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.
This information can be submitted electronically via the Document Image System into ACE.
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. A 60 day notice published on May 17, 2019 (84 FR 22504) and a 30 day notice on August 26, 2019 (84 FR 44630) on which no comments have been 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 ACE, dated July 31, 2015, and a SORN for Import Information System, dated July 26, 2016 (Vol. 81, Page 48826), 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 |
|
|
|
|
Public Cost
The estimated cost to the respondents is $12,952. This is based on the estimated burden hours (190) multiplied by the average loaded hourly wage rate for warehouse operators ($68.17). CBP calculated this loaded wage rate by first multiplying the Bureau of Labor Statistics’ (BLS) 2018 median hourly wage rate for Transportation, Storage, and Distribution Managers ($45.54), which CBP assumes best represents the wage for warehouse operators, by the ratio of BLS’ average 2018 total compensation to wages and salaries for Management, Business, and Financial occupations (1.4970), the assumed occupational group for warehouse operators, to account for non-salary employee benefits.1,2 This figure is in 2018 U.S. dollars and CBP assumes an annual growth rate of 0 percent; the 2018 U.S. dollar value is equal to the 2019 U.S. dollar value.
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 these records is $992. This is based on the number of responses that must be reviewed (8) multiplied by the time burden to review and process each response (2 hours) = 16 hours multiplied by the average hourly loaded rate for a CBP Trade and Revenue employee ($62.01)3 = $992.
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 by the average hourly loaded rate for a CBP Trade and Revenue employee ($62.01)4 = $7,441.
Minus the application fee of $575 multiplied by (x) the number of respondents (8) = $4600. To summarize $992 + $7,441 - $4600 = the Government cost ($3,833).
15. 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 has been no change in 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 Source of median wage rate: U.S. Bureau of Labor Statistics. Occupational Employment Statistics, “May 2018 National Occupational Employment and Wage Estimates United States.” Updated April 2, 2019. Available at https://www.bls.gov/oes/2018/may/oes_nat.htm. Accessed June 4, 2019.
2 The total compensation to wages and salaries ratio is equal to the calculated average of the 2018 quarterly estimates (shown under Mar., June, Sep., Dec.) of the total compensation cost per hour worked for Management, Business, and Financial occupations ($69.3800) divided by the calculated average of the 2018 quarterly estimates (shown under Mar., June, Sep., Dec.) of wages and salaries cost per hour worked for the same occupation category ($46.3450). 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 2018, “Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 2004-2018.” March 2019. Available at https://www.bls.gov/web/ecec/ececqrtn.pdf. Accessed June 4, 2019.
3 CBP bases this wage on the FY 2019 salary and benefits of the national average of CBP Trade and Revenue positions, which is equal to a GS-12, Step 6. Source: Email correspondence with CBP’s Office of Finance on June 12, 2019.
4 CBP bases this wage on the FY 2019 salary and benefits of the national average of CBP Trade and Revenue positions, which is equal to a GS-12, Step 6. Source: Email correspondence with CBP’s Office of Finance on June 12, 2019.
| File Type | application/msword |
| File Title | Supporting Statement |
| Author | Preferred Customer |
| Last Modified By | SYSTEM |
| File Modified | 2019-09-30 |
| File Created | 2019-09-30 |