Ams-71

SD_AMS_71_Grid_OLPP_2021.xlsx

NOP: Organic Livestock & Poultry Standards

AMS-71

OMB: 0581-0293

Document [xlsx]
Download: xlsx | pdf

Overview

AMS Grid
Table of Responders
Tables for narratives
Q15 breakout Overall ICR 01 21

Sheet 1: AMS Grid
INSTRUCTIONS: Use this form when a single information collection document involves multiple reporting and recordkeeping requirements. The totals of the figures in cols. should be entered in item 13 of OMB-83-1: cols. (D) &/or (I) = 13a (respondent is only counted once); cols. F & I = 13b; cols. H & K = 13c. (F)Total/(D)Total = (E)Average (H)Total/(F)Total = (G)Average (K)Total/(I)Total = (J)Average
NOTE: The columns will calculate automatically. If Col. E's response is something other than annually, i.e., 1/6 years, list as "1/6" & decimal will display. 		TITLE OF INFORMATION COLLECTION DOCUMENT OMB NO. 0581-0293
National Organic Program: Organic Livestock and Poultry Practices Proposed Rule

DATE PREPARED





August 11, 2021
IDENTIFICATION OF REPORTING OR RECORDKEEPING REQUIREMENT
ANNUAL BURDEN








REPORTS RECORDS






FORMS NO (S) NO. OF NO OF TOTAL ANNUAL HOURS TOTAL NO. OF ANNUAL TOTAL
SECTION OF DESCRIPTION (If "none" RESPONDENTS RESPONSES RESPONSES PER HOURS RECORD- HOURS PER RECORD-
REGS.




so state)
PER (Col. D x E) RESPONSE (Col. F x G) KEEPERS RECORD- KEEPING HOURS








RESPONDENT



KEEPER (Col. I x J)
(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)

Producers and Handlers (Operations)








205.101(c) Subpart B -- APPLICABILITY exempt producers and handlers (11.5% of current total certified that are exempt from organic certification) document compliance and maintain records for not less than 3 years.
 None

0.00
0.00 713 1.00 713.10
205.103 Certified operators maintain records for not less than 5 years None

0.00
0.00 6,538 2.00 13076.53

Subpart C - Production & Handling Requirements and E --Certification








205.200, .201, .400, .401, &.406 New operations submit their initial organic system plan: including one-time preparation of all practices, procedures, and information necessary to comply with new livestock and poultry requirements. None 364 1.00 364 4.00 1,457.06


205.200, .201, .400, .401, &.406 Current certified operations submit updated Organic System Plan (OSP): including one-time preparation of all practices, procedures, and information necessary to comply with new livestock and poultry requirements None 6174 1.00 6174 4.00 24,696.00


205.403 Curent and new livestock and poultry operations first on-site inspection that includes new livestock and poultry practices and procedures None 6538 1.00 6538 2.00 13076.53













205.405(b) (2)
None

0.00
0.00


205.663
None

0.00
0.00


205.681(a)
None

0.00
0.00



PRODUCERS and HANDLERS SUBTOTAL
6,538
13,077
39,230 7,251 3 13,790

TOTAL OF ALL PAGES
7,559
33,363
88,183 7,309 5 13,905
TOTAL - "F30" = OMB 831, 13 b; "H30" = OMB 831, 13c


40,673
102,088


INSTRUCTIONS: Use this form when a single information collection document involves multiple reporting and recordkeeping requirements. The totals of the figures in cols. should be entered in item 13 of OMB-83-1: cols. (D) &/or (I) = 13a (respondent is only counted once); cols. F & I = 13b; cols. H & K = 13c. (F)Total/(D)Total = (E)Average (H)Total/(F)Total = (G)Average (K)Total/(I)Total = (J)Average. NOTE: The columns will calculate automatically. If Col. E's response is something other than annually, i.e., 1/6 years, list as "1/6" & decimal will display. TITLE OF INFORMATION COLLECTION DOCUMENT OMB NO. 0581-0293
National Organic Program: Organic Livestock and Poultry Practices Proposed Rule

DATE PREPARED

August 11, 2021
IDENTIFICATION OF REPORTING OR RECORDKEEPING REQUIREMENT
ANNUAL BURDEN







REPORTS RECORDS






FORMS NO (S) NO. OF NO OF TOTAL ANNUAL HOURS TOTAL NO. OF ANNUAL TOTAL
SECTION OF DESCRIPTION (If "none" RESPONDENTS RESPONSES RESPONSES PER HOURS RECORD- HOURS PER RECORD-
REGS.




so state)
PER (Col. D x E) RESPONSE (Col. F x G) KEEPERS RECORD- KEEPING HOURS








RESPONDENT



KEEPER (Col. I x J)
(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)

Accredited Certifying Agents - Certification








205.402 Review of Application/Updates
agents review and process OSP applications/updates from livestock and poultry operations in compliance with new requirements for the first time and maintain records		 None 57.00 114.71 6538.27 2.00 13076.53 57.00 1.00 57.00
205.404(b) 205.406(d) Provide information and training to operations regarding livestock and poultry requirements None 57.00 1.00 6538.27 3.00 19,614.80














Accredited Certifying Agents - Accreditation








205.501 (a)(2-4), (6-7), (11)(v), (15) & (20-21); 205.503 (a -b), (d)(1-2) & (c-e); 205.504(a -e); 205.510(a)(1-2), and 205.642 Accreditation of Certifying Agents - Form TM-10CG - Provide Policies, Procedures, Evidence of Expertise and Ability, describe organizational units, primary location, areas of certification (crops, livestock, & handling), States & foreign countries where they operate, lists of currently certified operations, conduct & provide results of performance evaluations of personnel & inspectors, conduct program evaluations of their certification activities, provide procedures for residue testing, and other information that will assist in evaluating their application, and comply with any other requirements. Includes one-time preparation of practices and procedures necessary to comply with new livestock and poultry practice requirements TM-10CG 57.00 1.00 57.00 2.00 114.00 57.00 1.00 57.00
205.501 (a)(4)-(a)(6) Provide training to Certification Review Personnel and Inspectors regarding new livestock and poultry practices
57.00 2.00 114.00 5.00 570.00


205.501 (a)(4)-(a)(6) Certification Review Personnel receive training regarding new livestock and poultry practices
250.00 1.00 250.00 5.00 1,250.00

























57.00
13,497.53
34,625.33 57.00 2.00 114.00













































INSTRUCTIONS: Use this form when a single information collection document involves multiple reporting and recordkeeping requirements. The totals of the figures in cols. should be entered in item 13 of OMB-83-1: cols. (D) &/or (I) = 13a (respondent is only counted once); cols. F & I = 13b; cols. H & K = 13c. (F)Total/(D)Total = (E)Average (H)Total/(F)Total = (G)Average (K)Total/(I)Total = (J)Average
NOTE: The columns will calculate automatically. If Col. E's response is something other than annually, i.e., 1/6 years, list as "1/6" & decimal will display. 		TITLE OF INFORMATION COLLECTION DOCUMENT OMB NO. 0581-0293
National Organic Program: Organic Livestock and Poultry Practices Proposed Rule


DATE PREPARED
August 11, 2021
IDENTIFICATION OF REPORTING OR RECORDKEEPING REQUIREMENT
ANNUAL BURDEN







REPORTS RECORDS






FORMS NO (S) NO. OF NO OF TOTAL ANNUAL HOURS TOTAL NO. OF ANNUAL TOTAL
SECTION OF DESCRIPTION (If "none" RESPONDENTS RESPONSES RESPONSES PER HOURS RECORD- HOURS PER RECORD-
REGS.




so state)
PER (Col. D x E) RESPONSE (Col. F x G) KEEPERS RECORD- KEEPING HOURS








RESPONDENT



KEEPER (Col. I x J)
(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K)

Subpart E Certification - On-site Inspections












205.403 205.406(b) Inspectors provide on-site inspection reports addressing new requirements for livestock and poultry operations to the certifying agent None 250.00 26.15 6538.27 2.00 13076.53

0.00
205.501 (a)(4)-(a)(6) Inspectors receive 5 hours of training per new livestock and poultry practices
250.00 1.00 250.00 5.00 1,250.00




































Subpart G Administrative -State Organic Program












205.621(a) State Organic Programs
States submit proposed State organic program to Secretary		 None 0.00
0.00
0.00

0.00
205.621(c) States update State organic program to the Secretary. None 1.00 1.00 1.00 2.00 2.00 1.00 1.00 1.00

SUBTOTAL
251.00
6789.27 ` 14328.53 1.00
1.00















Sheet 2: Table of Responders
Supplemental Sheets
the numbers are correlated to the new revised grid

































REPORTING HOURS 0.59 0.41
















total operations

total handlers domestic total handlers international
Domestic Internataional









US Operations - New and Existing US Foreign Based Operations Foreign Ops - - New and Existing Foreign Operations - formerly excluded US Based Certifiers US Foreign Based Certifiers Foreign Governments Foreign Accredited Foreign Certifiers Domestic Inspectors Foreign Inspectors Misc. (Petit-ioners) State Organic Program

% Domestic Certifiers % USDA Foreign Certifiers



2501

41698
24558 10030 7110 New Excluded Handlers 961 961 developing a benchmark approach 1922

23,145.46 16,084.13

Frances, Valerie - AMS: Certification activities 19,287.88 13,403.45 32,691.33
Frances, Valerie - AMS: Inspection reports 7,715.15 5,361.38 - 2.00
78 0.59 0.41



41688 0.059993283438879
exempt operations - 11.5% of total - NASS
2824.17

Import Certificate # of shipments 67023 fas website database - need link













Frances, Valerie - AMS: training 737.50 512.50



46.02 31.98











% compromised shipments need a rationale










Frances, Valerie - AMS: activities under accreditation section 1,141.06 792.94 1,934.00




1,934.00
663569.150315281 14419.1471168031







17866


# of foreign nonusda certifying agents
certifiers accredited by other organic standards

































export certificates (fas webpage) 565821000 2.01 billion imported into us us organic exports represent 27% of oranic import sales - export shipments = 27% of import certifcates (67023) = 18,384 export certificates





























new nonretail label number of us handlers plus new formerly excluded handlers & private label handlers 1 hour per label 20 labels


50,000 organic UPCs manufactured by 17140 currently certified handlers and 30% or 15,000 labels manufactured by 30% or 5142 handlers will need to be relabeled by to show correct certifying agent. All labels are modified within 42 months so 25% of 1286 handlers or 3750 labels per year will be modified per year to accommodate this change at that time





























private labels not yet determined


































unannounced inspections 5% 2.5% meet full inspection criteria 2.5% are focused on specific issues and can include the trace back audits - will be additional inspections above the 100% annual
































qualifications & training inspectors & employees 500 - 250 contract inspectors plus 250 employee reviewers 20 hours
































equivalency go with accreditation model of 60 hours per year


































appeals no new requirements


































traceability counted among the unnannounced audits above traceback audits



















































































































Total 23,145.46 16,084.13 - - 20,428.94 14,196.39
- 8,452.65 5,873.88 - 2.00 88,183.46
























39229.60

34,625.33


14,326.53

2.00 88,183.46






















RECORDKEEPING HOURS




































Producers Exempt Producers Certifiers


Inspectors Petitioner State Organic Program



























13,076.53 713.10 57.00




1.00





























57.00





































































Total 13,076.53 713.10 114.00 - - - - - 1.00 13,904.63

102,088.09

























Internat'l Benefits US Benefits

$1,684,480.79




























SUMMARY TABLE

34.63% 31.30% 34,625.33 $1,463,427.65 114.00 $4,818.17 $1,468,245.82 34,739.33 609.46 $25,758.70























Respondent Categories Number of Respondents Wage Category Wage Rates May 2020 Wage + 31.3% Benefits Total Reporting Hours Total Reporting Costs Total Record keeping Hours Total Record Keeping Costs Total All Costs Total All Hours Total hours per respondent Total cost per respondent type























Certified Producers & Handlers - New and Existing Domestic 3857.58 11-9013 Farmers, Ranchers, and other Agricultural Managers https://www.bls.gov/oes/current/oes119013.htm $36.93 $48.49 23,145.46 $1,122,302.37 7,715.15 $374,100.79 $1,496,403.16 30,860.62 8.00 $387.91 $1,530,980.59 Total cost for all US Based Operations





















Exempt Producers & Handlers 713.10 11-9013 Farmers, Ranchers, and other Agricultural Managers $36.93 $48.49 0.00
713.10 $34,577.42 $34,577.42 713.10 1.00 $48.49

$2,280,551.82 all operations



















Certified Producers & Handlers - New and Existing Foreign 2680.69 11-9013 Farmers, Ranchers, and other Agricultural Managers $25.96 $34.95 16,084.13 $562,178.42 5,361.38 $187,392.81 $749,571.23 21,445.51 8.00 $279.62 $749,571.23 Total cost for all foreign based operations























11-9013 Farmers, Ranchers, and other Agricultural Managers

































US Based Certifiers 34 13-1041 Compliance Officers https://www.bls.gov/oes/current/oes131041.htm $36.35 $47.73 20,428.94 $975,023.48 67.26 $3,210.16 $978,233.63 20,496.20 609.46 $29,088.12 $29,088.12 total cost for a US Based Certifiers
























































US Foreign-Based Certifiers 23 World Bank OECD Wage rates $25.55 $34.40 14,196.39 $488,404.17 46.74 $1,608.02 $490,012.19 14,243.13 609.46 $20,967.57 $20,967.57 total cost for a foreign Based Certifiers

























































US based Inspectors 148 45-2011 Agricultural Inspectors $23.38 $30.70 8,452.65 $259,479.06 0.00 $0.00 $259,479.06 8,452.65 57.31 $1,759.18

$3,027.25 all inspectors



















Foreign based inspectors 103 45-2011 Agricultural Inspectors $16.44 $22.13 5873.88 $129,977.03

$129,977.03 5,873.88 57.31 $1,268.07






































































































































State Organic Program 1 13-1041 Compliance Officers $36.35 $47.73 2.00 $95.46 1.00 $47.73 $143.18 3.00 3.00 $143.18























total reporting & recordkeeping respondents 7,559


88,183.46 3,537,459.99 13,904.63 600,936.92 4,138,396.91 102,088.09

























Domestic & Foreign



2.64
1.90




























Recordkeeping respondents (less petitioners and inspectors) plus exempt operations 7,309


average reporting hours per response average recordkeeping hours per response



























all reporting respondents (minus excluded operations ) 6,846


2.50999084324217



























all responses per all respondents 5.38


average all reporting and recordkeeping hours per response hours per response



























reporting responses per reporting respondents 5


Domestic & Foreign Responses All Domestic Only



























recordkeeping responses per recordkeeping respondents 1


total all responses 40,672.69
23,996.89



























Just certified organic now 6174.00


reporting responses 33,363.33
19,684.36
































recordkeeping responses 7,309.36
4,312.52






























all domestic hours

40,672.69

-


























Just Domestic # of respondents responses per respondents 60,522.57 just domestic Reporting hours Reporting Costs recordkeeping hours Recordkeeping costs Total Costs total all domestic hours

























all reporting & recordkeeping respondents 4,752 5.05 2.52 hours per response 52,027.06 $2,356,804.91 8,495.51 $411,888.37 $2,768,693.28 60,522.57

























just reporters 4,752 4.14 2.64
































recordkeepers 4,604 0.94 1.97










































































































6538
State Certifier Breakout for OMB 81-I question #13




































Total US Certifiers Burden Hours Total State Certifier Burden Hours Total responses of certifying agents Total State Certifier Responses



0.52
























Number of Responders
State Certifiers
Err:509 # of responses per state in one year


























All Operations 7251.36





Err:509 hours per response for states


























USDA Certifiers 78.00 16 20496.20 4,204.35 Err:509 Err:509




























Domestic Based with only domestic ops with no involvement in imports Err:509

































Domestic Based with Foreign Ops Err:509

































USDA Accredited Foreign Based Certifying Agents 32.00

































Foreign Governments


































Foreign Accred Certifiers 0.00

































Inspectors & Inspecting staff 500.00

































Petitioners 0.00


































Err:509




































Total Responses #13b



































40,672.69

































Domestic


































Table 2 Reporting


































Excluded Handlers Err:509
International
































Currently Certified Operations Err:508 Record-Keeping Reporting Record-Keeping































Farmers
Err:509 Err:509 Err:509



Err:508


























Handlers

Err:508















































































































































Organic Integrity Database 08/7/2019













































recordkeeping


























All % united states % reporting recordkeeping international % reporting


























All Certified 42309
27217 0.643291025550119

15092 0.356708974449881



























Certified farms 29325 0.69311494008367 19358 0.660119352088662

9967 0.339880647911338



























Certified handlers 12984 0.30688505991633 7859 0.605283425754775

5125 0.394716574245225




























42309
27217

































0
0
































subtracted the double double certified


































from handlers













































































































Livestock 6362


































new applicants 6.13% 2593.5417


































exempt operations (<$5000) (11.5%) 4865.535


































exempt handlers (3.18% of exempt) 154.724013


































Sheet 3: Tables for narratives
Table 1: Summary of Reporting Burden

Table 2: Summary of Recordkeeping Burden




USDA Certified Operations Reporting Burden Number of Respondents Total Reporting Hours Wage + Benefits Total Reporting Costs

USDA Certified Operations Recordkeeping Burden Number of Respondents Total Recordkeeping Hours Wage + Benefits Total Recordkeeping Costs




USDA Certified Producers & Handlers - New and Existing Domestic 3,858 23,145 $48.49 $1,122,302

USDA Certified Producers & Handlers - New and Existing Domestic 3,858 7,715 $48.49 $374,101




USDA Certified Producers & Handlers - New and Existing Foreign 2,681 16,084 $34.95 $562,178

USDA Certified Producers & Handlers - New and Existing Foreign 2,681 5,361 $34.95 $187,393




USDA Certified Producers & Handlers - New and Existing - All 6,539 39,229
$1,684,480

Exempt Producers ((11.5% of current total certified that are exempt from organic certification)) 713 713 $48.49 $34,577

$2,280,551 52,305 7.21249310535025



USDA Certified Producers & Handlers - New and Existing - All 7,252 13,076
$596,071

$314.47

USDA Accredited Certifiers Reporting Burden Number of Respondents Total Reporting Hours Wage + Benefits Total Reporting Costs







US Accedited US-Based Certifers 34 20,429 $47.73 $975,023

USDA Accredited Certifiers Recordkeeping Burden Number of Respondents Total Recordkeeping Hours Wage + Benefits Total Recordkeeping Costs
$1,468,245


US Accredited Foreign-Based Certifiers 23 14,196 $34.40 $488,404

US Accedited US-Based Certifers 34 68 $47.73 $3,210

$25,758.68
114.719298245614
US Certifers - All 57 34,625
$1,463,427

US Accredited Foreign-Based Certifiers 23 47 $34.40 $1,608







US Certifers - All 57 115
$4,818

34,740 609.473684210526
Inspectors Reporting Burden Number of Respondents Total Reporting Hours Wage + Benefits Total Reporting Costs




$1,557.82

US Based Inspectors 148 8,453 $30.70 $259,479

State Organic Programs Recordkeeping Burden Number of Respondents Total Recordkeeping Hours Wage + Benefits Total Recordkeeping Costs

57.308

Foreign Based Inspectors 102 5,874 $22.13 $129,977

State Organic Programs 1 1 $47.73 $48




Inspectors - All 250 14,327
$389,456

SOP - All 1 1.00 $47.73 $48







Total Recordkeeping Burden - All Respondents 7,309 13,905
$600,937




State Organic Programs Reporting Burden Number of Respondents Total Reporting Hours Wage + Benefits Total Reporting Costs











State Organic Programs 1 2 $47.73 $95











SOP - All 1 2
$95











Total Reporting Burden - All Respondents 6,846 88,183
$3,537,460











Sheet 4: Q15 breakout Overall ICR 01 21
SUMMARY OF OLPP 2021 - NEW INFORMATION COLLECTION - #0581-0293 Q15 Breakout
REGS REG Text Previous Burden New Burden 2021 Difference Between New and Previous Burden Type of Change

Producers and Handlers (Operations)



205.101(c) Subpart B -- APPLICABILITY exempt producers and handlers (11.5% of current total certified) document compliance and maintain records for not less than 3 years. National Agricultural Statistic Service (NASS) estimates that exempt producers represent 11.5% of the total number of certified organic producers. The difference is due to aligning with NASS's estimate, rather than guestimating.
 0.00 713.10 713.10 ADJ
205.103 Certified operators maintain records for not less than 5 years. Corrected recordkeeping from 80 hours to 40 hours. Recordkeeping is an act of routine storage, and is not labor intensive. Records are also kept to comply with other requirements, such as the Internal Revenue Service (IRS) and State Business Licensing requirements. The total hours are not halved from the prior renewal package because the number of farmers have increased from 31,000 to 44,805. 0.00 13,076.53 13,076.53 ADJ


0 13,790 13,790

Subpart C & E - Production & Handling -- Operators submit initial application or update existing Organic System Plan (OSP)



205.200, .201, .400, .401, &.406 New operations submit their initial organic system plan: including one-time preparation of all practices, procedures, and information necessary to comply with new livestock and poultry requirements. 0.00 1,457.00 1,457.00 ADJ
205.201(a)(1) - (6),205.400(b), 205.401d, 205.406(a)(1)(i) 205.406(a)(3) Current certified operations submit updated Organic System Plan (OSP): including one-time preparation of all practices, procedures, and information necessary to comply with new livestock and poultry requirements 0.00 24,696.00 24,696.00 ADJ
205.403 Curent and new livestock and poultry operations first on-site inspection that includes new livestock and poultry practices and procedures 0.00 13,076.53 13,076.53 ADJ


0.00 39,230 39,230

Accredited Certifying Agents - Certification



205.402 Review of Application/Updates
agents review and process OSP applications/updates from livestock and poultry operations in compliance with new requirements for the first time		 0.00 13,076.53 13,076.53 ADJ
205.402 New Record storage-one time 0 57.00 57.00 ADJ
205.404(b) 205.406(d) Agents provide information and training to operations regarding livestock and poultry requirements
19,614.80 19,614.80 ADJ


0.00 32,748 32,748

Accredited Certifying Agents - Accreditation



205.501 (a)(2-4), (6-7), (11)(v), (15) & (20-21); 205.503 (a -b), (d)(1-2) & (c-e); 205.504(a -e); 205.510(a)(1-2), and 205.642 Accreditation of Certifying Agents - Form TM-10CG - Provide Policies, Procedures, Evidence of Expertise and Ability, describe organizational units, primary location, areas of certification (crops, livestock, & handling), States & foreign countries where they operate, lists of currently certified operations, conduct & provide results of performance evaluations of personnel & inspectors, conduct program evaluations of their certification activities, provide procedures for residue testing, and other information that will assist in evaluating their application, and comply with any other requirements. Includes one-time preparation of practices and procedures necessary to comply with new livestock and poultry practice requirements 0.00 114 114.00 ADJ
205.501 (a)(2-4), (6-7), (11)(v), (15) & (20-21); 205.503 (a -b), (d)(1-2) & (c-e); 205.504(a -e); 205.510(a)(1-2), and 205.642 New Record storage- one-time 0.00 57.00 57.00 ADJ
205.501 (a)(4)-(a)(6) Provide training to Certification Review Personnel and Inspectors regarding new livestock and poultry practices 0.00 570.00 570.00 ADJ
205.501 (a)(4)-(a)(6) Certification Review Personnel receive training regarding new livestock and poultry practices 0.00 1,250.00 1,250.00 ADJ


0.00 1,991.00 1,991.00

Accredited Certifying Agents - Certification + Accreditation 0.00 34,739 34,739

Subpart E Certification - Inspectors



205.403 205.406(b) Inspectors provide on-site inspection reports addressing new requirements for livestock and poultry operations to the certifying agent 0.00 13,076.53 13,076.53 ADJ
205.501 (a)(4)-(a)(6) Inspectors receive 5 hours of training per new livestock and poultry practices 0.00 1,250.00 1,250.00 ADJ


0.00 14,326.53 14,326.53







Subpart G Administrative -State Organic Program



205.621(c) States update State organic program to the Secretary. Reporting. Not properly accounted for in prior years. 0.00 2.00 2.00 ADJ
205.621(c) States update State organic program to the Secretary. Recordkeeping. Not properly accounted for in prior years. 0.00 1.00 1.00 ADJ


0.00 3.00 3.00
TOTAL
0.00 102,088 102,088
























































































































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