1,937

827

0

342

0

0

485

In this renewal, respondents stayed the same at 92, annual responses increased from 1,937 to 5,359, and
total burden hours increased from 485 to 827.
As indicated in the table above, a total of 3,422 additional responses were due to discretionary program
changes, mainly the addition of three new burdens as the program refined its identification of burden
during the review. These same changes also resulted in 342 additional burden hours. The three new
burdens are the importers’ requests for health certificates; submission of the VS Form 17-29; and a
requirement to schedule quarantine reservations. These were not captured previously. Specific details for
these burdens are shown below:
RESPONSES

REGS
93.301 et al
93.301 et al
93.301 et al

PREVIOUS
REASON
BURDEN
Request for Health
Certificate
0
VS 17-29
0
Quarantine Reservation __
0
0

NEW
BURDEN

DIFFERENCE

1,702
70
1,650
3,422

1,702
70
1,650
3,422

NEW
BURDEN

DIFFERENCE

TYPE OF
CHANGE
PROG
PROG
PROG

HOURS

REGS
93.301 et al
93.301 et al
93.301 et al

PREVIOUS
REASON
BURDEN
Request for Health
Certificate
0
VS 17-29
0
Quarantine Reservation _____ 0
0

170
7
165
342

170
7
165
342

TYPE OF
CHANGE
PROG
PROG
PROG

16. For collections of information whose results are planned to be published, outline plans for
tabulation and publication.
APHIS has no plans to publish the information collected in connection with this program.

17. If seeking approval to not display the expiration date for OMB approval of the information
collection, explain the reasons that display would be inappropriate.
APHIS is seeking approval not to display the expiration date on VS Forms 17-29 and 17-129. Both forms
are used in multiple OMB-approved information collections and therefore it is not practical to include an
OMB expiration date because of various expiration dates for each collection.

18. Explain each exception to the certification statement identified in the "Certification for
Paperwork Reduction Act."
APHIS can certify compliance with all provisions in the Act.

B. Collections of Information Employing Statistical Methods.
Statistical methods are not employed in this information collection activity.