1670-0031_OBP Forms_SSA_FINAL

Supporting Statement for Paperwork Reduction Act Submissions

Title: Office of Bombing Prevention Training and Conference Forms

OMB Control Number: 1670-0031

Supporting Statement A

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.

Under the Homeland Security Presidential Directive-19: Combating Terrorist Use of Explosives in the United States, the Department of Homeland Security (DHS) was mandated to develop strategies and recommendations on how to deter, prevent, detect, protect against, and respond to IED explosive attacks. DHS thus educates private sector security providers about IED threats, including tactics, techniques, and procedures relevant to their usage, so private sector security providers are knowledgeable about terrorist use of explosives and contribute to a layered security approach.

The Presidential Policy Directive-17: Countering Improvised Explosive Devices (PPD-17) reaffirms the 2007 Strategy for Combating Terrorist Use of Explosives in the United States. It provides guidance to update and gives momentum to our ability to counter threats involving improvised explosive devices (IEDs). DHS was mandated to deliver standardized IED awareness and familiarization training for federal, state and local responders and public safety personnel.

Over the past 10 years, incidents involving IEDs has increased worldwide. This highlights the existing threat of IED attacks by terrorists, transnational criminal organizations, and individuals domestically that have radical political, environmental, or international viewpoints. IEDs have been used in the theater of war, mass transit systems overseas in global aviation plots, assignation attempts against political leaders, and other attempts here within the United States. They have also been used to threaten our ability in the secure movement of goods in accordance with the National Strategy for Global Supply Chain Security.

The Office for Bombing Prevention (OBP) must collect various information to effectively deliver this training. Additionally, OBP collects data to provide updated and awareness product information following conferences and other outreach events.

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.

The purpose of the Volunteer Participant Release of Liability Agreement is to collect necessary information in case an individual who acts as a volunteer role player in support of official OBP training sustains an injury or death during the performance of their supporting role. If legal action is taken, this information can serve as a “hold harmless” statement /agreement by the Government. In the unlikely event that an injury or death is sustained in the performance of support for training, this information will be used by OBP to protect against legal action by the volunteer or their family. If legal action is taken, this information can serve as a “hold harmless” statement /agreement by the Government.

The purpose of the Gratuitous Services Agreement is to establish that no monies, favors or other compensation will be given or received by either parties involved in the volunteer training. The information from the Gratuitous Services Agreement will be used by OBP in the event that questions arise regarding remuneration or payment for volunteer participation in training events.

The purpose of the OBP Interest Sign-up sheet is to collect an individual’s contact information at the training events and conferences. This information is used by OBP in order to follow-up with an individual’s questions and to provide the individual with updated or new awareness product information at the conclusion of conference season as well as establish an OBP point of contact for them.

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.

The Gratuitous Service Agreement and Voluntary Participant forms are best delivered as hard-copies to volunteer participants that attend the courses to ensure the right audiences are targeted in an environment where last-minute changes to the participant list are common.

The OBP Interest Sign-up sheet is best used as a paper sign-up sheet or by collecting business cards during conferences.

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.



A search of reginfo.gov revealed that there are no other forms of these types currently in use; therefore, this collection is not collected or duplicated elsewhere.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

This information collection does not have impact on small businesses or other small entities.

6. Describe the consequence to Federal/DHS program or policy activities if the collection of information is not conducted, or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Failure to collect this information could result in questions of liability and/or remuneration for volunteers in OBP and reluctance to seek volunteer involvement as a result. This would negatively affect the overall quality of the program in delivering these trainings to private sector security providers, federal, state and local responders, and public safety personnel.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

(a) Requiring respondents to report information to the agency more often than quarterly.

(b) Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

(c) Requiring respondents to submit more than an original and two copies of any document.

(d) Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.

(e) 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.

(f) Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

(g) 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.

(h) 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.



There are no special circumstances causing information to be collected in this manner.

8. Federal Register Notice:

a. 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. 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.

b. 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 format (if any), and on the data elements to be recorded, disclosed, or reported.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.



	Date of Publication	Volume #	Number #	Page #	Comments Addressed
60Day Federal Register Notice:	August 5, 2019	84	150	38036 - 38037	0
30-Day Federal Register Notice	November 4, 2019	84	213	59398 - 59399	0

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No gifts or payments of any kind will be provided to the respondents of this information collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.



This collection does not include a pledge of confidentiality that is not supported by established authority in statute or regulation.

The DHS Privacy Office review finds that this is a privacy sensitive collection requiring a Privacy Impact Assessment (PIA) and a Systems of Records Notice (SORN). The collection is covered by PIA DHS/ALL-006 DHS General Contacts List and SORN DHS/ALL-002 – Department of Homeland Security (DHS) Mailing and Other Lists System November 25, 2008, 73 FR 71659.

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 sensitive nature being requested.

12. Provide estimates of the hour burden of the collection of information. The statement should:



a. 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 desired. If the hour burden on respondents is expected to vary widely because of differences 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.

b. 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-I.

c. 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, this cost should be included in Item 14.

DHS estimates that 750 respondents will complete both the Volunteer Participant Release of Liability Agreement and the Gratuitous Service Agreement. These respondents include emergency response personnel such as firefighters, police officers, and emergency management directors. In addition, DHS estimates that 500 respondents will fill out the Interest Sign-up Sheet. These respondents come from a variety of sectors. DHS estimates that 50 percent of the respondents for all instruments work in the private sector and 50 percent of the respondents work in state and local government.

DHS estimates that it will take a respondent approximately 0.20 hours (12 minutes) to complete the Volunteer Participant Release of Liability Agreement and the Gratuitous Service Agreement, with each form taking 0.10 hours (6 minutes). DHS estimates it will take a respondent approximately 0.02 hours (1 minute) to fill out the Interest Sign-up Sheet.

To estimate the labor costs for respondents signing the Volunteer Participant Release of Liability Agreement and the Gratuitous Service Agreement, DHS uses the average hourly compensation rate for emergency response personnel. DHS used Bureau of Labor Statistics (BLS) data to estimate the average hourly wage rate for firefighters, police and sheriff’s patrol officers (hereafter referred to as police officers), and emergency management directors.¹ The weighted average hourly wage rate for private-sector emergency response personnel is $23.50.² To account for benefits, DHS multiplies this average hourly wage rate by a compensation factor of 1.4277, which is the ratio of total compensation to salaries and wages.³ The average hourly compensation rate for private-sector emergency personnel responders is $33.55.⁴ The weighted average hourly wage rate for state and local emergency response personnel is $29.84.⁵ To account for benefits, DHS multiplies this average hourly wage rate by a compensation factor of 1.6002.⁶ The average hourly compensation rate for state and local emergency response personnel is $47.75.⁷ DHS assumes that half of the respondents are from the private sector and half are from state and local government. Therefore, for the purposes of this analysis, DHS uses an hourly compensation rate of $40.65 for emergency response personnel.⁸

To estimate the labor costs for the respondents filling out the Interest Sign-up Sheet, DHS uses BLS data to estimate the average hourly wage rate of $24.44 for all occupations.⁹ DHS multiplies this average hourly wage rate by the compensation factor of 1.4277 estimated above to get an average hourly compensation rate for private-sector respondents of $34.89.¹⁰ The weighted average hourly wage rate for state and local respondents is $26.83.¹¹ DHS multiplies this average hourly wage rate by the compensation factor of 1.6002 estimated above to get an average hourly compensation rate for state and local respondents of $41.57.¹² DHS assumes that half of the respondents are from the private sector and half are from state and local government. Therefore, for the purposes of this analysis, DHS uses an hourly compensation rate of $38.23 for respondents filling out the Interest Sign-up Sheet.¹³

As presented in Table A.12, for the proposed instruments, the estimated burden is 158 hours per year. At an hourly rate of $40.65 for those completing the Volunteer Participant Release of Liability Agreement and the Gratuitous Service Agreements and an hourly rate of $38.23 for those completing the Interest Sign-up Sheet, the dollar value of the total annual burden hours associated with the instruments of this information collection equals $6,416.

Table A.12: Estimated Annualized Burden Hours and Costs

Instrument	Number of Respondents	Number of Responses per Respondent	Average Burden per Response (in hours)	Total Annual Burden (in hours)	Average Hourly Compensation Rate	Total Annual Respondent Cost
Volunteer Participant Release of Liability Agreement	750	1	0.10	75	$40.65	$3,049
Gratuitous Services Agreement	750	1	0.10	75	$40.65	$3,049
Interest Sign-up Sheet	500	1	0.02	8	$38.23	$319
Total	1,250			158		$6,416

Note: Totals may not sum due to rounding.

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: (1) 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. 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 include, 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 to keep records for the government, or (4) as part of customary and usual business or private practices.

There are no recordkeeping, capital, start-up, or maintenance costs to respondents associated with this information collection.

 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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.



DHS expects that one GS-14 staff member in the Washington, D.C. area will review the forms. The average hourly wage rate of a GS-14, Step 10 staff member in the Washington, D.C. area is $73.00.¹⁴ To account for benefits, DHS multiplies the hourly wage rate by a load factor of 1.6919,¹⁵ resulting in an hourly compensation rate of $123.51. As presented in Table A. 14, in total, DHS estimates an annual government cost of $18,773.

Table A.14. Estimated Annual Federal Government Burden Hours and Costs

Form Name	Number of Reports	Burden for Design/ Administration per Report (in hours)	Total Annual Burden (in hours)	Average Hourly Compensation Rate	Total Annual Cost
Volunteer Participant Release of Liability Agreement	750	0.10	75	$123.51	$9,263
Gratuitous Services Agreement	750	0.10	75	$123.51	$9,263
Interest Sign-up Sheet16	20	0.10	2	$123.51	$247
Total	1,520		152		$18,773

Note: Totals may not sum due to rounding.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to annual reporting and recordkeeping hour and cost burden. A program change is the result of deliberate Federal Government action. All new collections and any subsequent revisions of existing collections (e.g., the addition or deletion of questions) are recorded as program changes. An adjustment is a change that is not the result of a deliberate Federal Government action. These changes that result from new estimates or actions not controllable by the Federal Government are recorded as adjustments.



The changes to the collection since the previous OMB approval include:

• updating the collection name to better reflect instruments in the collection

• adding the collecting of contact information,

• an increase in burden estimates and costs.

The OBP Interest Sign-up Sheet was added to the collection to provide individuals with training resources. The addition of the Interest Sign-up Sheet has increased the annual burden estimate by 8 hours, which corresponds to an annual cost of $319. It has also increased the annual government burden estimate by 2 hours at an annual cost of $247.

The annual burden cost for the existing collections (i.e., the Volunteer Participant Release of Liability Agreement and the Gratuitous Services Agreement) has increased by $2,204, from $3,894 to $6,098, due to updated hourly compensation rates.

The annual government cost for the existing collections (i.e., the Volunteer Participant Release of Liability Agreement and the Gratuitous Services Agreement) has increased by $11,695, from $6,831 to $18,526, due to updated hourly compensation rates.

16. For collections of information whose results will 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.



Information will not be published.

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



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

18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

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

1 BLS. Occupational Employment Statistics. OES Data. May 2018: All Data. Firefighters (33-2011), Police and Sheriff’s Patrol Officers (33-3051), and Emergency Management Directors (11-9161). https://www.bls.gov/oes/tables.htm. In the private sector, there are 16,300 firefighters that earn an average hourly wage of $18.19; 6,760 police officers that earn an average hourly wage of $26.73; and 2,630 emergency management directors that earn an average hourly wage of $48.10.

2 $23.50 per hour = (16,300 firefighters × $18.19 per hour + 6,760 police officers × $26.73 per hour + 2,630 emergency management directors × $48.10 per hour) ÷ (16,300 firefighters + 6,760 police officers + 2,630 emergency management directors).

3 BLS. Employer Costs for Employee Compensation – December 2018. Table 5. Employer Costs per Hour Worked for Employee Compensation and Costs as a Percent of Total Compensation: Private Workers, by Major Occupational Group and Bargaining Unit Status, December 2018. https://www.bls.gov/news.release/archives/ecec_03192019.pdf. The compensation factor of 1.4277 is estimated by dividing total compensation ($34.05) by wages and salaries ($23.85).

4 $33.55 = $23.50 × 1.4277.

5 $29.84 per hour = (288,780 local firefighters × $26.07 per hour + 9,020 state firefighters × $23.96 per hour + 570,150 local police officers × $31.29 per hour + 71,580 state police officers × $33.74 per hour + 5,160 local emergency management directors × $36.02 per hour+ 1,560 state emergency management directors × $33.25 per hour) ÷ (288,780 local firefighters + 9,020 state firefighters + 570,150 local police officers + 71,580 state police officers + 5,160 local emergency management directors + 1,560 state emergency management directors).

6 BLS. Employer Costs for Employee Compensation – December 2018. Table 3. Employer Costs per Hour Worked for Employee Compensation and Costs as a Percent of Total Compensation: State and Local Government Workers, by Major Occupational and Industry Group, December 2018. https://www.bls.gov/news.release/archives/ecec_03192019.pdf. The compensation factor of 1.6002 is estimated by dividing total compensation ($50.55) by wages and salaries ($31.59).

7 $47.75 = $29.84 × 1.6002.

8 $40.65 = ($33.55 × 50%) + ($47.75 × 50%).

9 BLS. Occupational Employment Statistics. OES Data. May 2018: All Data. All Occupations (00-000). https://www.bls.gov/oes/tables.htm.

10 $34.89 = $24.44 × 1.4277.

11 $26.83 per hour = (14,562,760 local workers × $25.98 per hour + 4,532,180 state workers × $29.56 per hour) ÷ (14,562,760 local workers + 4,532,180 state workers).

12 $41.57 = $26.83 × 1.6002.

13 $38.23 = ($34.89 × 50%) + ($41.57 × 50%).

14 Office of Personnel Management. Salary Table 2019-DCB. Average hourly wage rate for GS-14, Step 10. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/19Tables/html/DCB_h.aspx

15 Congressional Budget Office. Comparing the Compensation of Federal and Private-Sector Employees, 2011 to 2015. April 2017. https://www.cbo.gov/publication/52637. According to Table 4, average total compensation for all levels of education is $64.80. According to Table 2, average wages for all levels of education is $38.30. DHS estimates the compensation factor by dividing total compensation by average wages.

16 The number of reports (20) differs from the number of respondents in Table A.12 (500) because this accounts for the total number of sign-up sheets to be reviewed annually. There are 20 conferences per year, so government staff review only 20 sign-up sheets per year. Together, these 20 sign-up sheets are expected to contain the information from 500 respondents.