SUMMARY OF 2020 INFORMATION COLLECTION - #0581-0191 Q15 Breakout | ||||||
REGS | REG Text | Previous Burden - 2016 plus 2018 revision as appropriate | New Burden 2019 | Difference Between New and Previous Burden | Type of Change | |
Producers and Handlers (Operations) | ||||||
205.101(c) | Subpart B -- APPLICABILITY exempt producers and handlers (11.5% of current total certified) document compliance and maintain records for not less than 3 years. National Agricultural Statistic Service (NASS) estimates that exempt producers represent 11.5% of the total number of certified organic producers. The difference is due to aligning with NASS's estimate, rather than guestimating. |
7,650.00 | 4,866.00 | -2,784.00 | ADJ | |
205.103 | Certified operators maintain records for not less than 5 years. Corrected recordkeeping from 80 hours to 40 hours. Recordkeeping is an act of routine storage, and is not labor intensive. Records are also kept to comply with other requirements, such as the Internal Revenue Service (IRS) and State Business Licensing requirements. The total hours are not halved from the prior renewal package because the number of farmers have increased from 31,000 to 44,805. | 2,480,000.00 | 1,792,209.24 | -687,790.76 | ADJ | |
2,487,650.00 | 1,797,075.24 | -690,574.76 | ||||
Subpart C & E - Production & Handling -- Operators submit initial application or update existing Organic System Plan (OSP) | ||||||
205.201(a)(1) - (6),205.400(b), 205.401d, 205.406(a)(1)(i) 205.406(a)(3) | Initial Application consists of: Operators list practices and procedures to be performed and maintained, substances used, monitoring practices & procedures, describe recordkeeping systems, practices to prevent commingling & contact with prohibited substances, and other information as necessary. Consolidated all Organic System Plan regs for operations applying for certification for the first time changed. Hours changes from 40 to 80 hours. At some in the history of preparing these collections, the preparation time for Initial and Updated applications for certification were reversed. See OMB approved revision 10/2018. | 152,000.00 | 199,698.48 | 47,698.48 | ADJ | |
205.201(a)(1) - (6),205.400(b), 205.401d, 205.406(a)(1)(i) 205.406(a)(3) | Annual Update: Operators update lists of practices and procedures to be performed and maintained, substances used, monitoring practices & procedures, describe recordkeeping systems, practices to prevent commingling & contact with prohibited substances, and other information as necessary. Consolidated all Organic System Plan regs for certified operations updating their OSPs annually with hours corrected from 80 to 40 during revision approved by OMB 10/2018. | 1,240,000.00 | 1,692,360.00 | 452,360.00 | ADJ | |
205.103 &.237 | Pasture Practice Reporting by Certified Operations (Maintenance). Change due to Increase in number of certified organic livestock producers | 37,600.00 | 50,896.00 | 13,296.00 | ADJ | |
205.103 &.237 | Pasture Recordkeeping by Certified Operations (Maintenance) Consolidated into recordkeeping of all livestock producers. | 4,700.00 | 0.00 | -4,700.00 | ADJ | |
205.301 | Subpart D - Labels, Labeling, and Market Information - certified handlers determine composition of products to be labeled. Change due to increase in number of certified handlers. | 262,680.00 | 363,700.00 | 101,020.00 | ADJ | |
205.301 | livestock feed handlers determine composition of feed. Change due to increase in number of certified livestock feed handlers. | 694.00 | 3,990.00 | 3,296.00 | ADJ | |
205.303- 205.311 | certified handlers ensure that labels comply with the requirements for labeling food as organic. Changes due to correction of hours from 10 to 2 hours per label per OMB approved revision from 10/2018. There is an increased number of handlers. | 525,360.00 | 727,400.00 | 202,040.00 | ADJ | |
205.306 | livestock feed handlers ensure that labels comply with the requirements for livestock feed. Changes due to a increase number of livestock feed handlers. | 694.00 | 3,990.00 | 3,296.00 | ADJ | |
205.401(c) | Subpart E - Appli. for Cert. of Operations Annual Update as Appropriate Operators submit names of other agents to whom applications were sent dates, & outcomes of noncompliance actions. | 200 | 200.00 | 0.00 | ||
205.405(b)(1) & (b)(3) | Operators describe corrective actions taken or rebut the non-compliance - 5% of operations based on internal program experience over time | 1580 | 6,720.78 | 5,140.78 | ADJ | |
205.405(b) (2) | Operators submit new application to another agent. No change. | 130 | 400.00 | 270.00 | ||
205.663 | Mediation applicants for certification or certified operations request mediation/certifier declines request | 3 | 1,096.73 | 1,093.73 | ADJ | |
205.681(a) | Adverse Action Appeal Process applicants for certification or certified operators appeal adverse decisions to Administrator | 370 | 780.00 | 410.00 | ADJ | |
2,226,011.00 | 3,051,231.99 | 825,220.99 | 0.00 | |||
Accredited Certifying Agents - Certification | ||||||
205.402 | Review of Application/Updates agents review and process applications/updates received for completeness and viability, communicate findings to applicant, schedule on-site inspections, and provide operations copy of their on-site inspection. Increase due to increased number of operations seeking certification |
205,400.00 | 268,831.39 | 63,431.39 | ADJ | |
205.404(b) 205.406(d) | Agents set up accounts in Organic Integrity Database and upload basic data on all operations. New burden with standing up new online database | 0 | 22,402.62 | 22,402.62 | ADJ | |
205.404(b) 205.406(d) | agents issue certificates of organic operation, annual and updated certificates Increase due to increased number of operations seeking certification | 16,450.00 | 22,402.62 | 5,952.62 | ADJ | |
205.29 | agents recommend that NOP issue a temporary variance and notifies certified operations of any variance. Decreased due to fewer variances requested. | 159.79 | 12.50 | -147.29 | ADJ | |
205.670(d) & (e) | Residue Testing: A certifying agent must, on an annual basis, sample and test from a minimum of five percent of the operations it certifies. Results must be provided to operation. Increase due to increased number of operations seeking certification and better reporting | 1577.83 | 1,120.13 | -457.70 | ADJ | |
205.402(b)(2) | agents provide applicant with a copy of test results for any samples taken by inspectors. Increase due to increased number of operations seeking certification and better reporting | 1,577.83 | 560.07 | -1,017.76 | ADJ | |
205.405(a) 205.406(c) 205.662(a) | Noncompliance Procedures of Operations agents provide written notification to operators of noncompliances. (10% of all certified operations and new applicants) Increased due to more total operations. |
1,580.00 | 4,480.52 | 2,900.52 | ADJ | |
205.405(c) (1)(i) | Agents approve corrective action of new applicants and existing operations, and issue certificates of organic operation to operator. (50% of those operations who submitted corrective actions or rebuttals). Increased due to more total operations. | 1580 | 2,240.26 | 660.26 | ADJ | |
205.405 (c)(1)(ii), 205.405(c) (2) | Agents deny certification when applicants' noncompliance are not sufficiently corrected or when applicant fails to respond to noncompliances. (This includes the nonrespondents to the noncompliances (50%) and those that responded but did not correct the noncompliances sufficiently (50%)). Increased due to more accurate account and more operations applying for certification. | 79.00 | 1,680.20 | 1,601.20 | ADJ | |
205.662(c) | Agents/State notify operators of proposed suspension or revocation. (This includes the nonrespondents to the noncompliances (50%) and those that responded but did not correct the noncompliances sufficiently (50%)). Increased due to better procedures and enforcement. | 315.00 | 2,706.72 | 2,391.72 | ADJ | |
205.662(e) | Agents/States notify operators of suspension or revocation. (Operations that did not request mediation or appeal adverse actions) Increased due to better enforcement procedures | 201.50 | 2,652.12 | 2,450.62 | ADJ | |
205.405(c)(3) 205.501(a)(15)(i) | Agents send Administrator notification of approvals or denials and adverse actions. Increased due to better enforcement procedures | 395.00 | 2,240.26 | 1,845.26 | ADJ | |
205.670(f) | States and agents provide test results to the public. Increased due to agents following recommended guidance and increased use of websites to provide this information to the public. | 78 | 1,120.13 | 1,042.13 | ADJ | |
205.670(g) | States and agents report to health agencies any findings of pesticide residues that exceed regulatory tolerances. Slight increase due to increased operations | 78.00 | 100.00 | 22.00 | ADJ | |
229,393.95 | 332,549.53 | 103,155.58 | ||||
Accredited Certifying Agents - Accreditation | ||||||
205.501 (a)(2-4), (6-7), (11)(v), (15) & (20-21); 205.503 (a -b), (d)(1-2) & (c-e); 205.504(a -e); 205.510(a)(1-2), and 205.642 | Accreditation of Certifying Agents - Form TM-10CG - Provide Policies, Procedures, Evidence of Expertise and Ability, describe organizational units, primary location, areas of certification (crops, livestock, & handling), States & foreign countries where they operate, lists of currently certified operations, conduct & provide results of performance evaluations of personnel & inspectors, conduct program evaluations of their certification activities, provide procedures for residue testing, and other information that will assist in evaluating their application, and comply with any other requirements. Increased because all recordkeeping was consolidated into a single requirement. | 347.72 | 6240 | 5,892.28 | ADJ | |
205.501 (a)(2-4), (6-7), (11)(v), (15) & (20-21); 205.503 (a -b), (d)(1-2) & (c-e); 205.504(a -e); 205.510(a)(1-2), and 205.642 | Accreditation of Certifying Agents - Form TM-10CG - Provide Policies, Procedures, Evidence of Expertise and Ability, describe organizational units, primary location, areas of certification (crops, livestock, & handling), States & foreign countries where they operate, lists of currently certified operations, conduct & provide results of performance evaluations of personnel & inspectors, conduct program evaluations of their certification activities, provide procedures for residue testing, and other information that will assist in evaluating their application, and comply with any other requirements. Increased because more operations seeking certification | 4,740.00 | 6,240.00 | 1,500.00 | ADJ | |
205.501 (a)(4)-(a)(6) | Certification Review Personnel have 10 hours of training per year. Calculated as two (2) 5 hour trainings. Included because training is recommended best practice and audits show that training is required by certifying agents. | 0.00 | 2,500.00 | 2,500.00 | ADJ | |
205.501(a)(8) | Agents provide information to applicants seeking certification. Change reflects actual number of new applicants. | 2,765.00 | 2,496.23 | -268.77 | ADJ | |
205.501(a)(18) | Agents notify inspector of certifying agent's certification decision of an operation that the inspector evaluated. Increase due to more operations. | 8,225.00 | 11,201.31 | 2,976.31 | ADJ | |
205.504(d)(2) | Agents provide inspec. Repts. & evaluation documents for operations certified. Agents only provide examples of 3 inspection reports each year, not all operations. Slight decrease due to one certifying agents losing accreditation. | 237.00 | 234.00 | -3.00 | ADJ | |
205.501(a)(20) | Agents demonstrate the ability to comply with State Organic Program's additional requirements. Increased time to be aligned with what this activity requires. | 26.00 | 52.00 | 26.00 | ADJ | |
205.504(d)(3) | Agents provide results of any accreditation done by another accrediting body. No change because there are very few other accrediting bodies in the organic space. | 16.00 | 16.00 | 0.00 | ||
205.505(b) | private agents provide additional assurances with statements of agreement. Increased to 30 minutes per request | 15.75 | 31.50 | 15.75 | ADJ | |
205.510(a)(3) | Agents report measures implemented at request of Administrator, annual. Increased because enforcement has improved. | 90.00 | 1,400.00 | 1,310.00 | ADJ | |
205.500(c)(2) | NOP Import Certificate is a condition of international equivalency arrangements. Increased due to more transactions. | 2,935.81 | 3,500.00 | 564.19 | ADJ | |
205.504 | Export Certificates agents issue as required by equivalency arrangements. Increased due to more transactions. | 39.50 | 390.00 | 350.50 | ADJ | |
205.507(b) 205.665(g) | Denial of Accreditation applicants may either appeal the decision or describe actions taken to correct the deficiencies an agent that is suspended may submit a request for accreditation with corrections. Only one denial occurred this year. | 8.00 | 1.00 | -7.00 | ADJ | |
205.501(c)(3) 205.665(f) | Suspensions or Revocations of Accreditation Agents that are suspended or revoked transfer records to Secretary and make them available to State officials. Increased due to not being accounted for in previous packages. Hours due to one certifying agent losing accreditation this year. | 0.00 | 574.43 | 574.43 | ADJ | |
205.681(b) | Adverse Action Appeal Process applicants for accreditation or accredited agents appeal adverse decisions to Administrator. No change because same number of certifying agents that either applied for accreditation or were denied renewal of their accreditation as prior years | 80.00 | 80.00 | 0.00 | ||
19,525.78 | 34,956.47 | 15,430.69 | ||||
Subpart E Certification - Inspectors | ||||||
205.403 205.406(b) | inspectors provide on-site inspection reports to the certifying agent, annual. Increased due to increase in total operations inspected. | 329,000.00 | 448,052.31 | 119,052.31 | ADJ | |
205.501 (a)(4)-(a)(6) | Inspectors have 10 hours of training per year. Calculated as two (2) 5 hour trainings. Included because training is recommended best practice and audits show that training is required by certifying agents. | 0.00 | 2,500.00 | 2,500.00 | ADJ | |
Subpart G Administrative - Petitioners | ||||||
205.607 | Petitioners petition to amend the National List. No change | 750.00 | 750.00 | 0.00 | ||
Subpart G Administrative -State Organic Program | ||||||
205.621(a) | States submit proposed State organic program to Secretary. No new States have applied to be a state organic program. | 40.00 | 0.00 | -40.00 | ADJ | |
205.621(c) | States update State organic program to the Secretary. Reporting. Not properly accounted for in prior years. | 0.00 | 80.00 | 80.00 | ADJ | |
205.621(c) | States update State organic program to the Secretary. Recordkeeping. Not properly accounted for in prior years. | 0.00 | 80.00 | 80.00 | ADJ | |
329,790.00 | 451,462.31 | 121,672.31 | ||||
TOTAL | 5,292,370.73 | 5,667,275.54 | 374,904.81 |
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