SUPPORTING STATEMENT - PART A
Supporting Statement for
VA Acquisition Regulation Clause 852.211-72, Technical Industry Standards
OMB Control No. 2900-0586
Summary of Changes from Previously Approved Collection
|
1. Need for the Information Collection
The Department of Veterans Affairs (VA), Office of Acquisition and Logistics (OAL) requests the Office of Management and Budget (OMB) grant an extension of a previously approved IC request, OMB control number 2900-0586, for collection of information for both commercial and non-commercial item, service, and construction solicitations and contracts using VA Acquisition Regulation (VAAR) clause 852.211-72, Technical Industry Standards, as prescribed in C.F.R. Title 48, Federal Acquisition Regulations System, VAAR 811.204-70, Contract clause.
Authorities: 44 U.S.C. § 3507, Paperwork Reduction Act of 1995; and 48 C.F.R. §§ 1.301–1.304; and 48 C.F.R. § 811.204-70.
2. Use of the Information
VAAR clause 852.211-72, Technical Industry Standards, requires that items offered for sale to VA under the solicitation conform to certain technical industry standards, such as United States Department of Agriculture (USDA) Institutional Meat Purchase Specifications, and that the contractor furnish evidence to VA that the items meet that requirement. The evidence is normally in the form of a tag or seal affixed to the item, such as a label on beef product. In most cases, this requires no additional effort on the part of the contractor, as the items come from the factory with the tags already in place, as part of the manufacturer's standard manufacturing operation. Occasionally, for items not already meeting standards or for items not previously tested, a contractor will have to furnish a certificate from an acceptable laboratory certifying that the items furnished have been tested in accordance with, and conform to, the specified standards. Only firms whose products have not previously been tested to ensure the products meet the industry standards required under the solicitation and contract will be required to submit a separate certificate. The information will be used to ensure that the items being purchased meet minimum safety standards and to protect VA beneficiaries and VA employees.
3. Use of Information Technology
VA almost always requests or allows offerors/contractors to submit this IC electronically – typically via email or uploaded into VA-provided portal links. VA complies with the policy in Federal Acquisition Regulation (FAR) 4.002 (Deviation, Nov 2025) that mandates using electronic commerce whenever practicable and cost-effective.
4. Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
5. Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
6. Less Frequent Collection
The information is needed on each product offered for sale to the Government rather than quarterly. The information is submitted with each quotation, bid, or offer.
7. Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 C.F.R. § 1320.5(d)(2). More specifically to one requirement – requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it. The information is submitted with each quotation, bid, or offer. The time for response is the same as the time for submission of the quotation, bid, or offer, which may be fewer than 30 days, especially for lower dollar value solicitations or for commercial items.
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection was published on Wednesday, September 17, 2025. The 60-Day FRN citation is 90 FR 44904. No comments were received during the 60-Day Comment Period.
A 30-Day FRN for this collection was published on Friday, November 21, 2025. The 30-Day FRN citation is 90 FR 52793.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.
9. Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in this collection.
10. Confidentiality
A Privacy Act Statement is not required for this collection because we are not requesting individuals to furnish personal information for a system of records.
A System of Record Notice (SORN) is not required for this collection because records are not retrievable by Personally Identifiable Information (PII).
A Privacy Impact Assessment (PIA) is not required for this collection because PII is not being collected electronically.
No assurances of privacy/confidentiality will be provided to respondents.
However, data will be kept private to the extent allowed by law. Information provided to VA by a contractor is subject to being requested by third parties under the Freedom of Information Act (FOIA), as amended (5 U.S.C. § 552), but business-proprietary information is generally exempt from public disclosure under the FOIA.
This information collection does not require the submission of proprietary information.
Contract laws and regulations specify record retention requirements for contracts. FAR subpart 4.7, Contractor Records Retention, states the required records retention period based on different contract actions and circumstances.
11. Sensitive Questions
No questions considered sensitive are being asked in this collection.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
VAAR 852.211-72, Technical Industry Standards
Number of Respondents: 1,118
Number of Responses Per Respondent: 1 per solicitation
Number of Total Annual Responses: 1,118
Response Time: 30 minutes
Respondent Burden Hours: 559 hours
Total Submission Burden
Total Number of Respondents: 1,118
Total Number of Annual Responses: 1,118
Total Respondent Burden Hours: 559 hours
Part B: LABOR COST OF RESPONDENT BURDEN
Number of Total Annual Responses: 1,118
Response Time: 30 minutes
Respondent Hourly Wage: $52.29
Labor Burden per Response: $26.15
Total Labor Burden: $29,230
Overall Labor Burden
Total Number of Annual Responses: 1,118
Total Labor Burden: $29,230
The Respondent hourly wage was determined by using the Bureau of Labor Statistics (BLS) website at https://www.bls.gov/home.htm and the particular information at Purchasing Managers, Buyers, and Purchasing Agents 2024 Median pay (bls.gov). The Bureau of Labor Statistics (BLS) gathers information on full-time wage and salary workers. According to the latest (May 2024) available BLS data, the mean hourly wage is $38.38 on BLS wage code – ““13-1020 Buyers and Purchasing Agents (Group/broad)” plus 36.25% per OMB Memo M-08-13 dated March 11, 2008, equals $52.29 per hour.
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents, other than the labor burden costs addressed in Section 12 of this document, to complete this collection.
14. Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
VAAR 852.211-72, Technical Industry Standards
Number of Total Annual Responses: 1,118
Processing Time per Response: 30 minutes
Hourly Wage of Workers Processing Responses: $52.29
Cost to Process Each Response: $26.145
Total Cost to Process Responses: $29,230
Overall Labor Burden to the Federal Government
Total Number of Annual Responses: 1,118
Total Labor Burden: $29,230
Estimated annualized cost to the Government: $17,653 (559 hours at $31.58 per hour). It is estimated that the review and statement will be prepared by a Journeyman Contract Specialist equivalent to a GS-7. Based on a GS-7, step 5 salary, for FY25 – see Salary Table 2025-GS (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2025/GS_h.pdf) plus 36.25% per OMB Memo M-08-13 dated March 11, 2008, the hourly rate is ($23.18 X 136.25% = $31.58).
Part B: OPERATIONAL AND MAINTENANCE COSTS
Cost Categories
Equipment: $0
Printing: $0
Postage: $0
Software Purchases: $0
Licensing Costs: $0
Other: $0
Total Operational and Maintenance Cost: $0
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $17,653
Total Operational and Maintenance Costs: $0
Total Cost to the Federal Government: $17,653
15. Reasons for Change in Burden
There is no burden hour change. The burden cost estimate has increased since the previous approval due to higher wage rates for the BLS labor rate and the GS pay rate. This results in a net increase of $7,272 in burden cost, as shown below.
Summary of the cost differences between this SS and last SS
SS Block # |
Cost This SS |
Cost Last SS |
Increase (Decrease) |
Reason |
12 |
$29,230 |
$23,724 |
$5,506 |
Increase in BLS rate. |
14 |
$17,653 |
$15,887 |
$1,766 |
Increase in GS rate. |
16. Publication of Results
The results of these ICs will not be published.
17. Non-Display of OMB Expiration Date
We are not seeking approval to omit the display of the expiration date of the OMB approval on this collection instrument.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 C.F.R. § 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Browne, Forrest R. |
| File Modified | 0000-00-00 |
| File Created | 2025-11-22 |