1652-0053 Ccsp_ss_2024 (9.4.2024)

INFORMATION COLLECTION SUPPORTING STATEMENT

Certified Cargo Screening Standard Security Program

OMB Control Number 1652-0053

Exp.: 9/30/2024

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. (Annotate the CFR parts/sections affected).

The Transportation Security Administration (TSA) currently requires 100 percent screening of all cargo transported on passenger aircraft pursuant to a requirement in section 1602 of the Implementing Recommendations of the 9/11 Commission Act of 2007, Pub. L. 110-53 (121 Stat. 266, Aug. 3, 2007) (9/11 Act.)¹ The screening of air cargo must be in a manner approved by TSA and be commensurate with the level of security for the screening of passenger checked baggage.² To support implementation of this requirement, TSA created the Certified Cargo Screening Program (CCSP) through a regulation codified at 49 CFR part 1549. Under this program, TSA certifies qualified facilities as Certified Cargo Screening Facilities (CCSF) to screen air cargo. Section 1941 of the TSA Modernization Act of 2018 directs TSA to develop and issue standards for the use of third-party canine teams for the primary screening of air cargo.³

CCSFs may screen cargo as required by TSA and must implement measures to ensure a secure chain of custody from the point of screening to the point at which the cargo is tendered to the aircraft operator. CCSFs are also required to submit certain information to TSA to determine whether a person or entity meets the standards of their security program.

In the Spring 2020, OMB approved TSA’s request to revise the ICR applicable to this program to address changing conditions in the security of air cargo. Most notably, as a signatory to the Convention on International Aviation (also known as the Chicago Convention), the United States has agreed to apply the standards contained in Annex 17 as promulgated by the International Civil Aviation Organization (ICAO). Amendment 14 of Annex 17 removed the distinction between passenger and cargo operations for international operations and now requires that all cargo be subject to security controls, including screening where practicable, on all international commercial air transport operations.⁴ ICAO provided until June 30, 2021, for member states to implement the above standard.

As a result of the ICAO mandate, there has been an increase in demand for more options to mitigate the cost of screening cargo. To meet this demand, TSA developed a program to certify Third Party Canine-Cargo (3PK9-C) Teams to screen air cargo. TSA incorporated this capability under the framework of the CCSP, providing an opportunity for canine team providers the option to be regulated as CCSFs under 49 CFR part 1549 and approved to use certified 3PK9-C Teams to screen cargo for TSA regulated entities. As part of this program, TSA certifies qualified canine providers as Certified Cargo Screening Facilities-Canine (CCSF-K9) to screen cargo.

All CCSFs are required to allow TSA to assess whether a person or entity meets the standards of the applicable security program requirements. A CCSF-K9 is an inherently mobile capability that can screen cargo at the facility owned and operated by one of TSA's regulated entities. As holders of a TSA-approved security program issued pursuant to 49 CFR part 1549, CCSF-K9s can contract with air carriers and facility-based CCSFs to screen air cargo, on or off airport, with canine explosives detection teams certified as meeting TSA’s standards. The 3PK9-C program approves third-party (non-governmental) certifiers, operating under the 3PK9-C Certifier Order, to evaluate canine teams to determine whether these teams meet the TSA certification standards.

Recognizing non-governmental entities to evaluate 3PK9-C Teams to determine whether these teams meet TSA’s standards for the certification of explosives detection canine teams approved to screen air cargo serves two purposes. First, it ensures effective security. TSA must have confidence that the screening conducted by certified 3PK9-C Teams will protect air cargo by identifying unauthorized explosives, incendiaries, and other destructive substances and protect the air cargo from the introduction of these destructive substances from the time the cargo is screened until it is accepted by an aircraft operator or a foreign air carrier for transport.

To provide this confidence, TSA established uniform processes and standards for approval of 3PK9-C Certifiers, including qualification of personnel who will evaluate canine teams and consistent application of TSA’s criteria for canine teams seeking certification or recertification as a certified 3PK9-C Team. Second, the use of third-party certifiers allows for market-driven expansion of the program. As required by section 1941 of the TSA Modernization Act, no federal funds can be expended for the training or certification of canine teams operating under this program. As with the CCSF-K9s, qualified persons may apply to become a 3PK9-C Certifier. If approved, the 3PK9-C Certifier agrees to comply with an Order issued by TSA under the authority of 49 U.S.C. 46105.

TSA’s three primary security programs issued under 49 CFR part 1549 provide standards for compliance for those entities subject to the program requirements: (1) the Certified Cargo Screening Standard Security Program (CCSSSP), applicable to facility-based CCSFs; (2) the Certified Cargo Security Program-Canine (CCSP-K9), applicable to CCSF-K9s; and (3) the 3PK9-C Certifier Order, applicable to certified 3PK9-C Teams. For purposes of this document, the term “CCSF” will refer both to facility-based CCSFs and CCSF-K9s unless otherwise noted. This program also meets the mandate in Section 1941 of the TSA Modernization Act.

This ICR addresses the collections of information under the full scope of the CCSP, as discussed above. See OMB number 1652-0053. The collection of information is specifically required to address the following requirements of the CCSP: CCSF applications, 3PK9-C Certifier applications, Security Threat Assessment (STA) applications, criminal history records check, recordkeeping information, security program information, 3PK9-C Certifier Order information, reports of significant security concerns, and security coordinator information. Each of these will be discussed further in response to Question 2.

TSA is revising this collection to update the following TSA Forms: 419A, 419B, 419C, 419D and 419E, updating title and removing duplicative data elements. TSA is also making minor changes by updating instructions and removing information no longer required by the applicable security program.

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.

(1a) CCSF Applications. A CCSF applicant is required to submit an application to become a CCSF at least 90 days before the intended date of operation. In addition, once certified as a CCSF, the CCSF is required to submit any changes to the application information as they occur. CCSFs must renew their certification every 36 months by submitting a new complete application. CCSF applicants are required to provide TSA access to their records, equipment, and facilities necessary for TSA to conduct an eligibility assessment. See 49 CFR 1549.7. A CCSF-K9 applicant must also submit an Operational Implementation Plan, described within the CCSP-K9 and any changes to the plan information as they occur.

(1b) 3PK9-C Certifier Applications. TSA requires submission of initial applications, and updates to information in an application, by any person interested in being a 3PK9-C Certifier under the 3PK9-C Certifier Order.

(2a) STA Applications. TSA regulations require CCSF applicants to ensure that individuals performing cargo screening and related functions, and their supervisors have completed an STA conducted by TSA. In addition, TSA regulations require CCSF Security Coordinators (SC) and their alternates to successfully have completed an STA. TSA regulations further require these individuals to submit personally identifiable information so that TSA can perform STAs. See TSA Form 419F, previously approved under OMB control number 1652-0040. See also 49 CFR 1549.103 and 1549.111.

(2b) Criminal History Records Check (CHRC). TSA requires 3PK9-C Certifiers, 3PK9-C Canine teams, employees and authorized representatives, and those authorized to conduct 3PK9-C Program activities with unescorted access to a Security Identification Display Area, screening of air cargo, or carrying of explosives in the air cargo environment, to provide personally identifiable information including fingerprints so that they can undergo a CHRC.

(3) Recordkeeping. TSA requires CCSFs and 3PK9-C Certifiers to maintain records of compliance associated with compliance with all statutes, regulation, directives, orders, security programs, CHRCs, STAs, training, and other recordkeeping requirements.

(4a) CCSF-Required Security Programs. TSA requires CCSFs to accept and operate under a standard security program provided by TSA, accept TSA-initiated amendments, or submit a proposed modified security program or amendment(s) to the designated TSA official for approval initially and periodically thereafter as required.

(4b) The 3PK9-C Certifier Order. The 3PK9-C Certifier Order is provided to persons who apply to TSA to become a 3PK9-C Certifier and agree to implement TSA’s requirements, subject to enforcement for non-compliance. TSA requires 3PK9-C Certifiers to fully implement the requirements in the Order, any TSA-initiated amendments, and to follow specified procedures when submitting requests for modifications to the designated TSA official for approval initially and periodically thereafter, as applicable.

(5) Reports of Significant Security Concerns. TSA requires CCSFs and 3PK9-C Certifiers to report to TSA incidents, suspicious activities, and/or threat information.

(6) Security Coordinator. TSA requires CCSFs and 3PK9-C Certifiers to provide the name and contact information of the SC and one or more designated alternates at the corporate or ownership level.

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.

CCSF and 3PK9-C Certifier applicants have the latitude and flexibility to maintain the required information in a manner that best meets their particular needs, including maintaining the information electronically. CCSF and 3PK9-C Certifier applicants submit applications and related information required under the TSA regulations electronically through email. TSA also accepts paper applications by mail. TSA has systems in place to serve as repositories of information on participating CCSFs and 3PK9-C Certifiers to support the application process, including the STA application and review processes. Individuals submit personally identifiable information required for TSA to conduct STAs via a web-based tool. For those respondents without the resources or desire to submit information electronically, TSA will continue to work with entities to ensure methods are in place to submit and/or maintain the required information in a manner that best meets their needs.

TSA conducted usability testing on TSA Forms 419A, 419B, 419C, 419D and 419E. The purpose of the testing was to obtain feedback on the proposed changes to remove information no longer collected by the CCSSSP and to ensure the documents used plain language and met the current requirements of the Security Program and the CFR. The testing involved 8 participants. One participant was new to the security program, one participant was the current IAC-CCSF Principal Security Specialist (PSS), one participant was a Transportation Security Inspector familiar with the security program and CFRs, one participant was an Industry Engagement Manager, and 4 participants were predominantly IAC PSSs.

TSA found that the participants were able to use the form with ease – able to type into the documents, fonts were legible and overall user friendly. Also, the participants confirmed that the burden for providing the information was similar to TSA’s burden estimates. In addition, the participants confirmed that the forms met the current requirements of the CCSSSP and the CFR.

The participants recommended changes to the metadata of the forms to show the actual title of the TSA forms within the Properties section. Based on this recommendation, TSA updated the metadata of each file to reflect the title of the form. TSA also made minor language corrections, and updated email contact information.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in Item 2 above.

In lieu of an STA application, TSA may accept the following: a current Hazardous Materials Endorsement identified in 49 CFR part 1572 evidenced by a State-issued commercial driver’s license with hazardous materials endorsement; a current Transportation Worker Identification Credential (TWIC^®); a current Free and Secure Trade (FAST) card issued by the U.S. Customs and Border Protection under the FAST program; a criminal history records check that included a name-based check; or, another STA determined by TSA to be comparable to the STA specified in the regulations. In addition, TSA may also accept the following from 3PK9-C Certifier applicants: a current enrollment in one of the following DHS Trusted Traveler Programs: TSA PreCheck^®, Global Entry, NEXUS, or Sentri.

5. If the collection of information has a significant impact on a substantial number of small businesses or other small entities (Item 5 of the Paperwork Reduction Act submission form), describe the methods used to minimize burden.

This collection does not have a significant impact on a substantial number of small businesses or other small entities.

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.

The CCSFs and 3PK9-C Certifiers provide a process through specified programs for the air cargo industry to meet the congressionally mandated requirement to screen 100 percent of all air cargo. TSA must create programs to ensure methods of screening 100 percent of air cargo remain in place. If this information collection is not conducted, the air cargo industry may not be able to screen 100 percent of cargo transported on aircrafts without significant delays, which may have a negative effect on commerce.

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(d)(2).

With the exception of the following, this collection is conducted in accordance with 5 CFR 1320.5(d)(2).

• Information may need to be submitted more than once as CCSFs and 3PK9-C Certifiers are required to submit any changes to their initial application as they occur, which may be more frequently than quarterly.

• Under TSA regulations, for individuals required to undergo an STA (for example, an individual authorized to perform screening functions), TSA notifies the individual’s employer in writing that it has served a Determination of No Security Threat, a Final Determination of Threat Assessment, or a Withdrawal of Final Determination of Threat Assessment, as applicable, to the individual. In the interest of transportation security, the employers are required to retain this notification for 180 days after the employee has separated from the company.

• CCSF-K9 providers and certified 3PK9-C Teams are required to complete certification and recertification events in order to manage and become certified cargo screening canine teams under TSA regulations. All records are retained for 180 days after the individual is no longer a participant of the 3PK9-C Certifier Order and the 3K9-C Program.

• For purposes of TSA’s determination of whether the CCSF or 3PK9-C Certifier has complied with TSA’s requirements, the following records must also be retained for 180 days after the individual is no longer employed by the CCSF or the 3PK9-C Certifier or is no longer acting as the CCSF’s authorized representative:

(1) Records of all training and instruction given to each individual under the security requirements of 49 CFR part 1549, subpart B.

(2) Records demonstrating that each individual has complied with the STA provisions of 49 CFR 1549.111.

The following records must be retained until the next re-certification or until instructed by TSA to retain the records for a longer period, which may be longer than three years:

(1) Copies of all applications for approval or renewal of approval by TSA to operate as a CCSF under 49 CFR part 1549.

(2) Copies of TSA’s approval and renewals of approval as required by 49 CFR part 1549.

(3) Copies of Certification Events for the initial and renewal process.

(4) Copies of records for audits.

8. Describe efforts to consult 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. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d) soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

TSA published a 60-day notice in the Federal Register on March 26, 2024 (89 FR 20991), and published a 30-day notice on September 4, 2024 (89 FR 71920). No comments were received from either notice.

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

TSA will not provide any payment or gift to respondents.

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

While there are no assurances of confidentiality, information provided by individuals will be protected from disclosure to the extent appropriate under the applicable provisions of the Freedom of Information Act and the Privacy Act of 1974. Personal data will be collected and maintained in accordance with the Privacy Act. A Privacy Impact Assessment (PIA) update of DHS/TSA/PIA-019 Air Cargo Security Program is being completed to include the new population of screeners (canine and canine certifiers). PIA coverage is also provided by DHS/TSA/PIA-020 Security Threat Assessment for Airport Badge and Credential Holders. The applicable TSA system of records notice is DHS/TSA-002, Transportation Security Threat Assessment System, last published in the Federal Register on August 11, 2014 (79 FR 46862).

11. Provide additional justification for any questions of sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

TSA will not ask any questions of a sensitive or private nature.

12. Provide estimates of hour and cost burden of the collection of information.

In the following, TSA describes the expanded respondent population and presents a summary of each of the information collections covered by this ICR.

APPLICATIONS

CCSF Applications

Applicants seeking certification to be a cargo screening facility under 49 CFR part 1549 send TSA an application for consideration. TSA estimates an average annual number of CCSF applications to be 120. TSA estimates that each CCSF application requires forty (40) hours to complete, resulting in an annual hour burden of 4,800 hours. TSA assumes CCSF applications are completed by a first-line supervisor with a fully-loaded⁵ hourly wage rate of $46.01⁶, for an annual hour burden cost of $220,861. Table 1 summarizes these estimates.

Table 1: Hour Burden and Costs for CCSF Applications
Annual Number of Applications	Hour Burden per Application	Total Annual Hour Burden	Annual Hour Burden Cost
A	B	C = A × B	D = C × $46.01
120	40	4,800	220,861
Note: Calculations may not be exact due to rounding.

CCSF-K9 Provider Applications

As with CCSFs, CCSF-K9 applicants (providers) seeking certification to screen cargo send TSA an application for consideration. TSA estimates that 3 CCSF-K9 providers will apply annually.⁷ TSA estimates that a CCSF-K9 application will take 40 hours to complete, resulting in an average annual hour burden of 120 hours. TSA assumes these applications are completed by a CCSF-K9 first-line supervisor with a fully loaded wage rate of $78.89,⁸ for a total annual hour cost burden of $9,467. Table 2 summarizes these estimates.

Table 2: Hour Burden and Costs for CCSF-K9 Provider Applications

Population	Annual Number of Applications	Hour Burden per Application	Total Annual Hour Burden	Annual Hour Burden Cost
	A	B	C = A × B	D = C × $78.89
CCSF-K9	3	40	120	$9,467.16

Note: Calculations may not be exact due to rounding.

SECURITY THREAT ASSESSMENTS (STA) APPLICATIONS

CCSFs STA Applications

Certain employees of CCSFs are required to undergo a STA by TSA. TSA estimates there will be 6,859 STA applications per year. TSA estimates it takes each employee approximately 15 minutes (0.25 hours) to complete an application, for an annual hour burden of 1,715 hours. TSA uses a weighted-average fully-loaded⁹ hourly wage rate of $31.94¹⁰. TSA calculates a total annual hour cost burden of $54,764. Table 3 summarizes these estimates.

Table 3: Hour Burden and Costs for CCSF STA Applications
Annual Number of Applications	Hour Burden per Application	Total Annual Hour Burden	Annual Hour Burden Cost
A	B	C = A × B	D = C × $31.94
6,859	0.25	1,715	$54,764

Note: Calculations may not be exact due to rounding.

CCSF-K9 and 3PK9-C Certifier STA Applications

Covered employees working for a CCSF-K9 provider and 3PK9-C Certifier are required to undergo a STA, including a criminal history records check. These entities must demonstrate compliance with the requirement that their covered employees must undergo a criminal history records check. TSA has permitted these covered employees to meet the requirement by applying and receiving an STA through the TSA Pre✓^® Application Program, an Airport Security Program 49 CFR part 1542 regulated airport with a Secure Identification Display Area badge and corresponding STA including CHRC, or an Aircraft Operator Security 49 CFR part 1544 operator STA that requires administration of a CHRC. Data collection burden such as application time and travel burdens would be part of the following TSA existing Information Collection Requests: TSA Pre✓^® Application Program (1652-0059), Airport Security Program 49 CFR part 1542 (1652-0002), Aircraft Operator Security 49 CFR part 1544 (1652-0003).

RECORDKEEPING

CCSFs Recordkeeping

For each employee required to undergo an STA, CCSFs must also maintain records for training, TSA-required internal audits, and STA records per the requirements of the CCSSSP. TSA estimates an average annual number of respondents to be 904 (784 current companies + 120 new companies). TSA assumes the recordkeeping duties will be done by a clerical worker, and uses a fully-loaded hourly wage rate of $27.26¹¹ for these workers.

TSA estimates an annual average number of responses for training records to be 6,859. TSA estimates each response will require a time burden of .033 hours, for an annual hour burden of 229 hours and an annual hour burden cost of $6,232.

TSA estimates an annual average number of responses for internal audits to be 784. TSA will require the respondents to conduct an internal audit and show proof of compliance. TSA estimates each response will require a time burden of 3 hours, for an annual hour burden of 2,352 hours and an annual hour burden cost of $64,115.

TSA estimates an annual average number of responses for STA records to be 6,859. TSA estimates each response will require a time burden of 0.18 hours, for an annual hour burden of 1,258 hours and an annual hour burden cost of $34,279.

TSA estimates an average overall annual hour burden of 3,838 hours for all recordkeeping requirements. TSA estimates an annual average hour cost burden to overall CCSFs at $104,626. Table 4 summarizes these estimates.

Table 4: Total Recordkeeping Hour Burden and Costs for CCSFs
Activity	Number of Responses	Hour Burden	Total Hour Burden	Hour Burden Cost
	A	B	C = A × B	D = C × $27.26
Training	6,859	0.033	228.6	$6,232.46
Internal Audits	784	3	2,352.0	$64,114.63
STA Recordkeeping	6859	0.183	1,257.5	$34,278.52
Total	14,502		3,838.12	$104,625.61
Note: Calculations may not be exact due to rounding.

CCSF-K9 Providers Recordkeeping

For each employee required to undergo an STA, CCSF-K9 providers must also maintain records for certification events, training, internal audits, TSA audits and STAs per the requirements of the CCSP-K9 Security Program. TSA estimates an average annual number of respondents to be 16 (13 current companies + 3 new companies). TSA uses a fully-loaded hourly wage rate of $78.89 for average employee cost for information submission.¹²

TSA estimates an annual average number of responses for certification events to be 228. TSA estimates each response will require a time burden of .38 hours, for an annual hour burden of 87.4 hours and an annual hour burden cost of $6,895.

TSA estimates an annual average number of responses for training records to be 10,800. TSA estimates each response will require a time burden of .03 hours, for an annual hour burden of 360 hours and an annual hour burden cost of $28,401.

TSA estimates an annual average number of responses for internal audits to be 3,600. TSA will require the respondents to conduct an internal audit four times per year for each team, and show proof of compliance. TSA estimates each response will require a time burden of 0.17 hours, for an annual hour burden of 600 hours and an annual hour burden cost of $47,336.

TSA estimates an annual average number of responses for TSA audits to be 174. TSA estimates each response will require a time burden of 0.88 hours, for an annual hour burden of 154 hours and an annual hour burden cost of $12,1263.

TSA estimates an annual average number of responses for STA records to be 10,800. TSA estimates each response will require a time burden of 0.08 hours, for an annual hour burden of 900 hours and an annual hour burden cost of $71,004.

TSA estimates an average overall annual hour burden of 2,101 hours for all recordkeeping requirements. TSA estimates an annual average hour cost burden to overall CCSF-K9s at $165,762. Table 5 summarizes these estimates.

Table 5: Hour Burden and Costs for Recordkeeping for CCSF-K9s
Activity	Number of Annual Responses	Hour Burden per Response	Total Annual Hour Burden	Total Annual Hour Burden Cost
	A	B	C = A × B	D = C × $78.89
Certification Events	228	0.38	87.4	$6,895.25
Training Records	10,800	0.03	360	$28,401.47
Internal Audits	3,600	0.17	600	$47,335.79
TSA Audits	174	0.88	153.7	$12,125.85
STA Records	10,800	0.08	900	$71,003.68
Total	25,602		2,101.1	$165,762.04
Note: Calculations may not be exact due to rounding.

3PK9-C Certifier Recordkeeping

For each employee required to undergo an STA, 3PK9-C Certifier employees must maintain, certification events, audits, training, STA records and other recordkeeping requirements of the 3PK9-C Certifier Order. TSA estimates the average annual number of respondents to be 7 per year. TSA uses a fully-loaded hourly wage rate of $78.89 overall average employee cost for information submission.¹³

TSA estimates an annual average number of responses for certification events to be 638. TSA estimates each response will require a time burden of 0.13 hours, for an annual hour burden of 79.8 hours and an annual hour burden cost of $6,292.

TSA estimates an annual average number of responses for training records to be 63. TSA estimates each response will require a time burden of 0.03 hours, for an annual hour burden of 2.1 hours and an annual hour burden cost of $166.

TSA estimates an annual average number of responses for internal audits to be 12. TSA will require the respondents to conduct an internal audit and show proof of compliance. TSA estimates each response will require a time burden of 0.17 hours, for an annual hour burden of 2 hours and an annual hour burden cost of $158.

TSA estimates an annual average number of responses for TSA audits to be 12. TSA estimates each response will require a time burden of 0.43 hours, for an annual hour burden of 5.2 hours and an annual hour burden cost of $410.

TSA estimates an annual average number of responses for STA records to be 58. TSA estimates each response will require a time burden of 0.08 hours, for an annual hour burden of 4.8 hours and an annual hour burden cost of $381.

TSA estimates an average overall annual hour burden of 93.9 hours for all 3PK9-C Certifier recordkeeping requirements. TSA estimates an annual average hour cost burden of $7,407. Table 6 summarizes these estimates.

Table 6: Hour Burden and Costs for 3PK9-C Certifier Recordkeeping
Activity	Number of Annual Responses	Hour Burden per Response	Total Annual Hour Burden	Total Annual Hour Burden Cost
	A	B	C = A × B	D = C × $78.89
Certification Event	638	0.13	79.8	$6,291.71
Training	63	0.03	2.1	$165.68
Internal Audits	12	0.17	2.0	$157.79
TSA Audits	12	0.43	5.2	$410.24
STA Records	58	0.08	4.8	$381.32
Total	783		93.9	$7,406.74
Note: Calculations may not be exact due to rounding.

SECURITY PROGRAMS/ CERTIFIER ORDER

CCSFs Security Programs

TSA also has a number of burdens associated with the collection of information regarding a CCSF’s Security Program. For each of these burdens, TSA assumes the full-loaded hourly wage rate of $46.01 for first-line supervisors. TSA estimates an average annual number of respondents to be 120.

As discussed in the CCSF Application section, TSA estimates that 120 entities will apply for certification every year. TSA estimates a burden of 40 hours per new certification, resulting in an annual hour burden of 4,800 hours and an annual hour burden cost of $220,861.

Additionally, existing CCSFs must have their Security Program re-certified every three years. TSA estimates an annual average number of re-certifications to be 261 (1/3 of 784 existing CCSFs). TSA estimates each re-certification to require a 3-hour time burden, for an annual hour burden of 790 hours and an annual hour burden cost of $36,350.

TSA processes amendments to certain security programs by request of a regulated CCSF. TSA estimates it will receive one amendment request per year. TSA estimates each requested amendment will place a 1-hour burden on a CCSF, for an average annual hour burden of 1 hour and an average burden cost of $46. If safety and the public interest require an amendment, TSA may amend The CCSSSP.

TSA estimates it will submit 10 amendments per year. Each amendment will take 40 hours to submit, for an annual average of 400 burden hours and an annual hour burden cost of $18,405.

CCSFs must designate and submit the name and contact information of a security coordinator and alternate. TSA estimates there will be 120 submissions which will take 30 minutes (0.50 hours) to submit. TSA estimates the annual hour of 60 hours a year and annual cost of $2,961.

CCSFs must report security incidents to TSA. Of all the respondents, TSA estimates it will get 15 incidents reported a year, which will take 20 minutes (0.33 hrs.) per report. TSA estimates 5 hours annually and an annual cost of $230.

Across all CCSFs Security Program related collections, TSA estimates an annual hour burden of 4,451 and an annual average hour burden cost of $278,653. Table 7 summarizes these estimates.

Table 7: CCSF Security Programs Hour Burden and Costs
Activity	Number of Annual Responses	Hour Burden per Response	Total Annual Hour Burden	Total Annual Hour Burden Cost
	A	B	C = A × B	D = C × $46.01
New Certification	120	40	4,800	$220,861
Recertification	261	3	783	$36,028
Program Amendment	1	1	1	$46
TSA Issued Amendments	10	40	400	$18,405
Security Coordinator Submissions	120	0.5	60	$2,761
Security Incident Reports	15	0.33	5	$230
Total	716		4,451	$278,330.80
Note: Calculations may not be exact due to rounding.

CCSF-K9 Provider’s Security Program

TSA also has a number of burdens associated with the collection of information regarding a CCSF-K9 Provider’s Security Program. For each of these burdens, TSA assumes the fully-loaded hourly wage rate of $78.89 for security coordinators. TSA estimates an average annual number of respondents to be 16 (13 current companies + 3 new companies).

As discussed in the CCSF-K9 Application section, TSA estimates that 3 entities will apply for certification every year. TSA estimates a burden of 40 hours for a CCSF-K9 Provider to create a security program, resulting in an average annual hour burden of 120 hours and a total annual hour burden cost of $9,467.

Similar to CCSF entities, CCSF-K9 Providers may submit amendments to their security program. TSA estimates it will process 10 amendments per year. Each amendment issued by a CCSF-K9 Provider will take 1 hour to submit, for an annual average hour burden of 10 hours and an annual hour burden cost of $789.

If safety and the public interest require an amendment, TSA may amend the CCSSSP and CCSP-K9. TSA estimates it will submit 10 amendments per year. Each amendment will take 40 hours to submit, for an annual average burden hours of 400 burden hours and an annual hour burden cost of $31,557.

The CCSF-K9 Security Program mandates that each CCSF-K9 must designate and submit the name and contact information of a security coordinator and alternate. TSA estimates 3 new CCSF-K9 will submit the required information and it will take 30 minutes (0.5 hrs.) to submit. TSA estimates the annual hour of 1.5 hours a year and annual cost of $118.

Lastly, CCSF-K9s must report security incidents to TSA. TSA estimates it will receive 15 incidents reported a year, with a time burden of 20 minutes (0.33 hours) per report. TSA estimates a total annual hour burden of 5 hours and a total annual cost burden of $394.

Across all CCSF-K9 Provider’s Security Program related collections, TSA estimates an annual hour burden of 536.5 and an annual average hour burden cost of $42,326. Table 8 summarizes these estimates.

Table 8: CCSF-K9 Security Program Hour Burdens and Costs
Activity	Number of Annual Responses	Hour Burden Per Response	Total Annual Hour Burden	Total Annual Hour Burden Cost
	A	B	C = A × B	D = C × $78.89
New Certifications	3	40	120	$9,467
Submitting Security Program Amendments to TSA	10	1	10	$789
TSA Issued Amendments	10	40	400	$31,557
Security Coordinator Submissions	3	0.5	1.5	$118
Security Incident Reports	15	0.33	5	$394
Total	41		536.5	$42,326.08
Note: Calculations may not be exact due to rounding.

3PK9-C Certifier Order

There are a number of burdens associated with the collection of information regarding a 3PK9-C Certifier’s Order, certification, security coordinator, security incidents. For each of these quantified information collection burdens, TSA assumes they are completed by a front-line supervisor (security coordinator) with a fully-loaded wage of $78.89. TSA estimates the average annual number of respondents to be 7 per year.

Similar to CCSFs and CCSF-K9s, each 3PK9-C Certifier must designate and submit the name and contact information of a security coordinator and alternate. TSA estimates four 3PK-9 Certifiers will submit the required information and it will take 30 minutes to submit. TSA estimates the annual hour burden is 2 hours per year and annual cost of $158.

The 3PK9 -Certifiers must report security incidents to TSA. TSA estimates it will receive 15 incidents reported a year, with a time burden of 20 minutes (0.33 hours) per report. TSA estimates a total annual hour burden of 5 hours and a total annual cost burden of $394.

Across all 3PK9-C Certifier Order related collections, TSA estimates an annual hour burden of 7 and an annual average hour burden cost of $552. Table 9 summarizes these estimates.

Table 9: Hour Burden and Costs for 3PK9-C Certifier Order

Activity	Number of Annual Responses	Hour Burden Per Response	Total Annual Hour Burden	Hour Burden Cost
	A	B	C = A × B	D = C × $78.89
Security Coordinator Submissions	4	0.5	2	$157.79
Security Incident Reports	15	0.33	5	$394.46
Total	19		7	$552.25

Note: Calculations may not be exact due to rounding.

Total for CCSF, CCSF-K9, and 3PK9-C Certifier Respondents

The total annual number of respondents, total annual hour burden, and total annual hour burden cost for CCSF, CCSP-K9, and 3PK9-C certifiers are depicted in Table 10.

Table 10: Total Annual Respondents, Hour Burden and Costs for CCSFs, CCSF-K9 and 3PK9-C
Activity	Respondents	Responses	Annual Hour Burden	Annual Hour Burden Cost
Applications
CCSF	120	120	4800	$220,861
CCSF-K9	3	3	120	$9,467
STA Applications
CCSF	6,859	6,859	1,715	$54,764
Recordkeeping
CCSF	904	14,502	3,838	$104,625.61
CCSF-K9	16	25,602	2,101	$165,762.04
3PK9-C Certifier	7	783	93.9	$7,406.74
Security Programs / Orders
CCSF	120	716	4,451	$278,330.80
CCSF-K9	16	41	536.5	$42,326.08
3PK9-C Certifier	7	19	7	$552.25
Total	8,052	48,645	17,662.4	$884,095.27
Note: Calculations may not be exact due to rounding.

13. Provide an estimate of the total annual capital and start-up costs.

STA Fees

As described in Question 12, TSA estimates that employees from three populations – CCSF, CCSF-K9, and 3PK9-C Certifiers– will complete a STA for purposes of complying with the CCSSSP, CCSP-K9, and the 3PK9-C Certifier Order. TSA will permit CCSF-K9 employees and 3PK9-C Certifier employees to meet the STA with CHRC requirements found in the CCSP-K9 and 3PK9-C Certifiers Order, via other TSA vetting requirements and pay corresponding costs for those other STAs because other STAs contain a CHRC, to include a fingerprint based check.

TSA estimates a fee of $41.00 for each STA. TSA assumes that it will process an average of 6,959 STAs a year from the CCSF population, which translates to a cost of $281,219 collected annually. Table 11 summarizes the costs.

Table 11: STA Fee Costs for CCSF Populations
Population	Annual Number of STAs	STA Fee	STA Fee Costs
	A	B	C = A × B
CCSP STAs	6,959	$41.00	$281,219

Note: Calculations may not be exact due to rounding.

14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, and other expenses that will not have been incurred without this collection of information.

TSA Costs for CCSSSP Applications, Recertification, Security Coordinators, and Incident Reporting

TSA estimated an annual average of 381 (261 updated programs + 120 new programs) applications and security program reviews. CCSF applications and security program reviews are estimated to take an average 10 hours per entity requesting certification at a cost of $85.14 per hour for a TSA employee. The wage is based on the average loaded hourly wage rate for an I/J band TSA employee. TSA estimated that collecting security coordinator information and responding to security incident would involve 30 minutes (0.5 hours) and 10 hours, respectively. TSA hours for these responses would be 4,023 annually and cost $342,539. Table 12 summarizes these calculations.

Table 12: Federal Costs for CCSSSP Review
Activity	Number of Responses	Hour Burden per Response	Annual Hour Burden	Annual Hour Burden Cost
	A	B	C = A × B	D = C × $85.14
New CCSSSP Programs	120	10	1,200	$102,165.69
Recertification	261		2,613	$222,494.16
Security Coordinator Submissions	120	0.5	60	$5,108.28
Security Incident Reporting	15	10	150	$12,770.71
Total	516		4,023	$342,538.84
Note: Calculations may not be exact due to rounding.

TSA Costs for CCSF-K9 Applications, Security Coordinators, and Incident Reporting

TSA estimated an annual average of three CCSF-K9 applications. CCSF-K9 are estimated to take an average 10 hours per entity requesting certification at a cost of $85.14 per hour for a TSA employee. The wage is based on the average loaded hourly wage rate for an I/J band TSA employee. TSA estimated that collecting security coordinator information and responding to security incident would involve 30 minutes (0.5 hours) and 10 hours, respectively. TSA hours for these responses would be 182 annually and cost $15,453. Table 13 summarizes these calculations.

	Table 13: TSA Cost for CCSF-K9 Applications, Security Coordinators, and Incident Reporting
Activity		Number of CCSF-K9 Responses	Hour Burden per Response	Annual Hour Burden	Hour Burden Cost
		A	B	C = A × B	D = C × $85.14
Applications		3	10	30	$2,554.14
Security Coordinator Submissions		3	0.5	1.5	$127.71
Security Incident Reporting		15	10	150	$12,770.71
Total		21		181.5	$15,452.56
Note: Calculations may not be exact due to rounding.

TSA Costs for 3PK9-C Certifier Security Coordinators and Incident Reporting

TSA must process 3PK9-C Certifier security coordinator submissions and incident reports. The average loaded hourly wage rate for TSA employees to process these reports is $94.86.¹⁴ TSA estimates the time to process security coordinator information and respond to security incident reports is 30 minutes (0.5 hours) and 10 hours, respectively. The corresponding total annual hours are 152 and annual cost burden is $14,419. Table 14 summarizes these estimates.

Table 14: TSA Costs for 3PK9-C Certifier Security Coordinators and Incident Reporting
Activity	Number of 3PK9-C Responses	Hour Burden per Response	Total Hour Burden	Annual Hour Burden Cost
	A	B	C = A × B	D = C × $94.86
Security Coordinator Submissions	4	0.5	2	$189.73
Security Incident Reporting	15	10	150	$14,229.74
Total	19		152	$14,419.47
Note: Calculations may not be exact due to rounding.

STA Application Review¹⁵

TSA must review every STA application it receives. As previously stated, TSA estimates the time it takes to process each CCSF-K9 and 3PK9-C Certifiers STA application is 15 minutes (0.25 hours). The fully-loaded wage of the TSA employee reviewing these STAs is $85.14.¹⁶ The annual total hour burden for these reviews is 74.5 hours. This corresponds to a total annual hour burden cost of $6,343. Table 15 summarizes the estimated number of STA reviews by population, and the corresponding time and cost burdens of these reviews.

Table 15: Hour Burden and Costs for CCSF-K9 and 3PK9-C Certifiers STA Review
Population	Number of STA Applications Received	Hour Burden per Application	Total Hour Burden	Hour Burden Cost
	A	B	C = A × B	D = C × $85.14
CCSF-K9	240	0.25	60	$5,108
CCSP-3PK9-C Certifiers	58		14.5	$1,235
Total	298		74.5	$6,343
Note: Calculations may not be exact due to rounding.

Annual Audit of CCSFs, CCSF-K9s and 3PK9-C Certifiers

As stated in Question 12, TSA will audit each CCSF, CCSF-K9 and 3PK9-C Certifier annually. This translates to 1 audit per year per entity, with each audit taking 8 hours for TSA to complete (784 + 13 + 7) × 8 = 6,432 hours). The fully-loaded wage rate of the TSA employees conducting the audits is $85.14. This corresponds to a total annual hour burden cost of $547,698. Table 17 summarizes these estimates below.

Table 16: Hour Burden and Costs for CCSFs, 3PK9-C Certifiers and CCSF-K9s Audits
Activity	Number of Audits	Hour Burden Per Audit	Total Hour Burden	Annual Hour Burden
				Cost
	A	B	C = A × B	D = C × $85.14
TSA Audits	804	8	6,432	$547,608.07
Note: Calculations may not be exact due to rounding.

TSA Issued Amendments for the CCSSSP and CCSP-K9

If safety and the public interest require an amendment, TSA may amend the CCSSSP and CCSP-K9. TSA estimates it will submit 10 amendments per year. Each amendment will take 40 hours to submit. The fully-loaded wage of the designated TSA employee submitting an amendment is $85.14. The total annual hour burden to TSA is 400 hours, and will cost TSA a total annual hour burden cost of $34,055. Table 17 summarizes these estimates below.

Table 17: Hour Burden and Costs for TSA Issued Amendments for the CCSSSP, and CCSP-K9 Program
Activity	Number of Amendments	Hour Burden per Amendment	Total Hour Burden	Hour Burden Cost
	A	B	C = A × B	D = C × $85.14
TSA Issued Amendments	10	40	400	$34,055.23
Note: Calculations may not be exact due to rounding.

TSA Total Costs

TSA estimates a total Federal Government cost of $960,417 and 11,263 hours, as summarized by Table 18 below.

Table 18: Total TSA Costs
TSA Costs	Annual Hours	Annual Costs
CCSF Applications, Recertifications, Security Coordinators, and Incident Reporting	4,023	$342,539
CCSF-K9 Applications, Recertifications, Security Coordinators, and Incident Reporting	181.5	$15,453
3PK9-C Certifier Security Coordinators and Incident Reporting	152	$14,419
STA Review for CCSFs, CCSF-K9 and 3PK9-C Certifiers	74.5	$6,343
Annual Audit of CCSF, CCSF-K9, and 3PK9-C Certifiers	6432	$547,608.07
TSA Issued Amendments for the CCSSSP and CCSF-K9 Program	400	$34,055.23
Annual Total TSA Costs	11,263	$960,416.95
Note: Calculations may not be exact 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.

TSA is revising this collection to update the following TSA Forms: 419A, 419B, 419C, 419D and 419E, making minor changes by updating instructions and removing information no longer required by the CCSSSP. The minor changes do not impact the burden. However, since the submission of the ICR in 2021, the responses have increased from 23,512 to 48,645 with an annual burden increase of 1,622 (17,662 – 16,040).

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.

TSA will not publish the results of this collection.

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

TSA is not seeking such approval.

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

TSA is not seeking any exceptions.

1 See 49 U.S.C. 44901(g). The requirement for screening 100 percent of the cargo transported on passenger aircraft was implemented through TSA's regulations, including amendments to parts 1515, 1520, 1540, 1544, 1546, 1548, and adding part 1549. See 76 FR 51848 (Aug. 18, 2011).

2 Id. See also 49 U.S.C. § 44901(g)(2).

3 See sec. 1941 of the FAA Reauthorization Act of 2019, Division K, Title I, Pub. L. 115-254(132 Stat. 3186; Oct. 5, 2018).

4 See Convention of International Civil Aviation, Amendment 14, Annex 17, Standard 4.6.1.

5 A fully-loaded wage rate includes non-salary costs of employer cost of employee compensation, such as health and retirement benefits.

6 The unloaded wage rate for an Aircraft Cargo Handling Supervisor is $30.94. Bureau of Labor Statistics (BLS). May 2022 National Industry-Specific Occupational Employment and Wage Estimates. NAICS 481000 - Air Transportation. OCC 53-1041 Aircraft Cargo Handling Supervisors. Last modified April 25, 2023 (accessed March 25, 2024), https://www.bls.gov/oes/2022/May/naics3_481000.htm. TSA calculates a load factor to increase the unloaded wage to account for non-wage compensation. TSA calculates this factor by dividing the total compensation ($37.06) by the wage and salary component ($24.92) of compensation to get a load factor of 1.4872. BLS. Employer Costs for Employee Compensation – December 2023. Table 5. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: private industry workers. Production, transportation and material moving occupations. Last modified March 13, 2024 (accessed March 25, 2024), https://www.bls.gov/news.release/archives/ecec_03132024.htm. The fully-loaded wage rate is calculated by multiplying the unloaded wage rate by the load factor: $46.01 = $30.94 × 1.4872.

7 Although three respondents do not trigger the PRA threshold of “10 or more persons” TSA is including estimates within this ICR in the event more applications are received on an annual basis.

8 Wage data for CCSF-K9 first-line supervisors is not readily available. As such, TSA made the following assumptions to calculate a proxy: the first-line supervisor would be equivalent to a TSA I-Band Supervisory Transportation Security Specialist (Canine). The annual fully-loaded compensation and benefits amount for an I-Band employee is $154,323.69. TSA divides this annual salary by the number of workable hours for a Federal employee (2,087) in a calendar year to get a fully-loaded hourly wage rate of $73.95.

9 Supra.

10 This is a weighted average (by employment) of a fully-loaded wage rate among Laborers and Freight, Stock, and Material Movers, and Air Cargo Handling Supervisors. First, the unloaded wage rates and number employed were determined. The unloaded wage rate for Supervisors is $30.94 with employment of 2,610. BLS. May 2022 National Industry-Specific Occupational Employment and Wage Estimates. NAICS 481000 - Air Transportation. OCC 53-1041 Aircraft Cargo Handling Supervisors. The unloaded wage rate for Laborers is $20.99 with employment of 50,930. BLS. May 2022 National Industry-Specific Occupational Employment and Wage Estimates. NAICS 481000 - Air Transportation. OCC 53-7062 Laborers and Freight, Stock, and Material Movers, Hand. Last modified April 25, 2023. (accessed March 25, 2024), https://www.bls.gov/oes/2022/May/naics3_481000.htm. The weighted average unloaded wage rate is $21.48 = ($30.94 × 2,610) + ($20.99 × 50,930) ÷ (2,610 + 50,930). TSA then calculates a fully-loaded wage rate by multiplying the unloaded wage rate with the compensation factor $31.94 = ($21.48 × 1.4872, see Supra).

11 The unloaded wage rate for Receptionists and Information Clerks is $18.33. BLS. May 2022 National Industry-Specific Occupational Employment and Wage Estimates. NAICS 481000 - Air Transportation. OCC 43-4141 Receptionists and Information Clerks. Last modified April 25, 2023 (accessed March 25, 2024), https://www.bls.gov/oes/2022/May/naics3_481000.htm. BLS. Employer Costs for Employee Compensation – December 2023. Table 5. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: private industry workers. Production, transportation, and material moving occupations. Last modified March 13, 2024 (accessed March 25, 2024), https://www.bls.gov/news.release/archives/ecec_09172020.htm. The fully-loaded wage rate is calculated by multiplying the unloaded wage rate by the load factor: $27.26 = $18.33 × 1.4872.

12 TSA assumes recordkeeping duties for CCSF-K9 will be conducted by a first-line supervisor, therefore uses the fully-loaded wage rate for CCSF-K9 first-line supervisors calculated previously.

13 Unlike the CCSF entities, TSA SMEs do not assume that there is a clerical worker to conduct this record-keeping activity, therefore uses the managerial wage.

14 TSA estimates that three different TSA employees -- an I-band, J-band, and L-band -- will review each 3PK9-C Certifier application. Each will spend 30 minutes (0.5 hours) review the document, for a total of 1.5 hours to review an application. The wage rate used is an average of the three employees: $94.86 = ($78.89 + $91.38 +$114.32) ÷ 3.

15 While information collection for STAs for CCSF-K9 and 3PK9-C are covered by 1652-0059, TSA still does a STA review and has costs associated that are covered here.

16 This is an average of the fully-loaded wages for an I-band employee ($78.89/hr) and J-band employee ($91.38/hr), where $85.14 = ($78.89+91.38) ÷ 2. TSA assumes that both I-band and J-band employees will be reviewing these STA applications.