EICR ASF Dog Import SS (20210726)

June 2021

Supporting Statement

African Swine Fever; Importation of Live Dogs for Resale from Regions Where ASF Exists or Is Reasonably Believed to Exist

OMB Control No. 0579-XXXX

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 may also prohibit or restrict import or export of any animal or related material if required 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, the Farm Security and Rural Investment Act of 2002; 7 U.S.C. 8301, et. seq.

Part of the mission of the Veterinary Services (VS) business unit of the Animal and Plant Health Inspection Service (APHIS) is preventing foreign animal disease outbreaks in the United States, and monitoring, controlling, and eliminating a disease outbreak should one occur. In the past several years, there have been significant worldwide outbreaks of African swine fever (ASF). ASF is a highly contagious and deadly viral disease affecting both domestic and feral (wild) pigs. The disease has not been detected in the United States; however, USDA is committed to working with State and industry partners to keep the virus out of the country. An onset of ASF in the United States has the potential to decimate the U.S. swine industry, a $22.5 billion a year sector of the economy. Much of the industry imports to foreign countries so an impact to it would significantly damage U.S. trade. As noted, the disease also affects feral swine; feral swine numbers remain significant in the United States (approximately 5 million to 9 million animals in the United States as of September 2020) and these animals often have contact with domestic swine and other animals (such as dogs) and can spread the disease to them. ASF can also be spread by items that swine and dogs come in contact with such as bedding and packaging materials.

The past year has seen a large increase in the import of dogs (many rescue dogs) from regions where ASF has occurred. The number of import permits APHIS has issued has risen from 568 in fiscal year (FY 2018) to 2,669 in FY 2020; numbers are on track to hit 3,500 in FY 2021. Of the currently received permits, 1,465 originated in ASF-affected countries, accounting for 7,085 dogs entering the United States from these countries. Many of these dogs have contact with affected and potentially affected swine in their home countries. APHIS has determined that dogs imported from ASF-affected countries for resale purposes, along with their bedding, represent a possible pathway for the introduction of disease. To block this pathway, APHIS has issued a Federal Order imposing several restrictions on the importation of dogs for resale from regions where ASF exists or is reasonably believed to exist. Importers will need to verify that they have met these restrictions by completing and submitting a Dog Import Record, which will be further described below.

APHIS is requesting the Office of Management and Budget (OMB) approve its use of the Dog Import Record to verify compliance with the Federal Order’s requirements for bringing dogs into the United States from ASF-affected countries.

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.

Dog Import Record (ASF VSDIR 1); (USDA APHIS VS Federal Order DA-2021-01); (Private Sector)

This form helps APHIS determine where dogs are coming from (to assess the risk of whether they could have been exposed to ASF), where they are going, and, most importantly, measures taken to ensure neither the dogs nor anything that came with them can spread ASF. Both parts of the VS Dog Import Record must be completed and submitted for each shipment of imported dog or dogs intended for resale. Part 1 of the VS Dog Import Record must include the following information:

• The name, phone number, email, and address of the importer.

• The country of origin.

• The APHIS Animal Care import permit number.

• The number of dogs shipped.

• The U.S. port of entry.

• The date the dog or dogs arrived in the United States.

• The address(es) of the first U.S. post-entry point(s) of concentration.

• Importer certification and signature.

Part 2 of the VS Dog Import Record must include the following information:

The APHIS Animal Care import permit number.

• Each dog’s name (if applicable), microchip number, age, gender, breed, color/markings, and the date of bath completion.

• The name, phone number, email, and signature of the importer.

• The name, phone number, email, and signature of the bather(s).

In addition, the importer must certify that:

• The dogs and their shipping crates/containers were free of dirt, wood shavings, hay, straw, or any other organic/natural bedding material.

• All bedding that accompanied the dog or dogs during transit was properly disposed of at the post-entry point(s) of concentration.

• Each dog has an ISO compliant microchip implanted, and the microchip number was verified immediately before the animal was bathed.

• Each dog was bathed at the U.S. post-entry point(s) of concentration destination within 2 calendar days of arrival in the United States.

The form also contains space for a detailed list of bathing confirmation for the individual dog or dogs imported, including the dogs’ microchip numbers; name; age; gender; breed, color and markings; and the date of bathing. Each person bathing the dog or dogs must sign the form, as well as the importer.

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.

When an applicant submits an application for a permit to import dogs from a country considered affected by ASF, APHIS emails that applicant a VS Dog Import Record with instructions to complete the VS Dog Import Record and upload it into the APHIS eFile Animal Care Permitting system once the form is complete. This allows the importer to upload the form to the same location where they uploaded the supporting documentation to receive the permit, reducing importer confusion and streamlining the process.

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 effort is not available from any other source. APHIS is the only Federal agency responsible for preventing, detecting, controlling, and eliminating foreign animal diseases from the United States. Animal Care, another APHIS business unit, collects initial dog import information via APHIS 7040 (Application for Permit to Import Dogs) under its information collection number 0579-0036. Animal Care uses the eFile Animal Care Permitting system referenced in Question 3 for this purpose.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

APHIS estimates approximately 35 percent of the respondents in this information collection are small businesses. The information collected is the absolute minimum needed to prevent the spread of ASF.

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 were conducted less frequently or not at all, APHIS would not be able to adequately protect producers and herd owners against the incursion of ASF. A lack of this information could undermine APHIS’ ability to prevent an outbreak, which may result in additional disease spread and greater producer hardship.

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, such as:

• 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;

Importers must complete and submit the Dog Import Records within 2 business days of the dog’s or dogs’ arrival in the United States.

• 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 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;

• 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 other 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 has engaged in productive consultations with private importers and brokers to discuss data requirements; data availability; how data is collected and how frequently; how much data is available; the convenience and clarity of reporting formats and other collection instruments; and the clarity of, and necessity for, any recordkeeping requirements:

Irina Vlasova

Good World Animal Rescue and Protection

Rafael Ceferov Street 2

Baku, Mardakan, Azerbaijan 1076

Phone: (011) (994) (857) 222-5060

Email: [email protected]

Sarah Jaramillo, broker

GJ Enterprises, Customs Brokerage & Consulting, Inc.

1301 NW 89 Court, Suite 207

Doral, FL 33172

Phone: (305) 934-9657

Fax: (305) 393-8437

Email: [email protected]

Eileen McFadden

Golden Re-Triever Rescue Inc.

P.O. Box 1420

Washington Township, NJ 07676

Phone: (914) 772-6007

Email: [email protected]

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration 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.

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 will ask 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.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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.

See APHIS Form 71 for hour burden estimates. Estimates were developed based on real-time use and discussions with private dog importers and import brokers.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

The total annualized cost to respondents is $37,845 computed by multiplying the estimated average hourly wage ($29.02) by the total number of burden hours needed to complete the work (900), and then multiplying the product ($26,118) by 1.449 to capture benefit costs.

The average hourly rates used to calculate the estimate are for ranchers (SOCC 11-9013, $36.93) and animal breeders (SOCC 45-2021, $21.12) were obtained from the U.S. DOL Bureau of Labor Statistics occupational employment statistics website at http://www.bls.gov/current/oes_stru.htm.

According to DOL BLS news release USDL-21-0437 released March 18, 2021, employee benefits account for 31 percent of employee costs, and wages account for the remaining 69 percent. Mathematically, total costs can be calculated as a function of wages using a multiplier of 1.449.

13. Provide estimates of the total annual cost burden to respondents or recordkeepers 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.

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 79. The annualized cost to the Federal government is estimated at $81,710.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

This is a new collection.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to publish information it collects 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.

Not applicable. APHIS will display the expiration date.

18. Explain each exception to the certification Statement in the "Certification for Paperwork Reduction Act."

APHIS can certify compliance with all provisions under the Act.

B. Collections of Information Employing Statistical Methods

There are no statistical methods associated with the information collection activities used in this program.