Supporting Statement

2133-0506 – Merchant Marine Medals and
Awards
Supporting Statement

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT
SUBMISSIONS UNDER 5 CFR PART 1320
Information Collection: 2133-0506
A.

Justification

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.
This information collection provides a method of awarding merchant marine medals and
decorations to masters, officers, and crew members of United States ships in recognition
of their service in areas of danger during the operations by the Armed Forces of the
United States in World War II, Korea, Vietnam, Operations Desert Shield and Desert
Storm, Operations Enduring Freedom and Iraqi Freedom and the replacement of awards
previously issued. This information collection is in support of the Department of
Transportation's strategic goal for National Security.

These medals are authorized by Public Law 100-324, "The Merchant Marine Decorations
and Medals Act."
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.
This information is acquired and used by MARAD personnel to assist in processing and
verifying requests for seamen’s service awards. The issuance of awards is based upon
occasional requests received from the public. Without this information collection,
merchant seamen who have valiantly served their nation during war-time or risked their
lives to rescue other seamen during peace-time would have no other method to obtain
actual or replacement service decorations.
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. Also describe any
consideration of using information technology to reduce burden.
The required information may be submitted to the agency via electronic means such as
Internet e-mail, FAX, or telephone. The agency provides a total electronic option,
however, we estimate actual electronic submission to be 50%.

4.
Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in item 2 above.
MARAD is the only Federal agency collecting the information and is the only agency
issuing these types of decorations.
5.
If the collection of information impacts small businesses or other small
entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
This information collection does not involve small businesses. The requests come from
individual seamen or their families and information collected is the minimum required to
effectively administer the program and maintain internal controls.
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.
Medals and other decorations are issued only by request from individual citizens, and
without the collection, merchant seamen would have no other method of obtaining actual
or replacement service decorations.
7.
Explain any special circumstances that would cause an information collection
to be conducted in a manner:
*
requiring respondents to report information to the agency more often than
quarterly;
*
requiring respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it;
*
requiring respondents to submit more than an original and two copies of any
document;
*
requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records for more than three years;
*
in connection with a statistical survey, that is not designed to produce valid
and reliable results that can be generalized to the universe of study;
*
requiring the use of a statistical data classification that has not been reviewed
and approved by OMB;
*
that includes a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by disclosure and data
security policies that are consistent with the pledge, or which unnecessarily impedes

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sharing data with other agencies for compatible confidential use; or
*
requiring respondents to submit proprietary trade secret, or other
confidential information unless the agency can demonstrate that it has instituted
procedures to protect the information's confidentiality to the extent permitted by
law.
There are no special circumstances that require the collection of information to be
conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.
8.
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.
Describe efforts to consult with 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.
Consultation with representatives of those from whom information is to be obtained
or those who must compile records should occur at least once every three years even if the collection of information activity is the same as in prior periods. There
may be circumstances that may preclude consultation in a specific situation. These
circumstances should be explained.
The Maritime Administration published a 60-day notice and request for comments on this
information collection in the Federal Register on December 29, 2009, copy attached).
Comments were due by March 1, 2010. No comments were received.
Contact with persons outside MARAD on the conduct of this program is continuous and
extensive. Hundreds of applications/requests are processed each year and contacts with
requestors and feedback opportunities are commonplace. There were no major program
problems that could not be resolved.
9.
Explain any decision to provide any payment or gift to respondents, other
than remuneration of contractors or grantees.
None.
10.
Describe any assurance of confidentiality provided to respondents and the
basis for the assurance in statute, regulation, or agency policy.
No assurances of confidentiality are provided to respondents.

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11.
Provide additional justification for any questions of a sensitive nature, such
as sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private. This justification should include the reasons why the
agency considers the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the information is
requested, and any steps to be taken to obtain their consent.
No questions of a sensitive nature are asked of respondents.
12.
Provide estimates of the hour burden of the collection of information. The
statement should:
*
Indicate the number of respondents, frequency of response, annual hour
burden, and an explanation of how the burden was estimated. Unless directed to do
so, agencies should not conduct special surveys to obtain information on which to
base hour burden estimates. Consultation with a sample (fewer than 10) of potential
respondents is desirable. If the hour burden on respondents is expected to vary
widely because of differences in activity, size, or complexity, show the range of
estimated burden and explain the reasons for the variance. Generally, estimates
should not include burden hours for customary and usual business practices.
*
If this request for approval covers more than one form, provide separate
hour burden estimates for each form and aggregate the hour burdens in item 13 of
OMB Form 83-I.
*
Provide estimates of annualized cost to respondents for the hour burdens for
collections of information, identifying and using appropriate wage rate categories.
The cost of contracting out or paying outside parties for information collection
activities should not be included here. Instead, this cost should be included in item
14.
Responses
Per
Respondent

Number of
Respondents
700

x

Total
Responses
Annually

1

= 700

Hours
Per
Response
x

1

Total
Hours
Annually
= 700

13.
Provide an estimate of the total annual cost burden to respondents or
recordkeepers resulting from the collection of information. (Do not include the cost
of any hour burden shown in items 12 and 14).
*
The cost estimate should be split into two components: (a) a total capital and
start-up cost component (annualized over its expected useful life); and (b) a total
operation and maintenance and purchase of services component. The estimates
should take into account costs associated with generating, maintaining and

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disclosing or providing the information. Include descriptions of methods used to
estimate major cost factors including system and technology acquisition, expected
useful life of capital equipment, the discount rate(s), and the time period over which
costs will be incurred. Capital and start-up costs include, among other items,
preparations for collecting information such as purchasing computers and software;
monitoring, sampling, drilling and testing equipment; and record storage facilities.
*
If cost estimates are expected to vary widely, agencies should present ranges
of cost burdens and explain the reasons for the variance. The cost of purchasing or
contracting out information collection services should be a part of this cost burden
estimate. In developing cost burden estimates, agencies may consult with a sample
of respondents (fewer than 10), utilize the 60-day pre-OMB submission public
comment process and use existing economic or regulatory impact analysis associated
with the rulemaking containing the information collection, as appropriate.
*
Generally, estimates should not include purchases of equipment or services,
or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory
compliance with requirements not associated with the information collection, (3) for
reasons other than to provide information or keep records for the government, or
(4) as part of customary and usual business or private practices.
The annual cost burden to the respondents per response is as follows:
(a) Total Capital and Start-Up Costs Estimate:

N/A

(b) Total Operation and Maintenance and Purchase of Services Estimate: N/A
14.
Provide estimates of annualized cost to the Federal Government. Also,
provide a description of the method used to estimate cost, which should include
quantification of hours, operational expenses (such as equipment, overhead,
printing, and support staff), and any other expense that would not have been
incurred without this collection of information. Agencies also may aggregate cost
estimates from items 12, 13, and 14 in a single table.
The total annual cost to the Federal Government for processing the collection is estimated
as follows:
One-time Costs: $
Annual Costs:

There are no one-time costs.

$ 74,361.00

Requests for medals are received by one employee of the Office of Sealift Support, who
has the sole responsibility for reviewing and processing requests as well as preparing,
photocopying and mailing awards. The estimated time required for these tasks is one
hour at an average hourly wage of $57.42.

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Number of
Employees
1
x

Hourly
Wage
$57.42

x

Project
Time
1 hour

Overhead at 85%
Sub-total
Times 700 responses per year

=

Cost Per
Application
$
57.42

=
=
=

$
48.81
$ 106.23
$74,361.00

Maximum Total Annual Cost to Federal Government:

$74,361.00

15.
Explain the reasons for any program changes or adjustments reported in
items 13 or 14 of OMB Form 83-I.
This information collection has decreased as last reported in 2006. The number of
World War II merchant marine veterans are rapidly declining. However, there are many
family members who contact the Maritime Administration while doing genealogy
research on their relatives. With various websites available, the public has been able to
retrieve information directly without contacting MARAD.
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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.
There are no plans to publish the results of this information collection for statistical
purposes.
17.
If seeking approval to not display the expiration date for OMB approval of
the information collection, explain the reasons that display would be inappropriate.
None.
18.
Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
None.

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