9000-0075-Justification

JUSTIFICATION FOR 9000-0075
GOVERNMENT PROPERTY
A.

Justification.

1. Administrative requirements. "Property," as used in
Part 45, means all property, both real and personal. It
includes facilities, material, special tooling, special test
equipment, and agency-peculiar property. Government
property includes both Government-furnished property and
contractor-acquired property.
Contractors are required to establish and maintain a
property system that will control, protect, preserve, and
maintain all Government property because the contractor is
responsible and accountable for all Government property
under the provisions of the contract including property
located with subcontractors.
The contractor's property control records shall
constitute the Government's official property records and
shall be used to:
(a) Provide financial accounts for Government-owned
property in the contractor's possession or control;
(b) Identify all Government property (to include a
complete, current, auditable record of all transactions);
(c) Locate any item of Government property within a
reasonable period of time.
This clearance covers the following requirements:
(a) FAR 45.307-2(b) requires a contractor to notify
the contracting officer if it intends to acquire or
fabricate special test equipment.
(b) FAR 45.502-1 requires a contractor to furnish
written receipts for Government property.
(c) FAR 45.502-2 requires a contractor to submit a
discrepancy report upon receipt of Government property when
overages, shortages, or damages are discovered.
(d) FAR 45.504 requires a contractor to investigate
and report all instances of loss, damage, or destruction of
Government property.

(e) FAR 45.505-1 requires that basic information be
placed on the contractor's property control records.
(f) FAR 45.505-3 requires a contractor to maintain
records for Government material.
(g) FAR 45.505-4 requires a contractor to maintain
records of special tooling and special test equipment.
(h) FAR 45.505-5 requires a contractor to maintain
records of plant equipment.
(i) FAR 45.505-7 requires a contractor to maintain
records of real property.
(j) FAR 45.505-8 requires a contractor to maintain
scrap and salvage records.
(k) FAR 45.505-9 requires a contractor to maintain
records of related data and information.
(l) FAR 45.505-10 requires a contractor to maintain
records for completed products.
(m) FAR 45.505-11 requires a contractor to maintain
records of transportation and installation costs of plant
equipment.
(n) FAR 45.505-12 requires a contractor to maintain
records of misdirected shipments.
(o) FAR 45.505-13 requires a contractor to maintain
records of property returned for rework.
(p) FAR 45.505-14 requires a contractor to submit an
annual report of Government property accountable to each
agency contract.
(q) FAR 45.508-2 requires a contractor to report the
results of physical inventories.
(r) FAR 45.509-1(a)(3) requires a contractor to record
work accomplished in maintaining Government property.
(s) FAR 45.509-1(c) requires a contractor to report
the need for major repair, replacement and other
rehabilitation work.
(t) FAR 45.509-2(b)(2) requires a contractor to
maintain utilization records.
(u) FAR 45.606-1 requires a contractor to submit
inventory schedules.

2

(v) FAR 45.606-3(a) requires a contractor to correct
and resubmit inventory schedules as necessary.
(w) FAR 52.245-2(a)(3) requires a contractor to notify
the contracting officer when Government-furnished property
is received and is not suitable for use.
(x) FAR 52.245-2(a)(4) requires a contractor to notify
the contracting officer when government-furnished property
is not timely delivered and the contracting officer will
make a determination of the delay, if any, caused the
contractor.
(y) FAR 52.245-2(b) requires a contractor to submit a
written request for an equitable adjustment if Governmentfurnished property is decreased, substituted, or withdrawn
by the Government.
(z) FAR 52.245-4 requires a contractor to submit a
timely written request for an equitable adjustment when
Government-furnished property is not furnished in a timely
manner.
(aa) FAR 52.245-5(a)(4) requires a contractor to
notify the contracting officer when Government-furnished
property is received that is not suitable for use.
(bb) FAR 52.245-5(a)(5) requires a contractor to
notify the contracting officer when Government-furnished
property is not received in a timely manner.
(cc) FAR 52.245-5(b)(2) requests a contractor to
submit a written request for an equitable adjustment if
Government-furnished property is decreased, substituted, or
withdrawn by the Government.
(dd) FAR 52.245-7(f) requires a contractor to notify
the contracting officer when use of all facilities falls
below 75% of total use.
(ee) FAR 52.245-7(l)(2) requires a contractor to alert
the contracting officer within 30 days of receiving
facilities that are not suitable for use.
(ff) FAR 52.245-9(f) requires a contractor to submit a
facilities use statement to the contracting officer within
90 days after the close of each rental period.
(gg) FAR 52.245-10(h)(2) requires a contractor to
notify the contracting officer if facilities are received
that are not suitable for the intended use.

3

(hh) FAR 52.245-11(e) requires a contractor to notify
the contracting officer when use of all facilities falls
below 75% of total use.
(ii) FAR 52.245-11(j)(2) requires a contractor to
notify the contracting officer within 30 days of receiving
facilities not suitable for intended use.
(jj) FAR 52.245-17 requires a contractor to maintain
special tooling records.
(kk) FAR 52.245-18(b) requires a contractor to notify
the contracting officer 30 days in advance of the
contractor's intention to acquire or fabricate special test
equipment (STE).
(ll) FAR 52.245-18(d) & (e) requires a contractor to
furnish the names of subcontractors who acquire or fabricate
special test equipment (STE) or components and comply with
paragraph (d) of this clause, and contractors must comply
with the (b) paragraph of this clause if an engineering
change requires acquisition or modification of STE. In so
complying, the contractor shall identify the change order
which requires the proposed acquisition, fabrication, or
modification.
(mm) FAR 52.245-19 requires a contractor to notify the
contracting officer if there is any change in the condition
of property furnished "as is" from the time of inspection
until time of receipt.
2. Uses of information. This information is used to
facilitate the management of Government property in the
possession of the contractor.
3. Consideration of information technology. We use
improved information technology to the maximum extent
practicable. Where both the Government agency and
contractors are capable of electronic interchange, the
contractors may submit this information collection
requirement electronically. Nothing in the FAR precludes the
use of electronic interchange. In addition, the forms are
available online, screen fillable, and digital signature
capable.
4. Efforts to identify duplication. This requirement is
being issued under the Federal Acquisition Regulation (FAR)
which has been developed to standardize Federal procurement
practices and eliminate unnecessary duplication.

4

5. If the collection of information impacts small
businesses or other entities, describe methods used to
minimize burden. The burden applied to small businesses is
the minimum consistent with applicable laws, Executive
orders, regulations, and prudent business practices.
6. Describe consequence to Federal program or policy
activities if the collection is not conducted or is
conducted less frequently. Similar information is not
already available to the contracting officer or buyer.
7. Special circumstances for collection. Collection of
information on a basis other than solicitation-bysolicitation is not practical. Collection is consistent with
guidelines in 5 CFR 1320.6.
8. Efforts to consult with persons outside the agency.
Under the procedures established for development of the FAR,
agency and public comments were solicited and each comment
addressed before finalization of the text. A notice in the
July 19, 2006, Federal Register made this requirement
available to the public and requested comments.
9. Explanation of any decision to provide any payment or
gift to respondents, other than reenumeration of contractors
or guarantees. Not applicable.
10. Describe assurance of confidentiality provided to
respondents. This information is disclosed only to the
extent consistent with prudent business practices and
current regulations.
11. Additional justification for questions of a sensitive
nature. No sensitive questions are involved.
12 & 13. Estimated total annual public hour and cost
burden.
We estimate 5,000 contractors have Government
property.
(a) FAR 45.307-2(b), 45.307-3 and FAR 52.245-18.
Approximately 1,100 contractors have special test equipment.
We estimate that approximately 20% of all contractors
fabricate or acquire special test equipment each year. Wea
also estimate that on the average, it takes approximately 3
hours to identify, prepare and submit the information.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual responses
Hours per response
Total hours

5

220
x 1
220
x 3
660

(b) FAR 45.502-1. We estimate that 3,750 contractors
on the average prepare 2,000 receiving reports each per
year. We also estimate that it takes 30 minutes to prepare
each receiving report.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

3,750
x 2,000
7,500,000
x
.5
3,750,000

(c) FAR 45.502-2. We estimate that there are
approximately 600 contractors on the average that prepare 2
discrepancy reports each per year.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

600
x 2
1,200
x.5
600

(d) FAR 45.504. We estimate that 10 percent of
contractors report lost or damaged property each year. On
the average, each contractor losing property would make two
reports per year. We estimate that on the average, it takes
1 hour for contractors to retrieve, prepare and submit the
information.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

500
x 2
1,000
x 1
1,000

(e) FAR 45.505-1. We have not identified specific
recordkeeping requirements for contractors to record basic
information on the property records. All prudent
contractors would maintain basic records in accordance with
sound industrial practice. Specific recordkeeping
requirements imposed on contractors by FAR 45.505-3 through
45.505-13 are identified below.
(f) FAR 45.505-3 through 45.505-13. All 5,000
contractors are required to keep property records. We
estimate that each contractor maintains, on the average,
approximately 1200 items of property. We estimate upon
authorizing the expanded use of summary records (to include
special test equipment and special tooling) that contractors
will maintain summary records for 50 percent of the property
and item records for the remaining 50 percent. Since the
recordkeeping requirement varies per category of property,
we estimate that on the average, it will take 24 minutes to
prepare each record.
6

A.
B.
C.
D.
E.

Number of respondents
5,000
Responses per respondent
x 1,200
Total annual response
6,000,000
Hours per response
x .4
Total hours
2,400,000

(g) FAR 45.505-14. We estimate that 5,000 contractors
submit annual reports, and that each contractor submits, on
the average, 5 such reports each year.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

5,000
x
5
25,000
x
1
25,000

(h) FAR 45.508-2. The conduct of physical inventories
varies greatly from contractor to contractor. Contractors
use three types of inventories, (1) stratification
(inventory high dollar property two or more times per year,
low dollar property only 25% of inventory per year); (2)
cyclic (inventory so many items per month); and (3) wall-towall (shut down plant operations to inventory). We estimate
that on the average, it will take approximately 60 hours per
inventory.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

5,000
x 1
5,000
x 60
300,000

(i) FAR 45.509-1(a)(3). As a normal business practice
all contractors would be required to maintain a maintenance
program in accordance with sound industrial practice. As a
result, no burden has been identified for this subparagraph.
(j) FAR 45.509-1(c). We estimate that 250 contractors
submit an annual report identifying the need for major
repair, replacement, and other capital rehabilitation work.
These reports are extensive in nature and we estimate that
it would take approximately 3 hours to store, retrieve,
prepare, and submit the information.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

250
x 1
250
x 3
750

(k) FAR 45.509-2(b)(2). We estimate that 400
contractors maintain records for plant equipment with an
acquisition value of $5,000 or more. If the average
7

recording of usage is accomplished once a week (52 times a
year), the total annual responses would be 20,800. Most
items of plant equipment with an acquisition value of over
$5,000 have a built in method of recording actual usage,
that is, whenever the machine is turned on, it automatically
records when it is being used. Thus, we estimate the actual
recording burden at only 5 minutes per item.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

400
x 52
20,800
x 0833
1,732

(l) FAR 45.602-1, FAR 45.606, and SF 1428. We estimate
that 4,500 contractors generate excess/surplus Government
property each year. We estimate that contractors on the
average submit and correct 8 inventory schedules each year
and that it will take approximately 2 hours to store,
retrieve, prepare or correct, and submit the information.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

4,500
x 8
36,000
x 2
72,000

(m) FAR 52.245-2(a)(3), 52.245-10(h)(2), 45.106(b)(1)
and 45.302-6(d). We estimate that 1,500 contractors have
Government-furnished material. We further estimate that a
large percentage of these contractors (i.e., 1400) are
furnished material during the course of a year. Only
occasionally do contractors receive property that is
unsuitable for use (70 contractors). It takes approximately
30 minutes for the contractors to prepare and submit the
information. We included FAR 52.245-5(a)(4) in these
figures as whether the contract is a fixed-price or cost
type should have no bearing on whether the property is
suitable for use.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

70
x 1
70
x .5
35

(n) FAR 52.245-2(a)(4). We estimate that 1,400
contractors are furnished Government property each year.
Only occasionally do contractors submit reports indicating
that property is not received on time. We estimate that of
all contractors receiving property, approximately 90
contractors submit reports of property not received on time,
and that it takes approximately 30 minutes for the
contractor to prepare and submit the information. We
8

included the figures for 52.245-5(a)(5), because whether the
contract is fixed-price or cost should have no impact on
whether the property is received late.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

90
1
90
x .5
45
x

(o) FAR 52.245-2(b). Of the 1400 contractors
receiving property each year, we estimate that only 3
percent, or 42 contractors have Government-furnished
property decreased, substituted, or withdrawn and that it
takes 30 minutes to prepare and submit the report. We
included the figures for 52.245-5(b), because whether the
contract is fixed-price or cost should have no impact on
decreases, substitutions, or the withdrawal of property.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

42
1
42
x .5
21
x

(p) FAR 52.245-4 and 45.106(d). We included the
figures for property not suitable for use, or not received
in a timely manner in FAR 52.245-2(a)(3) and (a)(4) above.
The type of contract, fixed-price or cost should have no
bearing on whether the property is suitable for use or
received on time.
(q) FAR 52.245-5(a)(4) and 45.106(f)(1). We included
this reporting requirement under FAR 52.245-2(a)(3) above,
as the type of contract would not impact whether the
property is suitable for use.
(r) FAR 52.245-5(a)(5). We included this reporting
requirement under FAR 52.245-2(a)(4) above, as the type of
contract, whether fixed-price or cost, should have no impact
on whether or not the property is received on time.
(s) FAR 52.245-5(b). We included this reporting
requirement under FAR 52.245-2(b) above, as the type of
contract, whether fixed-price or cost, should have no impact
on whether property was decreased, substituted, or
withdrawn.
(t) FAR 52.245-7, 52.245-8, 52.245-11, 45.302-6(a) and
45.302-6(e)(1). We did not identify any recordkeeping or
reporting burden specific only to these clauses.
Recordkeeping and reporting burdens are included above.
Regarding the requirement for the contractor to notify the
contracting officer in writing whenever use of all
9

facilities for government work averages less than 75 percent
of the total use of property, this would only probably
happen at a Government-owned and contractor-operated
facility. Since this would be an extremely rare situation,
we didn't place any reporting burden on this requirement.
(u) FAR 52.245-9 and 45.302-6(c). The Government
property is provided to contractors on a rent-free use
basis. However, we estimate that 10 percent of all
contractors use property that requires rental payments. We
estimate that 500 contractors submit 4 quarterly reports,
and that it takes 1 hour to store, retrieve, prepare and
submit the report.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

500
x 4
2,000
x 1
2,000

(v) FAR 52.245-10(h)(2) and 45.302-6(d). We did not
identify any reporting requirements as specific to this FAR
cite as we included all property unsuitable for use under
the reporting burden identified under FAR 52.245-2(a)(3)(see
paragraph 13(m), above.).
(w) FAR 52.245-11 and 45.302-6(e)(1). No specific
burden was identified to this cite. The rationale applied
to FAR 52.245-7, paragraph 13(t) above.
(x) FAR 52.245-17(f)(1) and 45.306-5. We estimate
that approximately 900 contractors have special tooling.
Using the 900 as a baseline, we estimate that 75 contractors
also must maintain records on special tooling that they
actually produce. We estimate that each contractor
maintains 200 records and it takes 30 minutes to prepare
each record.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

75
x 200
15,000
x .5
7,500

The FAR requires three lists. We added hours for the
initial list of special tooling and the final list of
special tooling. The excess list of special tooling is
covered in paragraph (y) below. We calculated additional
hours as follows:
A.
B.
C.
D.

Number of respondents
Responses per respondent
Total annual responses
Hours per respose
10

900
x 10
9,000
x 1.5

E.

Total hours

13,500

(y) FAR 52.245-17(h). Of the 75 contractors
maintaining special tooling in accordance with this clause,
we estimate that 15 percent, or approximately 12 contractors
submit excess listings and that it takes each contractor 2
hours to store, retrieve, prepare and submit the
information.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

12
1
12
x 2
24
x

FAR 52.245-17(i)(4) requires contractors to submit two
copies of all special tooling lists to the ACO, PCO, and ICP
unless otherwise directed. We calculate the hours as
follows:
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual responses
Hours per response
Total hours

900
x 10
9,000
x .1
900

(z) FAR 52.245-18(b) and (e), and 45.307-3. The
reporting requirements for the special test equipment clause
are outlined in FAR 45.307-2(b), paragraph 13(a), above.
(aa) FAR 52.245-18(d). We estimate that only 60
subcontractors are given the authorization to fabricate or
acquire special test equipment each year. We estimate that
on the average each subcontractors name is submitted once
each year and it takes 30 minutes to prepare and submit the
notification.
A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual response
Hours per response
Total hours

60
x 1
60
x .5
30

(bb) FAR 52.245-19. We estimate that only 15
contractors provide notification that property provided "as
is" has changed in condition from the time it was last
inspected until time of receipt, and on an average, each
contractor submits one notification and that it takes 30
minutes to prepare and submit the notification.
A.
B.
C.
D.

Number of respondents
Responses per respondent
Total annual response
Hours per response
11

15
1
15
.5

E.

Total hours

7.5 (rounded
to 8)

A.
B.
C.
D.
E.

Number of respondents
Responses per respondent
Total annual responses
Hours per response
Total hours

Sum Total:
27,884
488.6
13,624,122
.4826
6,575,309

1
2

Cost to Public.
A.
B.
C.
14.

Total annual hours
6,575,805
Average wage + overhead
($20/hr + 75% overhead)
$35
Total annual
cost to Public
$230,153,175

Estimated annual cost to the Federal Government.

The time required for Government review of the
requirements of Part 45 is estimated to be approximately 1
(one) hour. This estimate is based on receiving, reviewing
and analyzing the information submitted by the contractor.
I. Number of responses:
II. Average hours per response:
III. Total burden hours:
IV. Average wages + overhead
($17/hr + 100% OH)
V. Total annual cost
to Government:

13,606,122
x
1
13,606,122
x $34
$462,608,148

15. Explain reasons for program changes or adjustments
reported in Item 13 or 14. This submission requests an
extension of OMB approval of an information collection
requirement in the FAR. The information collection
requirement in the FAR remains unchanged. Burden should
read 6,575,805 instead of 6,575,309. Simple addition error.
16.

Outline plans for published results of information
collections. Results of this collection will not be
tabulated or published.

17.

Approval not to display expiration date.
applicable.

1Based

on dividing C by A.

2Based

on dividing E by C.

12

Not

18.
B.

Explanation of exception to certification statement.
Not applicable.
Collection of Information Employing Statistical Methods.

Statistical methods will not be employed.

13