Supporting Statement 4-2-2020-Final

2020 SUPPORTING STATEMENT
SEED SERVICE TESTING PROGRAM
OMB NO. 0581-0140
A. JUSTIFICATION
1.

EXPLAIN THE CIRCUMSTANCES THAT MAKE THE COLLECTION OF
INFORMATION NECESSARY. IDENTIFY ANY LEGAL OR
ADMINISTRATIVE REQUIREMENTS THAT NECESSITATE THE
COLLECTION.
The Agricultural Marketing Act (AMA) of 1946 and regulations 7 CFR 75, thereunder
provide for the inspection and certification of quality of agricultural and vegetable
seeds in order to bring about efficient, orderly marketing and to assist the development
of new or expanding markets. Under the voluntary program, samples of agricultural
and vegetable seeds submitted to the Agricultural Marketing Service (AMS) are tested
for certain quality factors such as purity, germination, and noxious-weed seed content.
The items for which the seed is tested are designated by the company requesting the
service. A Seed Analysis Certificate-Sample Inspection or ISTA Orange International
Seed Lot Certificate is issued by AMS giving the test results. For the issuance of ISTA
Orange International Seed Lot Certificates, Seed Regulatory and Testing Division
(SRTD)-Authorized International Seed Testing Association (ISTA) Samplers sample
and submit seed samples to AMS. Most of the samples submitted represent seed
scheduled for export. Many importing countries require a Seed Analysis CertificateSample Inspection or an ISTA Orange International Seed Lot Certificate on seed from
the United States shipped into their country. The Seed Regulatory and Testing Division
of AMS, which tests the seed and issues the certificates, is the only Federal seed testing
facility that can issue the Seed Analysis Certificate-Sample Inspection.

2.

INDICATE HOW, BY WHOM, HOW FREQUENTLY, AND FOR WHAT
PURPOSE THE INFORMATION IS TO BE USED FOR REVISIONS,
EXTENSIONS, AND REINSTATEMENTS OF A CURRENTLY APPROVED
COLLECTION. INDICATE THE ACTUAL USE THE AGENCY HAS MADE
OF THE INFORMATION RECEIVED FROM THE CURRENT COLLECTION.
Application for Service (Request Process)
Companies are seed firms who use the certificates to represent the quality of seed lots
to foreign customers according to the terms specified in contracts of trade. An
Application for Service (Request Process) consists of a letter from companies providing
information needed for the service requested; information to identify the seed being
tested; the seed treatment (if treated); the tests to be performed, and any other
appropriate information required by the company to be on the Federal Seed Analysis
Certificate or the ISTA Orange International Seed Lot Certificate. Sampling
documentation will accompany the officially drawn sample submitted for testing. The
information provided by the company is included on the certificates, often to satisfy
requirements of importing countries or letters of credit. If the pertinent information
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were not collected, AMS would not know which tests to conduct and would not be able
to relate the test results with a specific lot of seed. The information must be provided
for each sample the company submits for testing. With this function of SRTDAuthorized ISTA Seed Sampler Program, Sampler records are kept on file for those
who sample seed for the issuance of ISTA Orange International Seed Lot Certificates.
This information is provided as a rule by ISTA in order to verify that the sample was
taken and submitted by an authorized Sampler. Without the AMS programs,
companies would have to obtain tests from state or commercial laboratories. Without
the programs, some importing countries would likely accept certificates from
commercial laboratories, while other countries would hold seed from the United States
at the port of entry until it is sampled and a test made by the importing country.
The Seed Analysis Certificate-Sample Inspection and the ISTA Orange International
Seed Lot Certificates are issued by AMS to report the seed quality factors from test
results in accordance with the request of the company. The Seed Analysis CertificateSample Inspection and the ISTA Orange International Seed Lot Certificates, completed
by AMS also contains information supplied by the company and the Sampler that is
accounted for in the burden hours. No form is used by companies to request the
service. Only pertinent items of information necessary to perform the inspection are
obtained with the company’s request.
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.
Normally the company or Sampler submits the information along with the sample that
is to be tested. The majority of information is transmitted by postal delivery or courier
service. If information is not provided with the sample, it is obtained from the
company or Sampler by telephone, facsimile (fax) transmissions, or electronic mail (email). The AMS, Science and Technology Programs, Seed Regulatory and Testing
Division is committed to complying with the E-Government Act, to promote the use of
the Internet and other information technologies to provide increased opportunities for
citizen access to Government information and services, and for other purposes.

4.

DESCRIBE EFFORTS TO IDENTIFY DUPLICATION. SHOW
SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY
AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE
PURPOSE(S) DESCRIBED IN ITEM 2 ABOVE.
No duplication occurs. The information obtained from the company or Sampler applies
to a single inspection. Each seed sample represents a single, specific quantity of seed.
Companies request service pertaining to a single seed lot identified with a mark or
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number. Information pertaining to one seed lot has no relationship to any other seed
lot. No useful information is available for a specific seed lot from any other source.
Information about the disposition of the seed analysis certificates, billing addresses, and
general instructions from the company are kept on file so they do not have to be
repeated with every inspection.
5.

IF THE COLLECTION OF INFORMATION IMPACTS SMALL BUSINESSES
OR OTHER SMALL ENTITIES (ITEM 15 OF THE PAPERWORK
REDUCTION ACT SUBMISSION FORM 83-1), DESCRIBE THE METHODS
USED TO MINIMIZE BURDEN.
The Small Business Administration defines, in 13 CFR part 121, small agricultural
producers as those having annual receipts of no more than $750,000 and small
agricultural service firms as those having annual receipts of no more than $7.0 million.
Under these definitions, the majority of seed companies that would be affected are
considered small businesses. We have estimated the number of companies for this
collection is 55 and we estimate that 42 are considered small businesses. Only
information necessary to identify the seed, the tests requested, and any seed treatment
present is requested. The same information is necessary for providing the service to
small businesses or to larger businesses. The voluntary service could not be provided
without the information.

6.

DESCRIBE THE 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 collection was made less frequently, the sampling, testing, and issuance of
certificates would be delayed since information on location and kind of seed to be
sampled and the type of tests desired by the company must be known before sampling
and testing is started.

7.

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;
The information must be collected each time a Sampler or company submits a
sample for testing because each sample is unique. If a company for the
voluntary service submits a sample and requests a test more than quarterly, the
information must be collected 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;

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Companies must provide the information when the sample is submitted. There
is no requirement that the company provide the information in less than 30 days.
However, the test cannot be made until the information is submitted, because
the laboratory must know which tests to perform.
-

REQUIRING RESPONDENTS TO SUBMIT MORE THAN AN
ORIGINAL AND TWO COPIES OF ANY DOCUMENT;
The company is not required to submit more than one copy of the information
with each sample.

-

REQUIRING RESPONDENTS TO RETAIN RECORDS, OTHER THAN
HEALTH, MEDICAL, GOVERNMENT CONTRACT, GRANT-IN-AID,
OR TAX RECORDS FOR MORE THAN 3 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;
No information is collected for statistical surveys or statistical data.

-

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
The collection does not include 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.

-

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 IS
CONFIDENTIALITY TO THE EXTENT PERMITTED BY LAW.
Occasionally information collected may contain trade secrets or other
confidential information. The confidentiality of that information is maintained
to the extent permitted by law. The Agency does not disclose information to
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anyone unless required to do so by the Freedom of Information Act (FOIA).
Most trade secrets and financial information do not have to be released under
the FOIA.
There are no other special circumstances. The collection of information is
conducted in a manner consistent with the guidelines in 5 CFR 1320.6.
8.

IF APPLICABLE, PROVIDE A COPY AND IDENTIFY THE DATE AND
PAGE NUMBER OF PUBLICATION IN THE FEDERAL REGISTER OF THE
AGENCYS 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.
A 60-day notice was published in the Federal Register on March 14, 2019, Vol. 84, No.
50, page 9290 which invited comments from interested persons. No comments were
received.
DESCRIBE EFFORTS TO CONSULT WITH PERSONS OUTSIDE THE
AGENCY TO OBTAIN THEIR VIEWS ON THE AVAILABILITY TO DATA,
FREQUENCY OF COLLECTION, THE CLARITY OF INSTRUCTIONS AND
RECORDKEEPING, 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 3 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.
The overall operation of the program was discussed with representatives of the
American Seed Trade Association (ASTA) and state officials. Ongoing contact is made
with current active company users and prospective companies. No recommended
changes or negative comments have been received. Information is only collected when
the company submits a sample for inspection. There are no suggested changes since
the information is supplied in a format determined by the company. Only a minimum
of information is collected and that information, such as the required test and
identification, is essential for determining the tests to be conducted and the identity of
the seed. In February 2019 the following individuals were consulted about this
collection:

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Jane DeMarchi
American Seed Trade Association
225 Reinekers Lane, Suite 650
Alexandria, Virginia 22314
(703) 837-8140
Mr. Don Robison
Seed Administrator
Office of Indiana State Chemist and Seed Commissioner
Purdue University
175 South University Street
West Lafayette, Indiana 47907-2063
(765) 494-1557
Apollo Seeds USA, Inc.
P.O. Box 1420
Campbell, California 95009
(408) 779-0784
Innova Seeds
P.O. Box 579849
Modesto, California 95357
(209) 527-3311
9.

EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO
RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR
GRANTEES.
No payments or gifts are made to companies.

10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO
RESPONDENTS AND THE BASIS FOR THE ASSURANCE IN STATUTE,
REGULATION, OR AGENCY POLICY.
Documents submitted by the public are considered confidential and are only used for
official purposes. All public records are maintained and handled according to the
provisions of the Freedom of Information Act and the Privacy Act.
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.
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No information of a sensitive nature is requested or provided.
12. PROVIDE ESTIMATES OF THE HOUR BURDEN OF THE COLLECTION OF
INFORMATION. THE STATEMENT SHOULD:
-

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 DIFFERENCE IN ACTIVITY, SIZE, OR COMPLEXITY,
SHOW THE RANGE OF ESTIMATED HOUR BURDEN, AND
EXPLAIN THE REASONS FOR THE VARIANCE. GENERALLY,
ESTIMATES SHOULD NOT INCLUDE BURDEN HOURS FOR
CUSTOMARY AND USUAL BUSINESS PRACTICES.

-

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 83.1.

-

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, THE
COST SHOULD BE INCLUDED IN ITEM 14.

ORDER CLERKS An estimated 55 companies are actively engaged in seed service testing.
No. of
records

Hourly Benefits &
Wages Compensation
cost per hour
(31.7 percent)

55
TOTAL

$17.21

$5.46

Total Wage
plus benefits
& compensation per
respondent
$22.67 hr.

Total Hrs. for
records

Total Cost

333

$7,549.11
$7,549.11

Data for computation of this hourly wage were obtained from the U.S. Department of Labor
Statistic’s publication, “May 2018 National Occupational Employment and Wage Estimates.”
This publication can also be found at the following Web site:
https://www.bls.gov/oes/current/oes_nat.htm.
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The Employer Costs for Employee Compensation was taken from the Bureau Labor Statistics
press release dated December 14, 2018.
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.)
-

THE COST ESTIMATE 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 SERVICE COMPONENT. THE ESTIMATES SHOULD
TAKE INTO ACCOUNT COSTS ASSOCIATED WITH GENERATING,
MAINTAINING, AND DISCLOSING OR PROVIDING THE
INFORMATION. INCLUDE DESCRIPTIONS OF METHODS USED TO
ESTIMATE MAJOR COST FACTORS INCLUDING SYSTEM AND
TECHNOLOGY ACQUISITION, EXPECTED USEFUL LIFE OF
CAPITAL EQUIPMENT, THE DISCOUNT RATE(S), AND THE TIME
PERIOD OVER WHICH COSTS WILL BE INCURRED. CAPITAL
AND START-UP COSTS INCLUDED, AMONG OTHER ITEMS,
PREPARATIONS FOR COLLECTING INFORMATION SUCH AS
PURCHASING COMPUTERS AND SOFTWARE; MONITORING,
SAMPLING, DRILLING, AND TESTING EQUIPMENT; AND RECORD
STORAGE FACILITIES.

-

IF COST ESTIMATES ARE EXPECTED TO VARY WIDELY,
AGENCIES SHOULD PRESENT RANGES OF COST BURDENS AND
EXPLAIN THE REASONS FOR THE VARIANCE. THE COST OF
PURCHASING OR CONTRACTING OUT INFORMATION
COLLECTION SERVICES SHOULD BE A PART OF THIS COST
BURDEN ESTIMATE. IN DEVELOPING COST BURDEN
ESTIMATES, AGENCIES MAY CONSULT WITH A SAMPLE OF
RESPONDENTS (FEWER THAN 10), UTILIZE THE 60-DAY PRE-OMB
SUBMISSION PUBLIC COMMENT PROCESS AND USE EXISTING
ECONOMIC OR REGULATORY IMPACT ANALYSIS ASSOCIATED
WITH THE RULEMAKING CONTAINING THE INFORMATION
COLLECTION, AS APPROPRIATE.

-

GENERALLY, ESTIMATES SHOULD NOT INCLUDE PURCHASES
OF EQUIPMENT OR SERVICES, OR PORTIONS THEREOF, MADE:
(1) PRIOR TO October 1, 1995, (2) TO ACHIEVE REGULATORY
COMPLIANCE WITH REQUIREMENTS NOT ASSOCIATED WITH
THE INFORMATION COLLECTION, (3) FOR REASONS OTHER
THAN TO PROVIDE INFORMATION OR KEEPING RECORDS FOR
THE GOVERNMENT, OR (4) AS PART OF CUSTOMARY AND USUAL
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BUSINESS OR PRIVATE PRACTICES.
There are no capital/startup or operational and maintenance costs.
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, OPERATION 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 program involves no cost impact on the Federal Government because the AMA
and regulations provide that the Federal Government shall be reimbursed for costs
incurred from the company on a user fee basis. The hourly user fee includes all Agency
costs of providing the service including fringe benefits.
15. EXPLAIN THE REASONS FOR ANY PROGRAM CHANGES OR
ADJUSTMENTS REPORTED IN ITEMS 13 OR 14 OF THE OMB FORM 83-1.
The number of companies applying for the service and shipping seed in foreign
commerce did not increase since the last submission. There is an increase in the
number of samples per company for use of the service and tests requested from 22.92 to
24.24 per company. The combined result is a burden increase of 18.00 hours. The
average response time of .25 hours has not changed.
16. FOR COLLECTIONS OF INFORMATION WHOSE RESULTS ARE
PLANNED TO BE PUBLISHED, OUTLINE PLANS FOR TABULATION AND
PUBLICATION. ADDRESS ANY COMPLEX ANALYTICAL TECHNIQUES
THAT WILL BE USED. 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.
The information is not published.
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.
The certificates used by the Seed Service Testing Program are the Seed Analysis
Certificate-Sample Inspection and the ISTA Orange International Seed Lot Certificate.
Application Request for Service Process (letter from companies providing information
needed to provide the service requested). Includes information to identify the seed
being tested; the seed treatment (if treated); the tests to be performed, and any other
9

appropriate information required by the company to be on the Federal Seed Analysis
Certificate or the ISTA Orange International Seed Lot Certificate. AMS computer
generates and uses the Seed Analysis Certificate-Sample Inspection to report seed test
results. The AMS computer also generates test results to be printed onto the ISTA
Orange International Seed Lot Certificates.
18. EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT
IDENTIFIED IN ITEM 19, CERTIFICATION FOR PAPERWORK
REDUCTION ACT SUBMISSIONS, OF OMB FORM 83-1.
No exceptions are requested to the certification statement identified in Item 19 of OMB
Form 83-I.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
THE AGENCY SHOULD BE PREPARED TO JUSTIFY ITS DECISIONS NOT TO
USE STATISTICAL METHODS IN ANY CASE WHERE SUCH METHODS MIGHT
REDUCE BURDEN OR IMPROVE ACCURACY OF RESULTS. WHEN ITEM 17
ON THE FORM OMB 83-1 IS CHECKED YES, THE FOLLOWING
DOCUMENTATION SHOULD BE INCLUDED IN THE SUPPORTING
STATEMENT TO THE EXTENT THAT IT APPLIES TO THE METHODS
PROPOSED:
This information collection does not employ statistical methods.

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