Overview
Title
Submission for OMB Review; Comment Request
Agencies
ELI5 AI
The government wants to make sure that farm machines coming from other countries are really clean, so any bad germs can't get in. They're asking people to tell them what they think about this idea by March 31, 2025.
Summary AI
The Department of Agriculture has submitted a request to the Office of Management and Budget (OMB) for review of a proposed information collection as required under the Paperwork Reduction Act of 1995. This collection relates to the importation of farm equipment in order to prevent foot-and-mouth disease (FMD) from entering the United States. It includes a requirement for exporters to provide certification that their equipment has been steam-cleaned to remove any dirt or particulate material. Public comments on this proposal are invited and must be submitted by March 31, 2025.
Keywords AI
Sources
AnalysisAI
The document in question announces a submission by the Department of Agriculture to the Office of Management and Budget (OMB) for reviewing a proposed collection of information. This request is part of fulfilling requirements established under the Paperwork Reduction Act of 1995. The focus of this collection effort is on preventing the spread of foot-and-mouth disease (FMD) into the United States through the importation of farm equipment from regions afflicted with FMD. As a preventive measure, exporters of used farm equipment are required to provide certification that their equipment has been steam-cleaned to eliminate any dirt or debris before being brought into the United States. Public comments on this proposed collection are invited until March 31, 2025.
Significant Issues and Concerns
There are several notable issues within the document that warrant attention:
Lack of Detailed Justification: The document provides specific figures for the number of respondents (77) and the total burden hours (78), yet it lacks clarity or a detailed rationale supporting these estimates. This absence of specificity could cast doubt on their accuracy and may invite skepticism or queries from stakeholders.
Need for Specific Examples: The section regarding the "Need and Use of the Information" describes potential financial impacts on exporters and importers if the information were not collected. However, it does not provide concrete examples or evidence to substantiate these claims, which might weaken the argument presented.
Access to Comment Submission Details: Instructions for submitting comments via the website www.reginfo.gov are somewhat obscured within the document's text. This could be an obstacle for individuals wishing to provide feedback, as the process for doing so is not prominently outlined.
Complex Legal References: The document references specific legal acts and regulations, such as the Animal Health Protection Act and 9 CFR 94.1(c), without offering summaries to elucidate their significance. This omission may make it difficult for readers who are not familiar with agricultural laws to grasp the context fully.
Alternative Methods for Compliance: The document only addresses steam-cleaning as a method of compliance without clarifying if alternative cleaning or certification methods are accepted. This lack of flexibility might impose unnecessary burdens on exporters who could benefit from other viable, less cumbersome solutions.
Potential Impact on the Public and Stakeholders
Broad Public Impact
For the general public, the initiative represents a measure aimed at safeguarding American agriculture by mitigating the risk of introducing FMD via imported farm machinery. This proposed collection effort seeks to ensure the continued health and safety of livestock industries, which is of national interest.
Impact on Specific Stakeholders
Exporters and Importers: The requirement for steam-cleaning and certification imposes an additional step and potentially increased costs for those involved in the international trade of farm equipment. While necessary for biosecurity, this could be viewed as a barrier or an added operational challenge for exporters, particularly from FMD-affected regions.
Regulatory Bodies: For agencies like the Animal and Plant Health Inspection Service (APHIS), the collection and verification of this information are critical in fulfilling their mandate to protect U.S. agriculture. However, the process relies heavily on cooperation from foreign counterparts in certifying compliance, which may present logistic and diplomatic hurdles.
Overall, while the initiative addresses a significant agricultural protection issue, the document could be improved by being more accessible and providing more comprehensive details and justifications for its proposals.
Issues
• The document does not provide a detailed explanation or justification for the specific number of respondents (77) or burden hours (78), this could raise questions about the accuracy and validity of these estimates.
• The section describing the 'Need and Use of the Information' lacks specific examples or evidence to support the claims about the financial impact on exporters and importers if the information were not collected.
• The instruction to submit comments via www.reginfo.gov is somewhat buried in the text, which might make it difficult for readers to identify how and where to provide feedback.
• The document references specific legal acts and sections (e.g., Animal Health Protection Act, 9 CFR 94.1(c)) without summarizing their relevance or implications for readers unfamiliar with these regulations. This might make the document difficult to fully understand for those not well-versed in agricultural laws.
• The document does not clarify whether any alternative methods for cleaning or certification, besides steam-cleaning, are accepted or considered to ensure flexibility and possibly reduce the burden on exporters.