Supporting Statement

SUPPORTING STATEMENT.doc

Qualification to Possess Firearms or Ammunition

OMB: 0704-0461

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SUPPORTING STATEMENT

DRAFT (0704-TBD)


Qualification to Possess Firearms or Ammunition”


  1. Justification


  1. Need for Information Collection


In accordance with DoD Instruction 3020.pp, “Private Security Contractors Operating in Contingency Operations” written acknowledgement by the contract company and its individual Private Security Contractor (PSC) personnel, after investigation of background of PSC personnel by the contractor, shall be provided verifying such personnel are not prohibited under U.S. law (18 USC 922(g)) to possess firearms or ammunition.


  1. Use of the Information


Written acknowledgements shall be used to verify that PSC personnel are not prohibited

from possessing firearms or ammunition.


In the case of individuals found to have a qualifying conviction, the appropriate authority

will immediately retrieve all government-issued firearms and ammunition. It will be requested that such individuals be removed from contracts supporting contingency operations.


  1. Information Technology


The use of information technology is not considered appropriate for the purposes of this collection. PSC personnel must sign the acknowledgement. In addition, the information collected during the verification process is maintained by the contract company and not by the Agency.


  1. Efforts to Identify Duplication


There is no duplication of data collection. This is the first time contractor data is collected for these specific purposes.


  1. Methods to Minimize Burden on Small Entities


The information collection associated with small businesses is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices.


  1. Consequences of Not Collecting the Data


If this data is not collected, Agencies will not be able to accurately verify whether or not PSC personnel are prohibited under U.S. law to possess firearms or ammunition.


  1. Special Circumstances


There are no special circumstances that require the collection to be conducted in a

manner inconsistent with the guidelines in 5 CFR 1320.5 (d) (2).


8. Agency 60-Day Federal Register Notice and Consultations Outside the Agency


Public comments will be solicited in the Federal Register as required by 5 CFR 1320.8(d). A subsequent information collection package to be submitted under regular processing timeframes will address any comments received on the information collection.


9. Payments to Respondents


No payment or gift will be provided to respondents, other than remuneration of contractors under their contracts.


10. Assurance of Confidentiality


The information collected will be disclosed only to the extent consistent with prudent

business practice, current regulations, and statutory requirements. No assurance of confidentiality is provided to respondents.


11. Sensitive Questions


Questions of a sensitive nature such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private are not asked in this collection.


12. Estimates of Response Burden and Annual Cost to Respondent


(a) Estimated Average Annual Respondent Burden:


(1) Responses per Respondent: 5-2,500 employees (average of 120)

(2) Number of Respondents: 125 companies

(3) Hours per Response: 15 minutes

(4) Total Annual Burden Hours: 3,750 (15,000 employees x .25 hrs)


A private security company is required to verify that its employees who are operating in either contingency operations (for DoD) or in a designated area of combat operations (for DoS and other federal agencies) are not prohibited under U.S. law (title 18, United States Code 922(g)) to possess firearms or ammunition. Based on current numbers of DoD and DoS armed private security contractors in Iraq and Afghanistan (DoS - 3,121 in Iraq and 599 in Afghanistan; DoD - 8,480in Iraq and 3,172 in Afghanistan), we estimate that there could be a requirement for 125 companies to complete this action for 15,000 individuals per year.



(b) Respondent Cost


Total Annual Cost to Respondents: $33,750 (3,750 total hours x $9)

Cost to Individual Respondent: $45 to $22,500 (5 x $9 to 2,500 x $9)


The cost to respondent is based on the approximate salary of $36.00 (rate per hour)/60 (minutes) = $.6 per minute.


  1. Estimates of Cost Burden for Collection of Information


DoD does not estimate any annual cost burden apart from the hour burden in

Item 12, above.


  1. Annual Cost to Government:


10 minutes for the contracting officer to verify information

15,000 total records x 10 minutes = 150,000 minutes

150,000 / 60 = 2,500 hours


Average Grade/Rank of contracting officer is GS-13 Step 1


Average Average Salary/hr Total Annual Total Annual Cost

Grade/Rank (DC area FY08) Hours

GS-13 Step 1 $39.75 2,500 $ 99,375 = ($39.75 X 2,500)


Total Cost to the Government: $99, 375.00


  1. Changes in Burden


Increase in burden due to a collection in use without an OMB Control Number.


  1. Plan for Tabulation or Publication


The information collected will not be tabulated or published.


  1. Approval to Avoid Display of the Expiration Date of OMB Approval.


Approval is not sought for avoiding display of the expiration date for OMB approval of the information collection.


  1. Exception to Certification Statement


There are no exceptions to the certification accompanying this Paperwork Reduction Act submission.



B. Collection of Information Employing Statistical Methods.


Statistical methods will not be employed.

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File Typeapplication/msword
File TitleSUPPORTING STATEMENT
Authorjanice savoy_mccormick
Last Modified ByPatricia Toppings
File Modified2009-05-19
File Created2008-08-29

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