Estimating the burden of contractor paperwork at 29.65 million hours a year — counting the cost before asking for it
The Defense Department sought comment on an existing form requiring contractors to submit data, estimating the annual burden at 29,652,480 hours. Before the government may ask the public or businesses for information, it must calculate and publish the burden.
Document overview (primary data)
- Document typeNotice
- AgencyDepartment of Defense
- Citation91 FR 55844
Key points
- The Defense Department sought comment under the Paperwork Reduction Act on a form requiring contractors to submit data.
- The annual burden is estimated at 29,652,480 hours, roughly 14,000 person-years at 2,080 hours each.
- The components are 1,040 respondents, 432 responses each, 449,280 annual responses and 66 hours per response.
- The subject is DD Form 1423, the Contract Data Requirements List used to order contractor data in defense procurement.
- Comment is expressly invited on the accuracy of the burden estimate, so the figure itself can be contested.
1Count the burden before asking
Before the government may require the public or businesses to submit information, it must estimate and publish how much time preparing that paperwork will take them. The Paperwork Reduction Act of 1995 requires it, on the premise that counting the burden and making it public will reduce paperwork that is not needed.
2The burden estimated
The calculation yields 29,652,480 hours a year. At 2,080 working hours per person per year, that is roughly 14,000 person-years. One procedure — contractors submitting data to the department — is estimated to consume that much labor.
3What the paperwork is for
The subject is DD Form 1423, the Contract Data Requirements List, used in defense procurement contracts to order the data a contractor must deliver. Format and content are standardized by reference to pre-approved Data Item Descriptions. Information needed to design, test, manufacture, train on, operate, maintain and provide logistical support for what is acquired is obtained contractually through this mechanism.
4The 60-day stage
- 1First stage (this notice)The agency publishes the proposal and invites 60 days of comment, due October 30, 2026
- 2What is askedWhether the collection is necessary, whether the burden estimate is accurate, how to improve quality, how to reduce burden
- 3Second stageThe agency applies to the Office of Management and Budget and invites a further 30 days of comment
- 4Effect of approvalA control number is assigned; here 0704-0188
Approval of an information collection proceeds in two stages. This is the first, where the agency asks the public directly. A second comment period follows alongside the application to the Office of Management and Budget. This site also covers a second-stage notice published the same day, so the two can be read together as one procedure.
5The estimate itself is open to comment
Notably, the matters on which comment is invited expressly include the accuracy of the burden estimate. The figure of 29.65 million hours can itself be contested by the businesses bearing it, as too high or too low. The government is made to produce a number, and then made to have that number checked.
Why it matters
The volume of paperwork government requires is quantified in hours and published. Because the estimate itself is open to comment, those bearing the burden can contest the number.
FAQ
Why publish an estimate of burden hours?
How do 60-day and 30-day notices differ?
Sources (primary)
Source: Federal Register (federal documents, public domain). Links go to the official site.