eFiling Alpha Pilot - Participant Questionnaire - Quantitative Burden

Example from Alpha Pilot. Actual Beta Pilot survey may vary from this, but expects
the length and the questions will be similar.

Participant Name:

1 Questionnaire Regarding Burden for Importers in the eFiling Alpha Pilot (Pilot)
If CPSC proceeds to conduct a larger-scale pilot, the Beta Pilot, we will need to estimate the burden (time and costs) for
participants to create, maintain, and provide data for eFiling, and for the government to process and review such data,
to meet the requirements of the Paperwork Reduction Act (PRA). CPSC will need to provide such estimates to the Office
of Management and Budget (OMB) and receive an OMB control number for the collection of information. The
information you provide below will assist CPSC in considering the framework for a Beta Pilot and estimating the burden
for submission to OMB.
Total number of products entered into the Product Registry
Total number of products for which PGA data was filed at entry
Total number of entry lines with PGA data submitted in the Pilot
Total estimated average cost to file CPSC PGA data in the Pilot per product $

; and per entry line $

.

Did you incur any capital, operating, or maintenance costs beyond staff time that were necessary to participate in the
Pilot? If so, please identify the nature and cost of such expenditures.

1.1 Stage of Participation
1. Please select the way you submitted PGA data:
Product Registry with reference number
Full PGA Message Set
Both

2. Please estimate the burden of participation in the Pilot by Staff Time, Employee Compensation Costs, and Other Costs
(please describe nature of other costs). (If this stage is not applicable to your experience, select N/A)
Total
Staff Time
2. STAGE AND BURDEN OF PARTICIPATION IN PILOT
N/A
Compensation
Other Costs
(hours)
Costs
EXAMPLE
3 hours
$300.00
$500 hardware
upgrade
1

A

B

C

D

E

F

G

H

I

Onboarding: Understanding CPSC's expectations and
directions, including: Kick-Off meeting, CATAIR
Implementation Guide, and Business Rules
documents

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Internal planning to approach the project

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Internally gathering and organizing electronic product
data (for either the Reference or Full PGA Message
Sets) per product

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Manually entering data in the Registry per product, or
providing Full PGA data to your broker. If you used
Full PGA, please describe what method you used to
transfer PGA data to your broker.

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Coordinating with your broker to prepare for project
to go live. Please describe any tasks that you believe
fall within this category.

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Coordinating with your broker to sync ACE Cargo
Release entry data with Product Registry reference
numbers

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Understanding the CBP warning/rejection messages
and working with CPSC to resolve those issues

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Registry:

Registry:

Registry:

Providing PGA data on an ongoing/recurring basis
throughout the pilot

Other:

2

TOTAL

Full PGA:

Full PGA:

Full PGA:

Produdct
Registry:

Product
Registry:

Product
Registry:

Full PGA:

Full PGA:

Full PGA:

3. If you were to participate in this same Pilot project, but it kicked off 1 year later (July 2017), using a steady-state ACE
system and a formalized PGA Message Set approach within ACE, do you believe your internal planning, time, and cost
would remain the same or be reduced? Please explain.

1.2 Data
4. How long did it take for you to gather information for each of the data fields and either place the information in the
Product Registry or provide it to your broker? A list of data fields appears in the chart below. If the burden for each
field is the same, in the space provided below, please estimate the average Staff Time and Total Compensation Cost to
provide each data field per product. If the burden to gather information varied by data field, you can use the optional
chart below to help estimate the average cost to gather data per product by field.

DATA FIELDS
A

B

N/A

Product Name and a Unique Product Identifier:
• GS1 Global Trade Item Number (GTIN), or
• Universal Product Code (UPC), or
• Model Number, or
• Serial Number, or
• Registered Number
Place of manufacture, including the Foreign
Manufacturer Name and Address

3

Registry:

Total Compensation
Cost
Registry:

Full PGA:

Full PGA:

Registry:

Registry:

Full PGA:

Full PGA:

Staff Time (Hours)

C

D

E

Testing Party (Laboratory) Name and Address

Rule(s) to which the finished product has been
certified

Certificate check box indicating that a required
certificate currently exists for the finished
product

TOTAL

Registry:

Registry:

Full PGA:

Full PGA:

Registry:

Registry:

Full PGA:

Full PGA:

Registry:

Registry:

Full PGA:

Full PGA:

Registry:

Registry:

Full PGA:

Full PGA:

5. If some data fields were more burdensome than others, what about providing this data made the data field more
burdensome?

6. Are there any additional unique product identifiers (in addition to model, UPC, etc.) you would like to include in a
future pilot? Why? Please estimate the time and cost associated with providing such a data field on a per-product basis.

4

7. Should CPSC include additional data elements that were not included in this Pilot in a future pilot? Should such data
fields be mandatory or optional? Please estimate the time and cost associated with providing such additional fields on a
per-product basis.

8. Are you (or someone on your behalf) separately maintaining the 5 eFiling data elements once such data has been
uploaded into the Product Registry or provided to your broker?
Yes
No
If you selected yes, what is the estimated total average cost per year to maintain the eFiling data elements? $
.
Does the cost of maintaining the eFiling data elements depend on the number of products or entries made per year, or
is this a static cost?

9. Would eFiling all data elements from a certificate, instead of select data elements from a certificate, be:
More burdensome
Less burdensome
Equally burdensome
Unknown
No Basis
Please explain the basis for your answer, including any increase or decrease in time and cost difference per product.

5

10. Are you (or someone on your behalf) separately maintaining the 5 eFiling data elements, in addition to maintaining
all data for a certificate?
Yes
No
What is the estimated total average cost per year to maintain certificate data? $
Does the cost of maintaining certificate data depend on the number of products or entries made per year, or is this a
static cost?

1.3 Burden
11. On average, how many distinct children’s products that are subject to CPSC’s third party testing and certification
requirements do you import per year?
12. On average, how many distinct non-children’s products that are subject to CPSC’s general certificate of conformity
requirement do you import per year?
13. On average, how many distinct SPH-listed products (children’s draw strings, electric handheld hairdryers, holiday
lights, extension cords) do you import per year?
14. On average, how many entry lines per year are associated with each of the following?
Importation of a regulated children’s product
Importation of a regulated non-children’s product
Importation of an SPH-listed product
15. CPSC provided a web services option to upload data into the Product Registry. No participants used this option in
the Alpha Pilot. Why did your firm choose manual entry into the Product Registry during the Pilot? Would you use a
web services option in a future pilot?

6

16. If burden was an issue in using web services, can you estimate the average time and compensation costs, and any
capital or one-time costs, associated with using web services initially and on an ongoing basis?

17. In a future pilot, would the web services option decrease the burden of providing product data? If so, by how much
per product and on an ongoing basis?

18. What, if any, impact did eFiling have on your broker costs to file entry data? Can you estimate the cost per product,
per line?

1.4 General Questions
19. Do you have any other comments/feedback on the time, costs, or burden to participate in the eFiling Alpha Pilot that
will assist us in estimating the burden to participate in a Beta Pilot?

20. How much time did it take for you to complete this Questionnaire?

7

Broker Name:

2 Questionnaire for Brokers Regarding Burden in the eFiling Alpha Pilot (Pilot)
If CPSC proceeds to conduct a larger scale pilot, the Beta Pilot, we will need to estimate the burden (time and costs) for
participants to create, maintain, and provide data for eFiling, and for the government to process and review such data,
to meet the requirements of the Paperwork Reduction Act (PRA). CPSC will need to provide such estimates to the Office
of Management and Budget (OMB) and receive an OMB control number for the collection of information. The
information you provide below will assist CPSC in considering the framework for a Beta Pilot and estimating the burden
for submission to OMB.
Total number of products entered into the Product Registry
Total number of products for which PGA data was filed at entry
Total number of entry lines with PGA data submitted in the Pilot
Total estimated average cost to file PGA data in the Pilot per product $

; and per entry line $

Did you incur any capital, operating, or maintenance costs beyond staff time that were necessary to participate in the
Pilot? If so, please identify the nature and cost of such expenditures.

1. Please select the way you submitted data in ACE:
Reference PGA Message Set (Product Registry Reference Number)
Full PGA Message Set
Both

8

.

2. Please estimate the burden of participation in the Pilot by Time, Employee Compensation Costs, and Other Costs
(please describe nature of other costs). (If this stage is not applicable to your experience, select N/A)
STAGE AND BURDEN OF PARTICIPATION IN PILOT

A

B

C

D

E

F

G

N/A

EXAMPLE

3 hours

Total
Compensation
Costs
$300.00

Onboarding: Understanding CPSC's expectations
and directions including: Kick-Off meeting,
CATAIR Implementation Guide, and Business
Rules documents

Registry:

Registry:

$500 hardware
upgrade
Registry:

Full PGA:

Full PGA:

Full PGA:

Internal planning to approach the project

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Coordinating with the Importer(s) to sync ACE
Cargo Release entry data with product reference
numbers

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Understanding the CBP warning/rejection
messages and working with CPSC to resolve those
issues

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Providing PGA data on an ongoing/recurring basis
throughout the pilot

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

Application software changes to code the
Reference PGA Message Set

Application software changes to code the Full
PGA Message Set

9

Staff Time
(hours)

Other Costs

H

Other:

Registry:

Registry:

Registry:

Full PGA:

Full PGA:

Full PGA:

TOTAL

2.1 Burden
3. What impact, if any, did eFiling have on the cost to file for participating clients, on a per-product and a per entry line
basis? Were those costs passed on to participants? If eFiling did not impact costs for the Alpha Pilot, what impact do
you anticipate that it will have on a per-product and per entry line basis in a Beta Pilot? What impact, if any, do you
anticipate that it will have on a per-product and per entry line basis if eFiling is implemented for all regulated consumer
products?

4. What, if any, one-time costs were associated with hardware, software, and training upgrades to accommodate
participation in the eFiling Alpha Pilot? If training costs are not included in the chart above, please estimate the average
number of hours of staff time and total compensation costs to train employees.

5. Once filed in a PGA Message Set, are you maintaining the reference PGA number or the 5 eFiling data elements?
Yes
No
Is there any additional cost (over and above the costs related to data you currently maintain for each client) associated
with maintaining this data? If your answer is yes, please provide the estimated total average cost per year to maintain
this data. $
10

Does the cost of maintaining this data depend on the number of products or entries made per year, or is this a static
cost?

6. If you were to participate in this same eFiling Alpha Pilot project, but it kicked off one year later (July 2017) using a
steady state ACE system and a formalized PGA Message Set approach within ACE, do you believe your internal planning,
time, and cost would remain the same, or be reduced?

7. How much time did it take for you to complete this Questionnaire?

11