1617ss06

INFORMATION COLLECTION REQUEST

FOR

SERVICING OF MOTOR VEHICLE AIR CONDITIONERS

SUPPORTING STATEMENT A

1. Identification of Information Collection

a) Title: "Servicing of Motor Vehicle Air Conditioners"

OMB Control Number: 2060-0247

EPA Number: 1617.06

b) Short Characterization/Abstract

History. Section 609 of the Clean Air Act Amendments of 1990 (Act) provides general guidelines for motor vehicle air conditioning (MVAC) refrigerant handling and MVAC servicing. It states that “no person repairing or servicing motor vehicles for consideration may perform any service on a motor vehicle air conditioner involving the refrigerant for such air conditioner without properly using approved refrigerant recovery and/or recovery and recycling equipment (hereafter referred to as “refrigerant handling equipment”) and no such person may perform such service unless such person has been properly trained and certified.” In 1992, EPA developed regulations under section 609 that were published in 57 FR 31242, and codified at 40 CFR Subpart B (§ 82.30 et seq.). The information required to be collected under the Section 609 regulations is currently approved for use through December 31, 2008. This supporting statement is submitted to justify an extension of the approval of use of this information. Pursuant to new requirements under the Paperwork Reduction Act, a notice was published in the Federal Register on June 9, 2008, announcing the intent to extend the renewal of this Infor­mation Collection Request and requesting comment on the renewal. Descriptions of the recordkeeping and reporting requirements mandated by section 609 and delineated in 40 CFR 82 subpart B are summarized below in this section. The chart located at the end of this document displays the estimated costs of these requirements.

Approved Refrigerant Handling Equipment. In accordance with Section 609(b)(2)(A), 40 CFR 82.36 requires that refrigerant handling equipment be certified by EPA or independent standards testing organization. Certification standards are particular to the type of equipment and the refrigerant to be recovered, and must be consistent with the Society of Automotive Engineers (SAE) standards for motor vehicle air conditioning (MVAC) equipment.

Approved independent standards testing organizations. Section 609(b)(2)(A) of the Act requires independent laboratory testing of refrigerant handling equipment to be certified by EPA. The Stratospheric Protection Division (SPD) requires independent laboratories to submit an application that documents: the organization’s capacity to accurately test equipment compliance with applicable standards consistent with the SAE standards for handling refrigerant, an absence of conflict of interest or financial benefit based on test outcomes, and an agreement to allow EPA access to verify application information. Once an independent laborato­ry has been approved by EPA, the application is kept on file in the SPD. Two laboratories – Underwriters Laboratories Inc. and ETL Testing Laboratories – are currently approved to test refrigerant handling equipment. EPA does not anticipate that any organizations will apply to EPA in the future to become approved independent standards testing organizations. Therefore, annual hours and costs related to information submitted by these organizations have been eliminated.

Technician training and certification. According to Section 609(b)(4) of the Act, automotive technicians are required to be trained and certified in the proper use of approved refrigerant handling equipment. Programs that perform technician training and certification activities must apply to the SPD for approval by submitting verification that its program meets EPA standards. The information requested is used by the SPD to guarantee a degree of uniformity in the testing programs for motor vehicle service techni­cians.

Due to rapid developments in technology, the Agency requires that each approved technician certification program conducts periodic reviews and updates of test material, submitting a written summary of the review and program changes to EPA every two years. After the test has been approved by EPA, a hard copy remains on file with SPD. Currently, 24 testing programs are approved by EPA to train technicians in the proper use of refrigerant handling equipment. Six of these programs are designed specifically for individual company’s own employees.

Certification, reporting and recordkeeping. To facilitate enforcement under Section 609, EPA has developed several record­keeping requirements. All required records must be retained on-site for a minimum of three years, unless otherwise indicated.

Section 609(c) of the Act states that by January 1, 1992, no person may service any motor vehicle air conditioner without being properly trained and certified, nor without using properly approved refrigerant handling equipment. To this end, 40 CFR 82.42(a) states that by January 1, 1993, each service provider must have submitted to EPA on a one-time basis a statement signed by the owner of the equipment or another responsible officer that provides the name of the equip­ment purchaser, the address of the service establishment where the equipment will be located, the manufacturer name, equipment model number, date of manufacture, and equipment serial number. The statement must also indicate that the equipment will be properly used in servicing motor vehicle air condition­ers and that each individual authorized by the purchaser to perform service is property trained and certified. The information is used by the SPD to verify compli­ance with Section 609 of the Act.

Any person who owns approved refrigerant handling equipment must maintain records of the name and address of any facility to which refrigerant is sent. Additionally, any person who owns approved refrigerant handling equipment must retain records demonstrating that all persons authorized to operate the equipment are currently certified technicians.

Finally, any person who sells or distributes a class I or class II refrigerant that is in a container of less than 20 pounds must verify that the purchaser is a properly trained and certified technician, unless the purchase of small containers is for resale only. In that case, the seller must obtain a written statement from the purchaser that the containers are for resale only, and must indicate the purchaser's name and business address. When a certified technician purchases small contain­ers of refrigerant for servicing motor vehicles, the seller must have a reasonable basis for believing the accuracy of the information presented by the purchaser. In all cases, the seller must display a sign where sales occur that states the certification requirements for purchasers.

2. Need for and Use of the Collection

a) Authority for the Collection

The information requested for all entities that service motor vehicle air conditioning is required by Section 609(d) of the Act and 40 CFR 82.36, 82.40, 82.42. This includes certification of both approved equipment and properly trained personnel. Section 609(b)(2)(A) and 40 CFR 82.38 require the approval of independent standards testing organization by EPA. Automotive air conditioning technician certification programs are referred to in Section 609(b)(4), and applicable requirements for program certification are detailed in 40 CFR 82.40. Reporting requirements associated with the sale of small containers for resale only are noted in Section 609(e) of the Act and 40 CFR 82.42(b)(3). The record­keeping requirements for the motor vehicle recycling program are derived from Section 114 of the Act.

b) Practical Utility/Users of the Data

Motor vehicle air conditioning service establishments are required by Section 609 of the Act to have purchased approved refrigerant handling equipment and to have only properly trained and certified personnel using the equipment by January 1, 1992. They must submit certification documents to EPA by January 1, 1993. The SPD uses the certifi­cates to confirm compliance with Section 609.

i) Equipment Certification

The Agency is required either to certify refrigerant handling equipment itself or to approve independent laboratories to test and certify equipment. In order for EPA to certify equipment, the Agency must be provided with information that proves the equipment’s ability to recover and/or recycle refrigerant according to the SAE J standards. Certification standards are particular to the type of equipment used and refrigerant being recovered.

Since EPA does not have the capabilities to test all refrigerant handling equipment on a national scale, the Agency relies on private laboratories to test equipment. Currently, Underwriters Laborato­ries (UL) and ETL Testing Laboratories (ETL) certify equipment on a voluntary basis. The Agency established an approval system to evaluate UL and ETL procedures and those of any other laboratories that may request approval in the future. Information submitted by the laboratories must include documentation of their capacity to accurately test equipment, an absence of a conflict of interest or financial benefit based on test results, and agreement to allow EPA access to verify information. The SPD uses the information provided by independent laboratories to evaluate their capacity to properly test refrigerant handling equip­ment. The Agency has required only the submission of information that will enable it to ensure that all approved laboratories can test equipment under Agency standards and the accepted SAE J standards.

ii) Technician Certification Programs

Technicians must pass a test at the completion of a certification program in order to perform any service or repair on MVACs and in order to use the approved equipment as stipulated in Section 609 and 40 CFR 82.34, 82.40. Technician certification programs must submit verification to EPA of their compliance with standards set forth in 40 CFR 82.40. The SPD uses certification program information to ensure that Agency standards are met, and that they are at least as stringent as the SAE J standards of the Society of Automotive Engineers, or the current national standard.

Because of the rapidly changing nature of the motor vehicle air conditioning market, EPA requires that technician certification programs conduct internal reviews and update their program periodically. By requiring a written summary of the review and any program changes to be reported to EPA every two years, the Agency ensures the accuracy of the information, and maintains parity among testing programs.

iii) Refrigerant Sent Off-site

EPA requires service establishments to record the name and address of any off-site facility which is reclaiming refrigerant. This information is used to verify compli­ance with the motor vehicle air conditioning recycling program.

iv) Purchases of Small Cans

Distribu­tors who purchase small containers of refrigerant must be properly trained and certified according to the standards set forth in 40 CFR 82.40, unless the purchaser provides a written statement verifying that the small containers were purchased for resale only. The seller may keep the initial statement from a distributor and update the file with the amounts of refrigerant purchased in the form of small containers. These records are used to ensure that small containers of refrigerant are not available for non-certified technicians. By requiring only minor additions to the existing invoice procedures, the Agency has ensured total compliance with Section 609.

3. Non-duplication, Consultations, and Other Collection Criteria

a) Non-Duplication

The specific information requested by this notice is not currently collected by any other office within EPA or any other government agency.

b) Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPAissued a public notice in the Federal Register on June 9, 2008 soliciting public comments for a 60-day period (73 FR 32570). EPA received no comments. EPA will issue a second notice soliciting public comments for a 30-day period concurrent with the submission of this renewal to OMB.

c) Consultations

In developing the regulations under the Act, EPA established an advisory council for issues relating to stratospheric ozone. The Stratospheric Ozone Protec­tion Advisory Council (STOPAC) membership included representatives from affected industries, environ­mental interest groups, and academics in related fields. Within STOPAC, subcommittees were formed to look at the more detailed issues. The subcommittee on motor vehicle air condi­tioning met several times, and discussed all aspects of the proposed regulations for Section 609 of the Act.

To update this ICR, information was recently obtained from the Mobile Air Conditioning Society (MACS) Worldwide and a number of technician certification organizations.

d) Effects of Less Frequent Collection

The equipment certification time table was established by Congress in Section 609. Since the certification submission is a one-time occurrence, a less frequent collection of this information would make it impossible to comply with Section 609.

Again, verifications of technician certification programs and independent standards testing organizations are required to be submitted to EPA under Section 609 of the Act. The review is a one-time occurrence and must take place to allow the Agency to approve programs under the Act.

Technician training and certification programs are required to submit to EPA a summary of their program reviews and updates every two years. This frequency of reporting is necessary because of the rapid rate of technological advancements.

e) General Guidelines

This rule does not exceed any of the guidelines.

f) Confidentiality

This section does not apply because this ICR does not request information of a confidential nature.

g) Sensitive Questions

This section does not apply because this ICR does not request information of a sensitive nature.

4. The Respondents and the Information Requested

a) Respondents / NAICS Codes

The following is a list of NAICS codes for organizations potentially affected by the information requirements covered under this ICR. It is meant to include any establishment that may service or maintain motor vehicle air conditioners.

4411 Automobile Dealers

4413 Automotive Parts, Accessories, and Tire Stores

447 Gasoline Stations

45299 All Other General Merchandise Stores

8111 Automotive Repair and Maintenance

Other affected groups include:

Independent Standards Testing Organizations

Organizations with Technician Certification Programs

b) Information Requested

i) Data Items, including Recordkeeping Requirements

All entities that service motor vehicle air conditioners must send to EPA, on a one-time basis, certification of an appropriate MVAC refrigerant handling device. This certifica­tion must include the name of the purchaser of the equipment, address of the establishment where the equipment will be located, name of equipment manufacturer, model number, date of manufacture, and serial number. The statement must be signed by the owner of the equipment or other responsible officer, and must indicate that the equipment will be properly used in servicing motor vehicle air condition­ers, and that each individual authorized by the purchaser to perform service is property trained and certified.

Independent laboratory testing of refrigerant handling equipment is designed to ensure that the equipment is capable of safely meeting the standards set forth by EPA in appendices to 40 CFR 82 Subpart B. To establish a degree of uniformity to the equipment certification programs, EPA requires organizations to submit applications documenting: the equipment used for equipment testing; the expertise and technical experience of their personnel; thorough knowledge of the standards in the appendices to 40 CFR 82 Subpart B; test procedures to be used and the rationale for them; absence of a conflict of interest or financial benefit based on test results; and agreement to allow EPA access to verify information. Specific reporting requirements may include: equipment ability to remove moisture, oil, and noncondensable gases from refrigerant, and a list of testing equipment used.

Technician certification programs interested in certifying technicians are required to document that their program meets EPA standards. An acceptable program includes the following components: adequate training through on-the-job or on-site instructional training, or self-study; a test that effectively covers all relevant standards dealing with the servicing and repair of motor vehicle air conditioners, anticipated future technological developments, the regulatory requirements imposed by EPA under Section 609 of the Act, the environmental conse­quences of the release of refrigerant during the servicing and repair of motor vehicle air conditioners, and the adverse effects of stratospheric ozone depletion; a test grader who receives no benefit based on test results; means of identifying the individual taking the test; the measures taken at the test site to ensure that the tests are completed honestly by each technician; individual proof of certification in the form of a certificate or card and unique certification number.

Certification programs are required to conduct a periodic review of their test material and submit to EPA a written program review summary and any material changes every two years.

Service establishments that own approved refrigerant handling equipment and send used refrigerant off-site for recycling or reclamation must record the facility name and address to which any refrigerant is sent. In addition, the seller of small containers to an uncertified purchaser must be provided with a written statement that the containers are for resale only. The statement must also contain the purchaser’s name and address. Finally, any person who owns equipment must retain records demonstrating that all technicians authorized to operate the equipment are certified pursuant to the Clean Air Act. All of these records must be kept on-site for a minimum of three years.

ii) Respondent Activities

All Entities That Service Motor Vehicle Air Conditioners

• One-Time Equipment and User Certification Forms:

  • Compile documentation for a certification that states the following: The name of the purchaser of the equipment, address of the establishment where the equipment will be located, name of equipment manufacturer, model number, date of manufacture, and serial number. The statement must be signed by the owner of the equipment or other responsible officer, and indicate that the equipment will be properly used in servicing motor vehicle air condition­ers and that each individual authorized by the purchaser to perform service is property trained and certified. In many cases a form is provided by the manufacturer of the equip­ment. Prepare and submit completed certification to EPA.

• Records of Certified Technicians:

  • Maintain records on-site demonstrating that all equipment users are properly trained and certified.

• Records of Refrigerant Sent Off-site:

  • Record and file the facility address to which any refrigerant is sent for off-site reclamation or recycling.

• Records of Class I or Class II Refrigerant Sold for Re-Sale:

  • Verify that purchaser is properly trained and certified.

  • Compile and file written statements from uncertified purchasers verifying their intent to only resell the small containers of refrigerant.

Independent Standards Testing Organizations

• New Independent Standards Testing Organization Certification

  • Research SAE J standards on MVAC refrigerant handling equipment.

  • Compile test methodology, a list of required equipment, and other information regarding the SAE standards for the application to EPA.

  • Prepare and submit application to EPA that documents capacity to accurately test whether refrigerant handling equipment complies with the applicable standards, an absence of conflict of interest or financial benefit based on test results and an agreement to allow EPA access to verify information to ensure that the testing program fulfills the SAE J-1990 standards for recycling and recovery equipment.

Technician Certification Programs

• New Technician Certification Program Certification:

  • Compile documents and submit to EPA verification that training program meets EPA standards.

• Technician Certification Program Review:

  • Conduct periodic program reviews

  • Prepare and submit summary of program review to EPA every two years

5. The Information Collected: Agency Activities, Collection Methodology, and Informa­tion Management

a) Agency Activities

• One-Time Equipment and User Certification Forms:

  • Review and store certification applications and supporting documents from all entities that have purchased approved refrigerant handling equipment.

• Records of Certified Technicians:

  • No Agency action required.

• Records of Refrigerant Sent Off-site:

  • No Agency action required.

• Records of Refrigerant Sold for Re-Sale:

  • No Agency action required.

• New Independent Standards Testing Organization Certification:

  • Review applications from independent labs that request to certify refrigerant handling equipment.

• New Technician Certification Program Certification:

  • Review applications from new technician certification programs.

• Technician Certification Program Review:

  • Review summaries of certification program updates every two years.

b) Collection Methodology and Management

The SPD and the EPA regional offices have planned and allocated resources for the efficient and effective management and use of this information. The Agency has developed a sample form that manufacturers may distribute to service establishments that have purchased approved refrigerant handling equipment. An establishment may submit the form provided by the manufacturer of the equipment. Entities are not required to use the manu­facturer's form, but they must submit the required information. The information submitted by each service establishment is maintained by the EPA Regional offices.

Independent standards testing organizations must submit to the Agency an application documenting their capacity to accurately test whether refrigerant handling equipment complies with the applicable standards, an absence of conflict of interest or financial benefit based on test results, and an agreement to allow EPA access to verify information. The Agency examines the submitted test procedures for their ability to meet the SAE standards as specified in Section 609 of the Act. These applications may be submitted manually or electronically, as long as they are made available for Agency review.

Technician certification programs must submit to the Agency a verification of their compliance with EPA regulations for review and approval by the SPD. Program materials include, but are not limited to: video tapes, scripts, manuals, booklets, and software or other forms of electronic information. Testing of technicians may be performed either manually or electronically. The certification programs and their review reports are kept on file at EPA for reference.

The Agency has determined that periodic on-site inspection is the most effective method to ensure compliance with Section 609. Records should be kept at the location where service involving refrigerant is performed or where small containers of refrigerant are distributed for resale.

c) Small Entity Flexibility

Section 609 contains a provision that allowed small entities (i.e., those which performed service on fewer than 100 motor vehicle air conditioners during the calendar year 1990) an additional year to comply with the provisions of Section 609.

EPA does not expect any new technician certification programs or indepen­dent standards testing programs to apply for approval; thus, this requirement is not expected to affect small entities.

The name and address of the refrigerant handling facility to which refrigerant is sent by an establishment with recovery-only capabilities is a standard part of existing record­keeping procedures for business transactions. The regulations regarding records maintained by persons who sell small containers of refrigerant solely require that the resale-only statement be added into invoicing procedures for sales to uncertified purchasers.

d) Collection Schedule

All entities operating at the time the regulations were introduced were required to submit certification forms to EPA by January 1, 1993. The certification for refrigerant handling equipment is intended as a one-time information request for the life of the equipment.

After the initial EPA approval, technician training programs must review their programs periodically to account for technological developments. A summary of the program review and any changes must be submitted to EPA every two years.

6. Estimating the Burden and Cost of the Collection

a) Estimating Respondent Burden

The basis of the analysis is the identification of the principal steps involved in complying with EPA recordkeeping and reporting requirements and the estimated burden associated with each step. The burden has been estimated by identifying the number of times the step will be undertaken and the number of hours required to complete each step. Appendix 1 presents the estimated annual respondent burden and costs for information collection activities associated with Section 609 of the Act.

Time required for completion of each activity is derived from the estimates in the previous ICR, with several exceptions. In this ICR, the maintenance of records of technician certification (of photocopying and filing the technician’s certification card) is estimated to require 0.083 clerical work hours per establishment (5 minutes), which is a reduction from the previous ICR’s estimate of 0.25 hours (15 minutes). Additionally, in this ICR, the equipment and user certification for compilation, preparation, and submission is estimated to require 0.17 hours (10 minutes) per establishment, which is a reduction from the 0.25 hour allotment in the previous ICR. This labor burden includes completion and mailing of a prepared form, which is included with equipment at time of purchase. The form requires information on establishment name, address, and telephone number, as well as equipment manufacturer, model number, serial number, and year.

In this ICR, time requirements have been divided into more discrete activities. For example, the previous ICR estimated a burden of 2 hours per establishment for conducting technician certification program reviews and submitting a summary to the EPA. In this ICR, 1.5 hours has been allotted per establishment to conduct the reviews, and 0.5 hours has been allotted per establishment to prepare and submit the summary.

It should be noted that minimal records need to be developed by industry establishments, and these records can be stored as hard copies; there is no need for the creation (or maintenance) of a database system. Therefore, no additional hours or costs are required for these activities.

b) Estimating Respondent Costs

i) Estimating Labor Costs

Respondent labor costs (hourly rate plus overhead and fringe) are estimated using data from the Bureau of Labor Statistics. Average hourly wages are multiplied by a factor of 2.1 to reflect the estimated additional costs for overhead and fringe. General recordkeeping tasks are assigned to administrative assistants, whereas preparations of applications and reports are assigned to managers. The following job characterizations were used in Table 1:

• General and Operations Manager: $47.73/hr x 2.1 = $100.23

• Executive Secretaries and Administrative Assistants: $18.83/hr x 2.1 = $39.54

• Automotive Service Technicians and Mechanics: $17.54/hr x 2.1 = $36.83

Table 1. Average Hourly Establishment Labor Costs

Managerial	Clerical	Technical
$100.23	$39.54	$36.83

ii) Estimating Capital and Operations and Maintenance Costs

The Agency estimates that there are no capital/operations and maintenance costs associated with the requirements of Section 609, and therefore, with the renewal of this information collection request.

c) Estimating Agency Burden and Cost

The basis of this analysis is the identification of the steps involved in implementing and operating the system. The costs associated with each step have been estimated by identifying the number of times the step will be undertaken, the number of hours required to complete each step, and the total dollar cost. Appendix 2 presents the estimated Agency burden hours and costs associated with the information collection activities for this ICR. Agency labor costs are based on the 2008 GS Salary Schedule for the locality pay area of Washington-Baltimore-Northern Virginia, DC-MD-PA-WV, which are multiplied by 1.6, the standard government benefits multiplier.¹ See Table 2 for EPA estimates of average hourly labor costs for managerial and clerical staff, whose wage estimates are based on GS 12 step 2, and GS 7 step 2 hourly rates respectively. As shown, EPA estimates that the annual Agency burden for all activities covered in this ICR is 253 hours at a total cost of $7,953.28 per year.

Wage estimates are based on the following characterizations of occupations:

• GS 12 Step 2 - Managerial: $34.54/hr x 1.6 = $55.26/hr

• GS 7 Step 2 - Clerical: $19.47/hr x 1.6 = $31.15/hr

Table 2. Average Hourly Agency Labor Costs

Managerial	Clerical
$55.26	$31.15

Estimates of burden hours are based on assumptions that filing and recording information will take very little time. Specific estimates are detailed in Appendix 2. No additional hours or costs will be incurred for preparation or development of a recordkeeping database. For the establishment activities that simply require on-site recordkeeping, EPA has no correlated burden. Similarly, for the activities currently not applicable to any establishments, EPA has no correlated burden.

d) Estimating the Respondent Universe and Total Burden and Costs

An average of 250 equipment certification forms are received and processed by EPA each month. Therefore, it is estimated that 3,000 establishments will compile and submit one-time certification forms to EPA each year. This estimate is consistent with those used in the previous ICR, which disaggregated the estimate into 2,000 forms from establishments that change ownership and have to submit a new one-time certification form, and 1,000 forms from new firms entering the market that are seeking certification of equipment and therefore must submit a one-time certification form. While these certification forms were historically sent by respondents to EPA Headquarters and then forwarded on to EPA Regional offices, as appropriate, they are now sent directly from establishments to EPA Regional offices.

The previous ICR estimated that there will be 14,000 establishments per year that must maintain records demonstrating that all equipment users are properly trained and certified. However, based on data collected in June 2007 from 11 out of 24 technician certification centers, it is estimated that 55,000 new MVAC technicians are certified each year. Assuming that MVAC service establishments will hire these newly certified technicians and maintain records demonstrating their certification, this ICR estimates that there will be 55,000 shop owners that must maintain such records each year.

The previous ICR estimated that there will be 5,000 establishments per year that send refrigerant off-site for handling. The current information collection maintains this estimate, as it represents approximately 3% of the total servicing establishments currently operating in the United States (approximately 171,000 establishments).² Because most service establishments recycle refrigerant on-site, the number of entities that send refrigerant off-site for recycling/reclamation is very low.

It is estimated that there are 1,370 purchases of small class I or class II refrigerant containers made by uncertified purchasers for resale only. This number is reduced from the estimate of 4,000 purchases in the previous ICR (derived from a discussion with a representative from the Automotive Refrigeration Products Institute) to account for the lower market share of small cans of CFC-12 refrigerant (which are used to service a decreasing fleet of CFC-12 MVACs) in 2008 as compared to 2002. See the change in burden section (6f) for a more detailed discussion of the change.

There are currently two independent standards testing organizations, and it is unlikely that any others will apply for approval. Additionally, no new technician certification programs are expected to apply for certification.

There are currently 24 technician certification programs that must submit program reviews every other year. It is estimated that EPA will review approximately 12 programs per year.

e) Bottom Line Burden Hours and Cost Tables

i) Respondent Tally

Total Annual Burden Hours: 6,700 hrs.

Total Annual Cost: $262,980.47

ii) The Agency Tally

Total Annual Burden Hours: 253 hrs.

Total Annual Cost: $7,953.28

iii) Variations in the Annual Bottom Line

Changes to the annual bottom line are due to a more accurate estimate in hourly wages and a shift in the time requirements and number of reporting establishments. See below for a more complete discussion of these changes.

f) Reasons for Change in Burden

The previously approved ICR estimated a total annual respondent burden of 6,882 hours and $129,631. By comparison, this ICR estimates a total annual burden of 6,700 hours and $262,980. Hence, there is a decrease of 182 hours and an increase of $133,349 since the previously approved ICR. This change can be attributed to the following factors.

• In the previous ICR, respondent hourly wages were assumed to be $50. In this ICR, to increase accuracy, wages have been estimated based on the most current Bureau of Labor Statistics (2006) national averages for managers, administrative assistants, and technicians to be $47.73, $18.83, and $17.53, respectively. These baseline wages were then multiplied by a factor of 2.1 to incorporate overhead and fringe costs into the hourly cost estimate, resulting in estimated hourly costs of $100.23, $39.54, and $36.83.

• The number of technician certification programs decreased from 25 to 24 since the previous ICR because one program went out of business.

• In the previous ICR, time allotments for EPA activities were not detailed. In this ICR, time requirements for each EPA activity related to establishments’ report submissions have been estimated. Additionally, wages for clerical and managerial EPA work has been estimated based on the 2008 GS Salary Schedule for the locality pay area of Washington-Baltimore-Northern Virginia, DC-MD-PA-WV. These baseline wages were multiplied by a factor of 1.6, the standard government benefits multiplier, to arrive at an accurate hourly cost.

• The previous ICR estimated that 14,000 new technician certifications would need to be recorded and filed by owners of approved refrigerant handling equipment each year. However, this ICR estimates the number to be 55,000. The time allotted to this activity in the last ICR was 0.25 hours per certification; this estimate is deemed too high, and has been reduced to 0.083 hours.

• The previous ICR estimated that equipment and user certification form compilation and submission would require 0.25 hours per establishment. That estimate has been reduced to 0.17 hours in this ICR.

• In 2002 it was estimated that there would be 4,000 purchases of small containers of class I and class II refrigerant for resale only by uncertified purchasers. It is estimated that at the time (in 2002), there were an estimated 32 million R-12 MVACs on the road. Today, it is estimated that there are only 11 million R-12 MVACs on the road, or roughly 65% less than there were in 2002. Therefore, to account for the decreased market for small containers of CFC-12 refrigerant, this ICR estimates that the number of purchases for resale only by uncertified purchasers of small cans will be 65% less than in 2002, or 1,370 purchases.

• Finally, the substantially identical equipment approval process is no longer applicable. This portion of Section 609(b)(2)(B) of the Act and 40 CFR 82.36(b) allowed for equip­ment that was purchased before the proposal of the regulations to be approved by EPA if it was substantially identical to equipment that had been certified by the EPA or approved independent laboratory. The substantially identical equipment regulation only relates to CFC-12 recovery and recycling equipment initially purchased before September 4, 1991; CFC-12 recovery-only equipment initially purchased before April 22, 1992; HFC-134a recovery and recycling, or recovery-only equipment initially purchased before March 6, 1996; equipment that recovers but does not recycle any single, specific refrigerant other than CFC-12 or HFC-134a that was initially purchased before March 6,1996; or equipment that recovers and recycles HFC-134a and CFC-12 refrigerant using common circuitry that was initially purchased before March 6, 1996. Because the average lifetime of such equipment is roughly 7 years, all such equipment is obsolete today. Therefore, documentation requirements related to this section have been removed from this ICR. In the previous ICR, 12 establishment burden hours and $1,200 annual costs were allocated to this activity.

g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average less than one hour per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2008-0312, which is available for online viewing at www.regulations.gov, or in person viewing at the Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air and Radiation Docket is (202) 566-1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2008-0312 and OMB Control Number 2060-0247 in any correspondence.

Appendix 1

Industry Reporting Burden

INFORMATION COLLECTION ACTIVITY	Frequency/ Number of Responses per Year	Labor Hours per Response					Costs
		General and Operations Manager $100.23	Automotive Service Technicians and Mechanics $36.83	Executive Secretaries and Administrative Assistants 39.54	Total Labor Hours	Average Total Hours	Total Labor Costs per Response	Average Cost/Year
ENTITIES THAT SERVICE MVACs
One-Time Equipment and User Certification Forms
Compile, Prepare, and Submit Certification	3,000	-		0.17	0.17	500	$ 6.59	$ 19,770.00
Records of Technician Certification
Maintain Records On-Site of Certification of Technicians	55,000			0.08	0.08	4,583	$ 3.30	$ 181,225.00
Records of Refrigerant Sent Off-Site
Record and file off-site facility address	5,000	-	0.25		0.25	1,250	$ 9.21	$ 46,037.50
Records of Refrigerant Sold
Verify certification of purchaser	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Obtain and file written statements from purchaser verifying intent to only resell small containers	1,370			0.25	0.25	343	$ 9.89	$ 13,542.45
Subtotal					0.75	6,676	$ 28.98	$ 260,574.95
INDEPENDENT STANDARDS TESTING ORGANIZATIONS
New Independent Standards Testing Organization Certification
Research SAE standards on MVAC recovery equipment	-	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Compile information for application to EPA	-	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Prepare and submit application to EPA	-	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Subtotal		N/A	N/A	N/A	N/A	N/A	N/A	N/A
TECHNICIAN CERTIFICATION PROGRAMS
New Technician Certification Program Certification
Compile documents and submit to EPA for verification of program	-	N/A	N/A	N/A	N/A	N/A	N/A	N/A
Technician Certification Program Review
Conduct periodic program reviews	12	1.50			1.50	18	$ 150.35	$ 1,804.14
Prepare and Submit summary of program review to EPA every two years	12	0.50			0.50	6	$ 50.12	$ 601.38
Subtotal		2.00		-	2.00	24	$ 200.46	$ 2,405.52
ANNUAL TOTAL	N/A					6,700	$ 229.44	$ 262,980.47

Appendix 2

Agency Reporting Burden

INFORMATION COLLECTION ACTIVITY	Frequency/ Number of Responses per Year	Labor Hours per Response				Costs
		Manager	Clerical	Total Labor Hours	Average Total Hours	Total Labor Costs per Response	Average Cost/Year
		$55.26	$31.15
One-Time Equipment and User Certification Forms
Review and file applications	3,000		0.08	0.08	250.00	$ 2.60	$ 7,787.50
New Independent Standards Testing Organization Certification
Review applications from testing organizations who request to certify equipment	-			-	-	$ -	$ -
New Technician Certification Program Certification
Review applications from new technician certification programs	-			-	-	$ -	$ -
Technician Certification Program Review
Review summaries of certification program updates every two years	12	0.25		0.25	3.00	$ 13.82	$ 165.78
Annual Total					253.00	$ 16.41	$ 7,953.28

1 Labor rates were retrieved from the “May 2006 National Industry-Specific Occupational Employment and Wage Estimates” for the Federal Executive Branch (NAICS Code 999100) provided by the U.S. Bureau of Labor Statistics at, http://www.bls.gov/oes/current/naics4_999100.htm.

2 Mobile Air Conditioning Society (MACS) (2007). Personal communication between Elvis Hoffpauir, MACS, and Charlotte Coultrap-Bagg and Pamela Mathis, ICF International. June 7, 2007. This data from (MACS) was chosen over that available from the US Census Bureau from 2002 because it is more current and it is more conservative.

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