Department of Agriculture:

Actions Needed To Enhance Paperwork Management and Reduce Burden

GGD-80-14: Published: Mar 10, 1980. Publicly Released: Mar 26, 1980.

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A study was undertaken which examines the effectiveness of the Department of Agriculture's (USDA) paperwork management program and policies. To manage paperwork effectively, federal agencies need reliable information on the burden imposed on the public, the use made of the information requested, and the extent of duplicate reporting. To ascertain burden estimates, 87 USDA requirements were analyzed. How reasonable or reliable the estimates are is difficult to ascertain, since neither the USDA nor the Office of Management and Budget (OMB) made a comprehensive evaluation.

USDA should improve its paperwork management program to better manage and further reduce the burden imposed on the public. In determining the true burden imposed on the public, burden estimates are used as an indicator to manage and limit the paperwork burden imposed. Thus, accurate and reliable burden estimates are essential. To prepare the burden estimates, the Food Safety and Quality Service (FSQS) relied soley on its program staff's judgment rather than contacting respondents. However, staff judgment does not produce reliable estimates. Additionally, USDA agencies must justify need and demonstrate practical utility when collecting federal paperwork from the private sector. Practical utility is defined by OMB as an agency's ability to use and timely process the information it collects. However, FSQS and the Packers and Stockyards program (P&S) justify need on the basis that the reporting is required under USDA regulations and by law; and the USDA practical utility review is conducted informally without documentation to support what was questioned or changed.

Recommendations for Executive Action

  1. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Secretary of Agriculture should: (1) require the USDA clearance office to upgrade policies and guidelines for estimating burden, assessing utility, and identifying and eliminating duplication; (2) require each agency to fully assess the burden and utility of its reporting requirements; (3) direct the clearance office to certify as reasonable only verified agency burden estimates and burden reductions; (4) approve only FSQS requests for clearance in which the method used to prepare the estimates is fully documented, ranges of respondent burden are shown, and the consolidation guidelines of OMB are correctly followed; (5) verify FSQS burden estimates either through historical data or contracting a sample of respondents before renewing reporting requirements; (6) repackage the meat inspections requirement into requirements based on functional areas; (7) oversee evaluation of the 1,100 locally developed forms and reports of FSQS; (8) direct USDA agencies which use or collect information from slaughtering packers to coordinate their needs through P&S; and (9) require the clearance office to identify and eliminate unnecessary duplication among USDA forms and reports used to collect information from slaughtering packers.

    Agency Affected:

  2. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Director, OMB, should: (1) not delegate any additional authority to USDA for review of its repetitive reporting requirements until OMB determined that USDA corrected the shortcomings discussed in this report; and (2) designate USDA to be the focal agency responsible for overseeing the government's collection of slaughtering packer information.

    Agency Affected:

  3. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Secretary of Agriculture should direct the Administrator, FSQS, to: (1) reduce costs imposed on businesses by requiring them to submit only a single application with the proper number of finished labels for each product, and by reviewing label application on a first-come, first-serve basis; (2) assess the practical utility of the FSQS label index; and (3) minimize conflicting reporting requirements in labeling regulations and inspector manuals of FSQS which cause duplication and red-tape.

    Agency Affected:


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