0307 Ss 20190501

Supporting Statement
Importation of Swine Hides, Bird Trophies, and Deer Hides
OMB No. 0579-0307
April 2019
NOTE: This is a reinstatement of a previously approved information collection with changes.
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.
The Animal Health Protection Act (AHPA) of 2002 is the primary Federal law governing the
protection of animal health. The law gives the Secretary of Agriculture broad authority to detect,
control, or eradicate pests or diseases of livestock or poultry. The Secretary may also prohibit or
restrict import or export of any animal or related material if necessary to prevent the spread of any
livestock or poultry pest or disease. The AHPA is contained in Title X, Subtitle E, Sections 1040118 of P.L. 107-171, May 13, 2002, the Farm Security and Rural Investment Act of 2002.
The Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of Agriculture
protects the health of the U.S. livestock and poultry populations. It prevents the spread of
contagious, infectious, or communicable animal diseases (such as African Swine Fever (ASF),
Bovine Babesiosis, Newcastle Disease (ND), Foot-and-Mouth Disease (FMD), Highly Pathogenic
Avian Influenza (HPAI), and Rinderpest). When feasible, it eradicates diseases from the United
States. Disease prevention is the most effective method for maintaining a healthy animal population
and for enhancing animal-related trade.
The regulations in 9 CFR part 95 (referred to below as the regulations) prohibit or restrict the
importation of specified animal products into the United States to prevent the introduction into the
U.S. livestock population of certain contagious animal diseases. Sections 95.16 and 95.17 of the
regulations contain, among other things, specific processing, and certification requirements for
untanned hides and skins and bird trophies.
The regulations require that shipments of hides be accompanied by certificates showing their origin
and certifying that the hides are from areas free of certain animal diseases. Shipments of ruminant
hides from Mexico must be accompanied by written statements indicating that the hides were frozen
for 24 hours and treated for ticks. Shipments of bird trophies must be accompanied by certificates of
origin certifying that the trophies are from regions free of exotic Newcastle disease and highly
pathogenic avian influenza. These activities help ensure that the products do not harbor disease or
ticks.
APHIS is asking the Office of Management and Budget (OMB) to approve, for 3 years, its use of
these information collection activities, to ensure that bird trophies and certain animal hides pose a
negligible risk of introducing certain animal diseases into the United States.
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2. Indicate how, by whom, how frequently, 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.
APHIS uses the following information activities to ensure that bird trophies and certain animal
hides pose a negligible risk of introducing certain animal diseases into the United States.
Certificate for Ruminant and Swine Hides from Certain Regions (Foreign Government)
9 CFR 95.16(a)(2)&(3)
Certificates are required to accompany shipments of hides to identify their origin. For ruminant
hides, foreign government officials certify that the ruminant hides are from regions free of FMD
and rinderpest. For swine hides, officials certify the hides are from regions free of ASF, FMD, and
rinderpest. If hides were from an approved slaughterhouse, foreign governments certify that on the
certificate. The certificate must bear the seal of the proper department of the national government of
the region in which the ruminants were slaughtered and be signed by an official veterinary inspector
of that region. The certificate must state that the hides or skins were taken from ruminants
slaughtered in an abattoir that meets the requirements that it be inspected and approved and that the
hides or skins are free from anthrax, FMD, and rinderpest.
Certificate or Importer Statement - Untanned Ruminant Skins (Business)
9 CFR 95.16 (a)(4)&(5)
Untanned ruminant hides or skins from any region may be imported without other restriction if an
inspector determines, based on inspection and on examination of a shipper or importer certificate,
that they have been pickled in a solution of salt containing mineral acid and with a pH less than or
equal to 5 and packed in barrels, casks, or tight cases while still wet with such solution; or they have
been treated with lime in such manner and for such period as to have obviously been processed, to
have become dehaired, and to have reached the stage of preparation for immediate manufacture into
products ordinarily made from rawhide.
Written Statement for Untanned Ruminant Hides from Mexico (Business) - 9 CFR 95.16(b)(2)
In addition to meeting all other applicable APHIS provisions, untanned deer or ruminant hides
imported from Mexico must be accompanied by a written statement from the owner or importer.
The statement must certify that the hides were pickled or treated with lime as specified or frozen
solid for 24 hours, which APHIS views as effective in eliminating ticks that could spread bovine
babesiosis.
Certificate for Untanned Ruminant Hides from Mexico (Foreign Government)
9 CFR 95.16(b)(3)
In addition to meeting all other applicable APHIS provisions, untanned deer or other ruminant hides
imported from Mexico must be accompanied by a certificate issued by a full-time salaried
veterinary officer of the Government of Mexico. The certificate must state that the hides were
treated with an acaricide to kill ticks that could carry and spread bovine babesiosis or taken from
cattle that were subjected to a tickicidal dip in one of the permitted dips at a Mexican facility 7 to 12
days before slaughter, and are free from ticks..

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Certificate for Bird Trophies from ND and HPAI-free Regions (Foreign Government)
9 CFR 95.16(c)
In addition to meeting all other applicable APHIS provisions, bird trophies imported from regions
that are free of ND and HPAI must be accompanied by a certificate of origin issued by a foreign
government official of the region of export. This certification statement will help to ensure that any
bird trophy imported into the United States will have originated in and been exported from a region
that is free of ND and HPAI.
Approved Warehouse Request and Agreement to Handle Restricted Animal Byproducts (VS
Form 16-28) (Business) - 9 CFR 94.6(b)
An establishment must provide evidence that it has the equipment, facilities, and capabilities to
store, handle, process, or disinfect restricted animal byproducts or controlled materials so as to
prevent the introduction or dissemination of ND and HPAI. This evidence is provided on VS Form
16-28. The following information is requested: date of last inspection, agreement expiration date (if
applicable), method of transportation by which products are received, countries from which
products originate, approximate yearly volume, name and title of contact person for the
establishment, byproducts or materials handled at the establishment, method of sewage disposal,
capacity and construction material of separate storage facilities (if applicable), whether there is
adequate separation of restricted and unrestricted materials, the method of transportation by which
products are moved to the storage facility, method of transportation by which products are moved to
the processing area, detailed description of how restricted materials are processed and/or
disinfected, name of the supervisor of processing and disinfection, name of disinfectants used, and
the methods used to disinfect containers. The signature of the inspector, the District Director, and
the approving official (Staff Veterinarian for Import-Export) are also required.
Approved Establishment Request and Agreement to Handle Restricted Animal Byproducts
(VS Form 16-29) and Recordkeeping (Business) - 9 CFR 94.6(b)
Restricted animal products, byproducts, and controlled materials including carcasses (or parts or
products of carcasses) of poultry, game birds, and other birds may be imported for consignment to
any museum, educational institution, or other establishment that has given APHIS evidence that it
has the equipment, facilities, and capabilities to store, handle, process, or disinfect such articles so
as to prevent the introduction or dissemination of ND and HPAI. Establishments that APHIS
determines meet the criteria are eligible to enter into an agreement for handling restricted imports of
animal byproducts and controlled materials via VS Form 16-29. The form requires signatures from
the establishment officer, the District Director, and a Staff Veterinarian for Import-Export. These
forms must be made available to an APHIS representative upon request, and must be maintained for
3 years.
Report of Entry, Shipment of Restricted Imported Animal Products and Animal Byproducts
and Other Material (VS Form 16-78) and Recordkeeping (Business) - 9 CFR 94.6(b)
This form accompanies all restricted animal products moving from the port of entry to APHISapproved establishments or APHIS-approved storage facilities. Part A of this form is completed by
U.S. Government inspectors at the port of entry. Part B of this form is completed by approved
establishments; that is, museums, educational institutions, or other establishments approved to
receive bird or poultry carcasses or products for educational purposes. The establishments forward a
copy of this form to the VS District Office. The completed form helps APHIS ensure that the
imported restricted materials are stored and processed in accordance with the requirements.
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Establishments must provide the following information on VS Form 16-78: Date products or
materials are received; the name of the approved establishment; whether the shipment is intact (if
not an explanation must be given); date of treatment completion; whether the railroad car, truck, or
other mode of transport has been disinfected; disinfectant used; method of treatment; disposition of
refuse; and the name and signature of the establishment owner. These forms must be made available
to an APHIS representative upon request, and must be maintained for 3 years.
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, e.g., permitting electronic submission of responses, and the basis
for the decision for adopting this means of collection. Also describe any consideration of using
information technology to reduce burden.
The certification statements used in this program must physically accompany the shipment to the
United States and must contain an original signature of the foreign government official, owner, or
importer to be valid.
APHIS has no control or influence over when foreign countries will automate their certificates.
However, APHIS is involved with the Government-wide utilization of the International Trade Data
System (ITDS) via the Automated Commercial Environment (ACE) to improve business operations
and further Agency missions. This will allow respondents to submit the data required by U.S.
Customs and Border Protection and its Partner Government Agencies (PGAs), such as APHIS to
import and export cargo through a Single Window concept. APHIS is also establishing a system
known as e-File for CARPOL (Certification, Accreditation, Registration, Permitting, and Other
Licensing) activities. This new system will strive to automate some of these information collection
activities. The system is still being developed and business processes continue to be identified and
mapped.
4. Describe efforts to identify duplication. Show specifically why any similar information
already available cannot be used or modified for use for the purpose described in item 2
above.
The information APHIS collects in connection with this program is not available from any other
source. APHIS is the only Agency responsible for preventing the introduction of foreign animal
diseases into the United States.
5. If the collection of information impacts small businesses or other small entities, describe
any methods used to minimize burden.
The information collected is the absolute minimum needed to ensure that bird trophies and certain
animal hides pose a negligible risk of introducing certain animal diseases into the United States.
APHIS estimates that less than 2 percent of importers could be considered small entities.

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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.
If the information was collected less frequently or not collected at all, it would significantly hinder
APHIS’ ability to ensure that these commodities pose a minimal risk of introducing foreign animal
diseases into the United States. This would make a disease incursion event much more likely, with
potentially devastating effects on the United States livestock industry.
7. Explain any special circumstances that require the collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5.
•

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;

Written Statement for Untanned Ruminant Hides from Mexico - The statement must certify that the
hides were pickled or treated with lime as specified or frozen solid for 24 hours, which APHIS
views as effective in eliminating ticks that could spread bovine babesiosis.
Certificate for Untanned Ruminant Hides from Mexico - The certificate must state that the hides
were treated with an acaricide to kill ticks that could carry and spread bovine babesiosis or taken
from cattle that were subjected to a tickicidal dip in one of the permitted dips at a Mexican facility 7
to 12 days before slaughter, and are free from ticks..
• 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 sharing of 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.

No other special circumstances exist that would require this collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5.
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8. 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 form, and on the data elements to be recorded, disclosed, or reported.
If applicable, provide a copy and identify the date and page number of publication in the
Federal Register of the agency's notice, soliciting comments on the information collection
prior to submission to OMB.
APHIS contacted the following individuals by email and phone to discuss the information APHIS
collects to administer its regulations regarding imports of the subject items. We discussed with them
how we and they obtain the necessary data and how frequently; how much data is available; the
convenience and clarity of reporting formats and other collection instruments; and the clarity of, and
necessity for, any recordkeeping requirements. The respondents stated via email or phone that they
had no concerns with any of these items and had no further recommendations.
John Meeham
Flora and Fauna Customhouse Brokerage
152-31 135th Ave., Jamaica, NY 11434
718-977-7700
jjmeeham@faunaandflora.com
Rosella Quartarone
Safari Specialty Importers Inc.
76 Boniface Drive, Suite 7
Pine Bush, NY 12566
845-943-5943
info@safarispecialtyimporters.com
Pat Devivo
MRZ Container Freight Station
107-02 150th Avenue
Jamaica, NY 11434
718-244-8914
On Thursday, February 21, 2019, pages 5411-5412, Volume 84, No. 35, APHIS published in the
Federal Register, a 60-day notice seeking public comments on APHIS’ plans to request a
reinstatement and 3-year approval of this collection of information. During that time, one comment
was received from a concerned citizen about her perception of the general maltreatment of animals.
It had no relevance to the purpose of this information collection.
9. Explain any decision to provide any payment or gift to respondents, other than
reenumeration of contractors or grantees.
This information collection activity involves no payments or gifts to respondents.

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10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
No additional assurance of confidentiality is provided with this information collection. Any and all
information obtained in this collection shall not be disclosed except in accordance with 5 U.S.C.
552a.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior or 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.
This information collection activity will ask no questions of a personal or sensitive nature.
12. Provide estimates of the hour burden of the collection of information. Indicate the
number of respondents, frequency of response, annual hour burden, and an explanation of
how the burden was estimated.
•

Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. 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.

See APHIS Form 71. Burden estimates were developed from discussions with APHIS headquarters
and field personnel, State veterinary authorities, and individuals who have expressed interest in the
importation of untanned ruminant hides and skins into the United States and bird trophies.
•

Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories.

APHIS estimates the total annualized cost to the above respondents to be $10,047.96. APHIS
arrived at this figure by multiplying the estimated total burden hours (247 hours) by the estimated
average hourly wage and bennet ($27.66 + 13.02 = 40.68) of the respondents. The estimated hourly
wage was provided by the U.S Department of Labor, Bureau of Labor Statistics (see
https://www.bls.gov/news.release/pdf/ocwage.pdf).
According to DOL BLS news release USDL-18-1499 dated September 18, 2018 (see
https://www.bls.gov/news.release/pdf/ecec.pdf), benefits account for 32% of employee costs, and
wages account for the remaining 68%. Mathematically, total costs can be calculated as a function
of wages, resulting in a multiplier of 1.4706.
Benefits = wages X 47.06% (27.66 X 0.4706 = $13.02)
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13. Provide estimates 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 estimates 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.
There are user fees associated with the usage of the VS Forms 16-28 and 16-29. The user fees are
for the inspection of various import and export facilities and establishments. The person for whom
the service is provided and the person requesting the service are jointly and severally liable for
payment of these user fees in accordance with §§130.50 and 130.51.
14. Provide estimates of annualized cost to the Federal government. Provide a description of
the method used to estimate cost and any other expense that would not have been incurred
without this collection of information.
See APHIS Form 79. The estimated annualized cost to the Federal Government is $14,646.91.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14
of the OMB Form 83-1.
ICR Summary of Burden:

Program Change Program Change Change Due to
Change Due to
Due to New
Due to Agency
Adjustment in Potential Violation
Statute
Discretion
Agency Estimate
of the PRA

Requested

Previously
Approved

Annual Number
of Responses

793

0

0

0

793

0

Annual Time
Burden (Hr)

248

0

0

0

248

0

Annual Cost
Burden ($)

0

0

0

0

0

0

This is a reinstatement of a previously approved information collection resulting in a program
change of 793 annual responses and 248 annual burden hours.
New burden in this reinstatement request not previously reported includes:
•

Certificate or Importer Statement for Untanned Ruminant Skins

•

Approved Warehouse Request and Agreement to Handle Restricted Animal Byproducts (VS
Form 16-28)

•

Approved Establishment Request and Agreement to Handle Restricted Animal Byproducts
(VS Form 16-29)

•

Report of Entry, Shipment of Restricted Imported Animal Products and Animal Byproducts
and Other Materials (VS Form 16-78)

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16. For collections of information whose results are planned to be published, outline plans for
tabulation and publication.
APHIS has no plans to publish information it collects in connection with this program.
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.
The VS Form 16-28, VS Form 16-29, and VS Form 16-78 are in multiple APHIS information collections;
therefore, it is not practical to include an OMB expiration date because of the various expiration dates for
each information collection. APHIS is seeking approval to not display the OMB expiration date on these
form; however, APHIS is also considering creating common forms.

18. Explain each exception to the certification statement identified in the “Certification for
Paperwork Reduction Act.”
APHIS can certify compliance with all provisions under the Act.
B. Collections of Information Employing Statistical Methods
Statistical methods are not employed in this information collection activity.

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