0109-labor-2018-SSA - Rev 09-27-2018

0109-labor-2018-SSA - Rev 09-27-2018.docx

Agricultural Labor

OMB: 0535-0109

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1Supporting Statement


AGRICULTURAL LABOR SURVEY


OMB No. 0535-0109



TERMS OF CLEARANCE: NASS agrees to request a non-substantive change should the Standard Occupation Classification (SOC) Policy Committee recommend changes to the proposed SOC codes for extant FLS occupational categories.


NASS RESPONSE: On July 24, 2017, OMB approved a non-substantive change request from NASS. The revised SOC codes now used by NASS are in item 2 below.


A. JUSTIFICATION


This is a request to make a substantive change to the currently approved docket.

In this substantive change renewal, NASS has been directed by the USDA to expand the survey to add greater detail to the summarized data. This will involve an increase in the currently approved sample size to collect more data on agricultural labor that is performed under each of the standard occupational classification (SOC) codes. In addition NASS will resume collecting data on a quarterly basis rather than biannual basis which collected the quarterly data. This should help to reduce the potential for any memory bias that may have occurred previously. This change is expected to take place in January 2019, contingent on the passage of the 2019 FY Federal Budget. If there is a delay in the passage of the Federal Budget the changes will take place in July 2019. In addition the biannual survey will be conducted in April 2019 and the data for the January and April quarters will be collected as they are currently approved. After that the data collections will collect data on a quarterly basis. Response to these data collections by the sampled farm and ranch operators is on a voluntary basis.

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.


Agricultural labor statistics are an integral part of the primary function of the National Agricultural Statistics Service (NASS), which is the collection, processing, and dissemination of current State, regional, and national agricultural statistics. Wage rate estimates have been published since 1866 and U.S. farm employment estimates have been published since 1910. General authority for these data collection activities is granted under U.S. Code Title 7, Section 2204 which specifies that "The Secretary of Agriculture shall procure and preserve all information concerning agriculture which he can obtain ... by the collection of statistics ... and shall distribute them among agriculturists."

Comprehensive and reliable agricultural labor data are also needed by the Department of Labor for setting "Adverse Effect Wage Rates" (AEWR) and in the administration of the "H-2A" program for non-immigrants who enter the United States for temporary or seasonal agricultural labor. The Department of Labor also uses NASS labor data to set Child Labor Regulations.


The Agricultural Labor Survey is the only timely and reliable source of information on the size of the farm worker population. The Census Bureau, which previously collected this information in its decennial Census, has conceded that, because of undercount issues, the agricultural labor data from the decennial Census should not be used.


According to the USDA’s Economic Research Service (ERS), 21.0 million full- and part-time jobs were related to the agricultural and food sectors in 2015, making up 11.1 percent of total U.S. employment. Direct on-farm employment accounted for about 2.6 million of these jobs, or 1.4 percent of total U.S. employment.


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 Agriculture Adjustment Act of 1938, as amended, requires USDA to compute parity prices of farm products. This computation uses an index of prices paid by farmers which in turn is composed of five indexes, one of which is an index of wage rates. Wage rate estimates are the most widely used component of the Agricultural Labor Survey program. These estimates measure actual agricultural wage rates as well as year-to-year changes.


Under the H-2A program for agriculture, part of the Immigration Reform and Control Act of 1986, agricultural employers are permitted to employ foreign workers only if domestic workers are unavailable and the employment of foreign workers will not adversely affect wages and working conditions of U.S. agricultural workers employed in similar work. The Agricultural Labor Survey program is a critical source in determining the number of domestic workers who apply for work and ensuring that foreign workers cause no adverse effect on American farm workers. The minimum wage rate offered by agricultural employers as a requirement for employing foreign workers is determined by Federal regulations (CFR 655.107 Adverse Effect Wage Rates).


Data on number of workers and hours worked are used to estimate agricultural productivity. The Employment Standards Administration in the Department of Labor uses estimates of agricultural workers in conjunction with their estimates of employment covered by the Fair Labor Standard Act of 1938, as amended.


The data will now be collected for the following Standard Occupational Classifications:


Worker codes

Code

Work Hired to Do



FIELD WORKERS


11

Agricultural Equipment Operators - Crop, Nursery and Greenhouse:

Drive and control farm equipment to till soil and to plant, cultivate, and harvest crops.

12

Farmworkers - Crop, Nursery and Greenhouse:

Manually plant, cultivate, and harvest vegetables, fruits, nuts, horticultural specialties, field crops, Christmas trees and short rotation woody crops. Use hand tools, such as shovels, trowels, hoes, tampers, pruning hooks, shears, and knives. Duties may include tilling soil and applying fertilizers; transplanting, weeding, thinning, or pruning crops; applying pesticides; or cleaning, grading, sorting, packing, and loading harvested products. May construct trellises, repair fences and farm buildings, or participate in irrigation activities.

13

Graders And Sorters - Crop, Nursery and Greenhouse Products:

Grade, sort, or classify agricultural crops by size, weight, color or condition.

14

Hand Packers And Packagers - Crop, Nursery and Greenhouse Products:

Pack or package by hand a wide variety of products and materials.

15

All Other Field Workers:

All agricultural workers working with crops, nursery or greenhouse products not included in codes 11-14.



LIVESTOCK WORKERS


20

Agricultural Equipment Operators – Farm, Ranch, and Aquacultural Animals: Drive and control heavy farm equipment while attending to live farm, ranch, or aquacultural animals and in harvest of unprocessed animal products.

21

Farmworkers - Farm, Ranch, and Aquacultural Animals: Attend to live farm, ranch, or aquacultural animals including cattle, sheep, swine, goats, horses and other equines, poultry, finfish, shellfish, and bees. Duties may include feeding, watering, herding, milking, grazing, castrating, branding, de-beaking, weighing, catching, and loading animals. May conduct simple exams; maintain records; assist in births; and administer medications, vaccinations, or insecticides. May clean and maintain animal housing areas.

22

Graders And Sorters - Farm, Ranch, and Aquacultural Animal Products:

Grade, sort, or classify unprocessed food and other agricultural products by size, weight, color, or condition.

23

Hand Packers And Packagers - Farm, Ranch and Aquacultural Animal Products:

Pack or package by hand a wide variety of products and materials.

24

All Other Livestock Workers:

All agricultural workers working with farm, ranch and aquacultural animals or products not included in codes 20 – 23.



SUPERVISORS


31

Farmers, Ranchers and Other Agricultural Managers:

Plan, direct, or coordinate the management or operation of farms, ranches, greenhouses, aquacultural operations, nurseries, tree farms, or other agricultural establishments.

32

First-Line Supervisors of Farm Workers:

Directly supervise and coordinate the activities of agricultural, aquacultural, and related workers.



OTHER WORKERS


41

Agricultural Inspectors:

Inspect agricultural commodities, processing equipment and facilities, and aquacultural operations, to ensure compliance with regulations and laws governing health, quality, and safety.

42

Animal Breeders:

Select and breed animals according to their genealogy, characteristics, and offspring.

43

Pesticide Handlers and Sprayers:

Mix or apply pesticides, herbicides, fungicides, or insecticides through sprays, dusts, vapors, soil incorporation, or chemical application to all crops including nursery and greenhouse products and facilities, and livestock, and livestock facilities. Usually requires specific training and state or federal certification. Excludes pilots who dust or spray crops from aircraft.

44

Any Other Worker Not Listed Above:

Including, but not limited to, mechanics, shop workers, truck drivers, accountants, bookkeepers, office workers. Excluding contract & custom workers, retail workers, and “value-added” workers.

In the pilot test that was conducted in 2013 the data that was reported for some of the Standard Occupational Classification (SOC) codes was very limited. Due to disclosure issues we were not able to publish data for many of the SOC codes. Since NASS conducts this survey under a cooperative agreement with the US Department of Labor (DOL), it was agreed that NASS should continue to publish the data using 4 worker categories (see next paragraph) consistent with our previous reports to ensure the continuation of historic charts and graphs created by data users.


Agricultural workers are estimated in four categories--field workers, livestock workers, field and livestock workers combined, and all hired workers (including supervisors and other workers) to provide a basis for meaningful comparison with the nonagricultural sector and to determine the impact of changes in the level of the Federal minimum wage.


The Bureau of Economic Analysis (BEA) in the Department of Commerce relies on the number of hired agricultural workers, hours worked, and wages paid as components in personal and national income for the agricultural sector of the gross domestic product (GDP). Legislatures and policy makers use agricultural labor data when setting policy that affects the farm sector. According to the USDA’s Economic Research Service (ERS) - Agriculture, food, and related industries contributed $992 billion to U.S. GDP in 2015, a 5.5-percent share. The output of America’s farms contributed $136.7 billion of this sum—about 1 percent of GDP.


Agricultural Labor Survey employment data (for example, worker numbers and wage rates) is used to ensure equitable allocation of federal assistance for farm workers. This includes support for housing and education for seasonal farm workers.


Changes in wage rates help measure the changes in costs of production of major farm commodities. Cost of production estimates are used by policy makers to help determine support levels for farm programs, including target prices, loan rates, and the milk support price. Price supports affect all farmers directly or indirectly. Price supports for grain farmers, for example, are generally used to ensure grain supplies are adequate and grain prices for livestock producers are reasonable.


The Agricultural Labor Survey provides data that can be used to measure the availability of farm workers across the nation, and be used to help determine if there is a shortage of farm laborers.


Labor data are used by policy makers in determining immigration policies. Analysts use the data to evaluate the effects of changes in the immigration and labor laws on producers, wage rates, and costs of production.


Agricultural labor data are used by farm worker organizations to help set wage rates and negotiate labor contracts as well as to determine the need for additional workers. They are also used by private organizations and government agencies responsible for the planning and placement of farm workers and those that work closely with employer and labor crew chiefs.


The Economic Research Service in USDA also uses wage rate data to estimate labor costs for crop and livestock enterprise budgets.


With all these uses in mind, NASS expanded the data collected, beginning in April 2018 to include base wage rates per hour. In addition to the type of work performed on the operation, operators are now asked to report data for each base hourly rate. In the past these data were combined for all hired workers in each category. The following two tables show the changes made to the questionnaires.




New Format

Section 1 - PAID WORKERS for January (continued)



4. Fill out the table below for the workers paid to do agricultural work the week of January 6th through January 12th. Report workers who fall under the same worker code on a single line.


  • Record each worker only once

  • Report only one week of hours and wages for the reference week

  • Base wages include the minimum amount paid regardless of method of pay (salaried, hourly, piece rate, etc.) but exclude bonus and overtime pay

  • Bonus pay includes performance pay, hazard pay, other regularly paid bonuses, etc. that are paid in addition to the base wages


INCLUDE:

  • Workers directly hired and paid by the farm operation

  • Part-time workers, paid family members, and hired managers

  • Workers on paid leave (sick or vacation) (include typical hours and wages for the week)


EXCLUDE:

  • Contract and custom workers

  • Retail workers and “value-added” workers


Enter the Worker Code from

Page 5

Number of

Paid Workers

that week

Total

Hours Worked

that week

Total

Gross Wages

Paid that week


(Dollars)

How much of the Total Gross Wages Paid that week were….

Total

Base Wages


(Dollars)

Total

Bonus Wages


(Dollars)

Total

Overtime Wages


(Dollars)

12

60

3000

$42,000

$36,000

$6,000

$0

32

2

100

$1,500

$1,400

$0

$100

12

4

170

$2,120

$1,920

$200

$0

611

612

613

614

Xxx

xxx

xxx

611

612

613

614

Xxx

xxx

xxx

611

612

613

614

Xxx

xxx

xxx

611

612

613

614

Xxx

xxx

xxx





Previous Format


Section 1 - PAID WORKERS for APRIL (continued)


4. Fill out the table below for the workers paid to do agricultural work the week of April 8th through April 14th. Report workers who fall under the same worker code on a single line.


  • Record each worker only once

  • Report only one week of hours and wages for the reference week

  • Base wages include the minimum amount paid regardless of method of pay (salaried, hourly, piece rate, etc.) but exclude incentive pay

  • Incentive pay includes bonuses, performance pay, hazard pay, overtime pay, etc. that is paid in addition to the base wages.


INCLUDE:

  • Workers directly hired and paid by the farm operation

  • Part-time workers, paid family members, and hired managers

  • Workers on paid leave (sick or vacation) (include typical hours and wages for the week)


EXCLUDE:

  • Contract and custom workers

  • Retail workers and “value-added” workers



Worker Code

(select from list on page 5)

Number

of Paid Workers

That Week

Total Hours Worked

That Week

Total Gross Wages

Paid That Week


(Dollars)

Total Base Wages

Paid That Week


(Dollars)

Total Incentive & Overtime Wages

Paid That Week


(Dollars)

Example: 12

612 60

613 3000

614 $42,000

xxx $36,000

xxx $6000

Example: 32

612 2

613 100

614 $1,400

xxx $1,400

xxx $ 0

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx

611

612

613

614

Xxx

Xxx









NASS plans to continue to publish the data for the 4 worker categories, to maintain the historic data series. With the new data, NASS plans to expand the publication of SOC based worker class wages (at least) at the regional level (the regions will remain unchanged from historically reported regions). The publication may also include number of workers by SOC-based class, and possibly hours/worker. NASS is looking into the publishing of these quarterly or semi-annually, however, only the annual average estimates will be used by the Department of Labor (DOL).  Currently, NASS only publishes these SOC-based worker classes at the US-level for each quarter.

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.


Web-based data reporting is available for these surveys. The percent of operators who responded by internet in April 2017 was 2.8% and in October 2017 was 1.6%.


Both the standard survey and the bridge survey will be available for completion on the internet.


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.


The National Agricultural Statistics Service cooperates with State departments of agriculture and land grant universities to conduct agricultural surveys. These surveys meet both State and Federal needs, thus eliminating duplication and minimizing reporting burden on the agricultural industry. For example, NASS has worked jointly with the California Employment Development Department (EDD) since January 1997 to use one labor questionnaire for both organizations. This administrative data provided to NASS by EDD eliminates the need for operators to report similar data to two government agencies. Respondent burden is reduced by collecting data for both the State of California and USDA during only one data collection effort.


In 2013 NASS entered into a cooperative agreement with the Department of Labor (DOL) in which NASS would continue to collect and summarize agricultural farm data. Through this agreement NASS has begun the process of expanding data collection to allow NASS results to be published using the DOL Standard Occupational Codes when possible.


The Agricultural Labor Survey is the only timely and reliable source of information on the size of the farm worker population. The data collected on this survey are not available from any other source.


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 burden.


Information requested for agricultural labor can be provided with a minimum of difficulty by the respondent. Farms using a small number of workers generally provide the needed data without having to consult their record books, while large labor users can respond by using their normal day-to-day operating records.


Generally a pre-survey cover letter and sample of the questionnaire are mailed to respondents, alerting them that an interviewer will be contacting them. The sample questionnaire familiarizes respondents with the questions that will be asked and provides them with the opportunity to record the information in advance of the enumerator contact. This reduces interview time and allows the respondent to assemble the needed information at his or her convenience. If respondents prefer to provide their data over the internet, that option is available through our Electronic Data Repository (EDR) system. Instructions on how to access the EDR system are included with the pre-survey letter.


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.


Prior to 2013 NASS conducted the Agricultural Labor Survey on a quarterly basis and published the results quarterly. In 2013 NASS began collecting quarterly farm labor data by contacting respondents only twice a year. The April survey collected data for the October-December and January-March quarters. The October survey collected data for the April-June and July-September quarters. This was done in order to cut data collection costs. Although quarterly data was being published it was only made available twice a year (following each biannual survey). As a result the data was not as timely as some data users are needing. NASS plans to return to the quarterly release of data once the new program changes are implemented.


Collecting information less frequently would not produce the timely estimates required to monitor seasonal variations in the agricultural labor work force or provide data for government needs as required by law.


7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with the general information guidelines in 5 CFR 1320.5.


There are no special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.


8. 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.


The Notice soliciting comments on this collection was published in the Federal Register on October 6, 2017 on page 46753. The notice announced the intent to renew the data collection project for 3 years. NASS received only one public comment; Farm Worker Justice (a national advocacy organization) is in support of the continuation of the Agricultural Labor survey. Their comments and NASS’s response are both included as attachments to this renewal.


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 record-keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.


NASS stays in close contact with Department-level personnel involved with agricultural labor policy. In addition, each year NASS conducts a series of meetings at various sites across the United States to maintain a dialogue with farmers and industry leaders to discuss issues relevant to NASS programs. Agricultural labor is one of the areas highlighted in these meetings. Consultations with the Department of Labor, the Economic Research Service, and the Bureau of Economic Analysis are ongoing.


In response to a request from the USDA Department Headquarters the survey program will be expanded to collect wage rates with greater detail. Beginning in April 2018 NASS began conducting a bridge study to collect data for base, incentive, and overtime wages. The study will be continued in October of 2018. Additional information on this can be found in Supporting Statement B.


9. Explain any decision to provide any payment or gift to respondents.


There are 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.


Questionnaires include a statement that individual reports are confidential. U.S. Code Title 18, Section 1905; U.S. Code Title 7, Section 2276; and Public Law 107-347, Title V (CIPSEA) provide for confidentiality of reported information. All employees of NASS and all enumerators hired and supervised under a cooperative agreement with the National Association of State Departments of Agriculture (NASDA) must read the regulations and sign a statement of compliance.


Additionally, NASS employees and NASS contractors comply with the OMB implementation guidance document, “Implementation Guidance for Title V of the E-Government Act, Confidential Information Protection and Statistical Efficiency Act of 2002 (CIPSEA).” CIPSEA supports NASS’s pledge of confidentiality to all respondents and facilitates the agency’s efforts to reduce burden by supporting statistical activities of collaborative agencies through designation of NASS agents, subject to the limitations and penalties described in CIPSEA.


The following confidentiality pledge statement will appear on all NASS questionnaires.


The information you provide will be used for statistical purposes only. Your responses will be kept confidential and any person who willfully discloses ANY identifiable information about you or your operation is subject to a jail term, a fine, or both. This survey is conducted in accordance with the Confidential Information Protection provisions of Title V, Subtitle A, Public Law 107-347 and other applicable Federal laws. For more information on how we protect your information please visit: https://www.nass.usda.gov/confidentiality.


11. Provide additional justification for any questions of a sensitive nature.


There are no questions of a sensitive nature.


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


Burden hour calculations are shown below. The minutes-per-response figures come from telephone and field enumerator experience with previous labor surveys.


Cost to the public of completing the questionnaire is assumed to be comparable to the hourly rate of those requesting the data. Reporting time of 44,901 hours is multiplied by $36.66 per hour for a total cost to the public of $1,646,070.66.


NASS uses the Bureau of Labor Statistics’ Occupational Employment Statistics (most recently published on March 30, 2018 for the previous May) to estimate an hourly wage for the burden cost. The May 2017 mean wage for bookkeepers was $19.76. The mean wage for farm managers was $38.62. The mean wage for farm supervisors was $24.11. The mean wage of the three is $27.50. To calculate the fully loaded wage rate (includes allowances for Social Security, insurance, etc.) NASS will be adding an additional 33% for a total of $36.66 per hour.


13. Provide an estimate of the total annual cost burden to respondents or record-keepers resulting from the collection of information.


There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.


14. Provide estimates of annualized cost to the Federal government; provide a description of the method used to estimate cost which should include quantification of hours, operational expenses, and any other expense that would not have been incurred without this collection of information.


The total cost to the Federal government for the agricultural labor survey for Fiscal Year 2019 is an estimated $6.2 million. Currently there is a proposal before the President to increase the budget for the Agricultural Labor program by $5 million for Fiscal Years 2019 and 2020. This proposed increase in funding is in response to moving the survey from a biannual survey back to a quarterly survey and increasing the sample size to allow for reporting SOC data at a regional level rather than at a US level.


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


This is a revision of a currently approved information collection. The majority of the increase in the number of responses and burden hours is due to a change in the sample sizes and frequency of the data collection. The expected increase in funding will allow NASS to resume collecting data on a quarterly basis as well as increase the sample size to provide enough useable data to publish regional estimates rather than just US level estimates for the different SOC codes.



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.


Agricultural labor survey data collection procedures include periodic national training schools for statisticians and regular training sessions for enumerators conducted by each field office.


Quarterly data are collected during the 2-week period following the survey reference week, which is the Sunday through Saturday period containing the 12th day of the survey months (January, April, July and October). This is the same week specified by other government agencies which deal with employment and wage series. Attached to this supporting statement are the survey questionnaires, as shown in the table below. List and area frame samples use the same questionnaires. The primary farm operator questionnaire is used in all States’ except for California. The quality control sheet is also attached. Estimates are published approximately 30 days after the survey reference date. All agricultural labor releases can be found on the Web at:


http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1063.



The NASS Farm Labor Survey publication will continue to include the same summarized data tables using the Deptartment of Labor’s Employment and Training Administration’s (ETA) worker categories that were historically published, and can be found at the following link.


When sufficient data is available NASS will begin to publish the expanded data for regions and for more SOC codes that were suppressed in the past due to confidentiality rules. The larger sample size should allow for this additional data to be published.

In November, 2015 NASS expanded the publication to include tables with farm labor data summarized using the Standard Occupational Classification (SOC) codes. (See attachment)


Historically, the ETA codes 41 – 44 (Other Farm Labor) were not published independently but were included in “all hired workers” less field and livestock workers and supervisors. Since there are not direct links between these codes and the SOC codes, or the data collected is insufficient, they will be excluded from the new portion of the publication.


NASS quality measures and methodology reports can be found at the following link


https://www.nass.usda.gov/Publications/Methodology_and_Data_Quality/Farm_Labor/index.php.


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.


There is no request for approval of non-display of the expiration date.


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


There are no exceptions to the certification statement.


September 2018

3


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