I have the following questions regarding the proposed SITC Smuggling Form.
1. There are no directions with the form. No, not every cell is self explanatory.
2. Who is this sent too?
3. If it is sent via email then is Personal Identifiable Information (PII) and issue and should the document be password protected?
4. The name of the form is different than what is actually in the Federal Register.
5. The Federal register says:
• Estimate of burden: The public reporting burden for this collection of information is estimated to average 0.025 hours per response.
o However the form says:
• The time required to complete this information collection is estimated to average .25 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.
6. Are the Customs and Border Protection Agriculture Specialists (CBPAS) ever expected to complete this form? If so they still need to complete a Form CBP 191 Release of Information to release the information and the form should also be signed off by at least a Supervisory CBPAS.
7. If the CBPAS are to complete the form, isn’t this information already in the USDA Agriculture Quarantine Activity Database database?
8. If the CBAPS are to complete this then it really needs to be in the USDA Manual for Agriculture Clearance with directions answering all of the above questions.
9. If CBPAS are to complete this, then there is no room for entry numbers, Manufacture Identification or feedback and findings from SITC.
Comment from Dan Lundgren Lundgren
This is comment on Notice
Agency Information Collection Activities; Proposals, Submissions, and Approvals: Smuggling, Interdiction, and Trade Compliance Program
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Related Comments
Public Submission Posted: 08/09/2011 ID: APHIS-2011-0051-0003
Sep 19,2011 11:59 PM ET
Public Submission Posted: 07/22/2011 ID: APHIS-2011-0051-0002
Sep 19,2011 11:59 PM ET