1626ss16

Information Collection Request Supporting Statement
PART A OF THE SUPPORTING STATEMENT
NATIONAL REFRIGERANT RECYCLING AND EMISSIONS REDUCTION PROGRAM

1) Identification of the Information Collection
Title and Number of the Information Collection
This information collection request (ICR) is titled “National Refrigerant Recycling and Emissions
Reduction Program”, EPA ICR Number: 1626.16, Office of Management and Budget (OMB) Control
Number: 2060-0256.

Characterization/Abstract
Section 608 of the Clean Air Act (CAA), also known as the National Recycling and Emission Reduction
Program (the Program), directs the Environmental Protection Agency (EPA) to issue regulations
governing the use of ozone-depleting substances (ODS), including chlorofluorocarbons (CFCs) and
hydrochlorofluorocarbons (HCFCs), during the maintenance, service, repair, or disposal of airconditioning and refrigeration appliances.
The regulations require persons servicing refrigeration and air-conditioning appliances to observe
certain service practices that reduce emissions of ozone-depleting refrigerants. The regulations also
establish certification programs for technicians, recovery/recycling equipment, and off-site refrigerant
reclaimers. In addition, EPA requires that ozone-depleting refrigerants contained in appliances be
removed prior to disposal of the appliances and that all refrigeration and air-conditioning appliances be
provided with a servicing aperture that facilitates recovery of the refrigerant. The Agency requires that
substantial refrigerant leaks in appliances be repaired when they are discovered. These regulations
significantly reduce emissions of ozone-depleting refrigerants, and therefore aid U.S. and global efforts
to minimize damage to the ozone layer and the environment as a whole.
To facilitate compliance with and enforcement of Section 608 regulations, EPA requires reporting and
recordkeeping from; technician certification programs; equipment testing organizations; refrigerant
wholesalers; refrigerant reclaimers; refrigeration and air-conditioning appliance owners; technicians;
and other establishments that perform refrigerant removal, service, or disposal. OMB previously
approved this collection under ICR Number 1626.12 through December 31, 2017. Specific reporting and
recordkeeping requirements were initially published May 14, 1993 (58 FR 28660) and codified at 40 CFR
part 82, subpart F (§82.150 et seq.). In September 2016, EPA finalized a rule that updated the

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requirements under the Program and extended them to cover appliances containing
hydrofluorocarbons (HFCs) and other non-exempt substitute refrigerants (81 FR 82272) (hereinafter
referred to as the 2016 Rule). That rule contained new recordkeeping and reporting requirements and
removed outdated recordkeeping and reporting requirements. EPA submitted that revised collection to
OMB under the ICR Number 1626.15 and OMB accepted it for review on December 30, 2016.
EPA is proposing to revise the leak repair provisions so they apply only to equipment using refrigerant
containing a class I or class II substance. This proposal would remove reporting and recordkeeping
requirements for owners and operators of appliances containing 50 or more pounds of a non-exempt
substitute refrigerant (e.g., HFCs) and technicians servicing such appliances. This proposal does not
affect the recordkeeping and reporting requirements finalized in the 2016 Rule that apply to appliances
containing 50 or more pounds of an ODS refrigerant 1. There are no new records that would be
maintained or reports that would be submitted under this proposal. EPA is also taking comment on
whether, in connection with the proposed changes to the legal interpretation in the 2016 Rule, the
extension of the Program to non-exempt substitute refrigerants should be rescinded in full. If EPA were
to finalize a rescission of the full set of subpart F requirements for substitutes, the burden of this ICR
would decrease.
EPA has estimated that there are 573,731 annual respondents consisting of representatives from the airconditioning and refrigeration community. The annual cost for respondents for the collection and
maintenance of records, as well as reports to EPA, is estimated to total $24,625,892.

2) Need for and Use of the Collection
Need/Authority for the Collection
This proposed information collection is authorized under Section 608(a) of the Clean Air Act. This section
directs the Administrator to “promulgate regulations establishing standards and requirements regarding
the use and disposal” of ozone-depleting substances and to implement Section 608(c) which contains a
statutory prohibition against venting of ODS and substitute refrigerants. EPA requires reporting and
recordkeeping to facilitate compliance with and enforcement of the Section 608 requirements. In
addition, EPA’s authority is supplemented by Section 114, which authorizes the EPA Administrator to

For the purposes of those document, “ODS refrigerant” means any substance, including blends and mixtures,
consisting in part or whole of a class I or class II ozone-depleting substance that is used for heat transfer purposes
and provides a cooling effect.

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require recordkeeping and reporting in carrying out any provision of the CAA.

Practical Utility/Users of the Data
The purpose of the collection request is to facilitate compliance with and enforcement of Section 608 of
the CAA including the prohibition on venting ODS refrigerants and non-exempt substitute refrigerants
and to reduce emissions of class I and class II ozone-depleting refrigerants to the lowest achievable level
during the maintenance, service, repair, and disposal of appliances. EPA has used and will continue to
use these records and reports to ensure that refrigerant releases are minimized during the refrigerant
recovery, recycling, and reclamation processes.
Some recordkeeping requirements are intended to facilitate information sharing between regulated
entities to ensure compliance with Section 608 requirements. Owners/operators of appliances
containing ODS use the information provided by service technicians to ensure their systems are not
leaking in violation of the regulations. Refrigerant wholesalers use the data provided by service
technicians to ensure they are complying with the refrigerant sales restriction.
Most of the reporting requested from respondents under this ICR are to seek a benefit such as an
extension to repairing or retrofitting an appliance leaking in violation of Section 608 requirements or to
voluntarily become an organization to test and certify technicians or to test and certify recovery and
recycling equipment.

3) Non-duplication, Consultations, and Other Collection
Criteria
Non-duplication
The specific information requested is not currently collected by any other EPA office or any other
government agency.

Public Notice Required Prior to ICR Submission to OMB
EPA is proposing changes to the existing recordkeeping and reporting requirements covered by this ICR.
EPA is requesting comment on this ICR in that proposed rulemaking.

Consultations
The burden calculations for this renewal were developed based on information from EPA’s consultations

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for the previous ICR.

Effects of Less Frequent Collection
EPA is proposing to remove recordkeeping and reporting requirements related to the repair of leaking
appliances containing 50 or more pounds of non-exempt substitute refrigerant. The existing information
collection requirements are either one-time, annual, or occasional submissions.
The one-time submissions (e.g., applications for approval of technician certification organizations) and
annual submissions (e.g., reclaimer annual reports) are required for EPA to track changes in industry and
for long-term management of the Program. Occasional submissions, such as requests for extensions to
repair, retrofit, or retirement timelines for ODS appliances, allow entities flexibility in meeting regulatory
requirements. .

General Guidelines
The reporting and recordkeeping requirements do not violate the regulations established by OMB at 5
CFR part 1320.5(d)(2).

Confidentiality
EPA informs respondents that they may assert claims of business confidentiality for any of the
information they submit. Information claimed confidential will be treated in accordance with the
procedures for handling information claimed as confidential under 40 CFR Part 2, Subpart B, and will be
disclosed only if EPA determines that the information is not entitled to confidential treatment. If no
claim of confidentiality is asserted when the information is received by EPA, it may be made available to
the public without further notice to the respondents (40 CFR 2.203). The handling and confidentiality of
the reporting requirements for assuring computer data security, preventing disclosure, proper storage,
and proper disposal follow EPA's confidentiality regulations (40 CFR 2.201 et seq.).

Sensitive Questions
None of the reporting or recordkeeping requirements contain sensitive questions.

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4) Respondents and Information Requested
Respondents / North American Industry Classification System
(NAICS) Codes
Table 1 lists the NAICS codes potentially affected by the information requirements covered under this
ICR. These categories generally include owners/operators of industrial process refrigeration, commercial
refrigeration, and comfort cooling appliances; plumbing, heating, and air-conditioning contractors;
refrigerant wholesalers; manufacturers and distributors of small cans of automotive refrigerant;
refrigerant reclaimers; disposers and recyclers of appliances; and testing and certifying organizations.
These listings are not all-inclusive but are consistent with the types of organizations potentially
impacted by this ICR.
Table 1: NAICS Codes of Potentially Affected Respondents
Industry Category

NAICS Code

NAICS Code Definition

Agriculture and Crop Support Services

115

Support Activities for Agriculture and Forestry

Arts, Entertainment, and Recreation

71

Arts, Entertainment, and Recreation

Beverage and Ice Manufacturing

312

Beverage Manufacturing

423

Merchant Wholesalers - Durable Goods

441

Motor Vehicle and Parts Dealers

Educational Services

611

Educational Services

Food Manufacturing

311

Food Manufacturing

452

General Merchandise Stores

Durable Goods Wholesalers and Dealers

General Merchandise Stores

Grocery and Specialty Food Stores

All Other Miscellaneous Store Retailers (except
Tobacco Stores)

453998
4451

Grocery Stores

4452

Specialty Food Stores

72231

Food Service Contractors

Hospitals

622

Hospitals

Non-durable Goods Wholesalers and
Dealers

424

Merchant Wholesalers – Non-durable Goods

322

Paper Manufacturing

323

Printing and Related Support Activities

324

Petroleum Manufacturing

Non-food Manufacturing

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Industry Category

NAICS Code
325

Chemical Manufacturing

326

Plastics and Rubber Manufacturing

332

Metals Manufacturing

333

Machinery Manufacturing

334

Computer and Electronic Product Manufacturing

336

Transportation Equipment Manufacturing

3254

Pharmaceutical Manufacturing

3391

Medical Equipment and Supplies Manufacturing

339999

Office Buildings

NAICS Code Definition

Miscellaneous Manufacturing

92

Public Administration

511

Publishing Industries (except Internet)

512

Motion Picture and Video Industries

515

Broadcasting

517

Telecommunications

518

Data Processing, Hosting, and Related Services

519

Libraries and Archives

522

Credit Intermediation and Related Activities

524

Insurance Carriers

531

Real Estate

541

Professional, Scientific, and Technical Services

551

Management of Companies and Enterprises

561

Administrative and Support Services

712

Museums, Historical Sites, and Similar Institutions

721

Accommodation

813

Religious, Grantmaking, Civic, Professional, and
Similar Organizations

48

Transportation and Warehousing

Other Warehousing, Storage, and
Transportation

4931

Warehousing and Storage

Refrigerated Warehousing and Storage

49312

Refrigerated Warehousing and Storage

Research and Development

5417

Research and Development

Utilities

211

Oil and Gas Extraction

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Industry Category

NAICS Code
221

Warehouse Clubs and Supercenters

Reclaimers

Refrigerant Wholesalers

Service Technicians

Disposal Establishments

Service Establishments

Small Can Manufacturers
Certifying Organizations

NAICS Code Definition
Utilities

452910

Warehouse Clubs and Supercenters

325120

Industrial Gas Manufacturing

423930

Recyclable Material Merchant Wholesalers

424690

Other Chemical and Allied Products Merchant
Wholesalers

562212

Solid Waste Landfill

562920

Materials Recovery Facilities

325120

Industrial Gas Manufacturing
Hardware and Plumbing and Heating Equipment
and Supplies Merchant Wholesalers

4237
424690

Other Chemical and Allied Products Merchant
Wholesalers

238220

Plumbing, Heating, and Air-conditioning Contractors

423990

Other Miscellaneous Durable Goods Merchant
Wholesalers

562212

Solid Waste Landfill

562920

Materials Recovery Facilities

811111

General Automotive Repair

811310

Commercial Industrial Machinery and Equipment
(not Automotive and Electronic) Repair and
Maintenance

811412

Appliance Repair and Maintenance

325120

Industrial Gas Manufacturing

441310

Automotive Parts and Accessories Stores

541380

Environmental Test Laboratories and Services

Information Requested
All records pursuant to this ICR must be available onsite at the respondents' place of business for a
minimum of three years. EPA encourages entities to submit reports electronically to
[email protected]. Entities may also submit reports by mail to: Section 608 Program Manager;
Stratospheric Protection Division; Mail Code: 6205T; U.S. Environmental Protection Agency; 1200
Pennsylvania Avenue, NW; Washington, DC 20460.

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1. Refrigerant Recovery/Recycling Equipment Testing Organizations
The data items required by organizations that test and certify refrigerant recovery/recycling equipment
are specified in 40 CFR 82.160(a), (b), and (e).
i) Data Items


Application for approval by EPA to certify refrigerant recovery/recycling equipment (as applicable).
Information includes:

 List refrigerant recovery/recycling equipment present at the organization that will be used for
testing;

 Verification of expertise in refrigerant recovery/recycling equipment testing and the technical
experience of the organization's personnel;

 Verification of the organization’s knowledge of the standards and recordkeeping and reporting
requirements in 40 CFR Part 82, Subpart F; and

 Description of the organization’s program for verifying the performance of certified recycling
and recovery equipment manufactured over the long term, specifying whether retests of
equipment or inspections of equipment at manufacturing facilities will be used;

 Verification that the organization has no conflict of interest and receives no direct or indirect
financial benefit from the outcome of certification testing; and

 Agreement to allow EPA access to records and personnel to verify the information contained in
the application.





Records of refrigerant recovery/recycling equipment testing and performance.
List of certified refrigerant recovery/recycling equipment that includes the name of the
manufacturer and the name or serial number of the model line.
Notice of when a model of refrigerant recovery/recycling equipment fails a three-year recertification
test.

ii) Respondent Activities






Prepare a one-time application to become an approved refrigerant recovery/recycling equipment
testing organization.
Retain records of recovery/recycling equipment testing and performance and refrigerant
recovery/recycling equipment.
Notify EPA within 30 days of retesting or inspection if equipment previously certified fails the
periodic re-test required by the regulation.

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

Publish online a list of all certified equipment and update the list annually.

2. Refrigerant Reclaimers
The data items required by reclaimers are specified in 40 CFR 82.164(d).
i) Data Items


Application for reclaimer certification by EPA, including a certification that the reclaimer will:

 Reclaim refrigerant to all the specifications in Appendix A of Subpart F that are applicable to that
refrigerant;

 Verify that each batch of refrigerant reclaimed meets these specifications using the analytical
methodology prescribed in Appendix A;

 Release no more than 1.5 percent of the refrigerant during the reclamation process;
 Dispose of wastes from the reclamation process in accordance with all applicable laws and
regulations; and








Maintain records and submit reports.

Records of the analysis conducted to verify that each batch of reclaimed refrigerant meets the
necessary specifications.
Records on the quantity of ODS and substitute refrigerant (by ASHRAE type) sent for reclamation,
the amount reclaimed, waste products from the reclamation process, and names and addresses of
persons sending refrigerant for reclamation.
Annual reports noting the total annual quantity of material (the combined mass of refrigerant and
contaminants) by refrigerant type sent to them for reclamation, the mass of refrigerant reclaimed
by refrigerant type, and the mass of waste products produced.

ii) Respondent Activities





Prepare a one-time application to become a certified refrigerant reclaimer.
Maintain records of analyses conducted to verify that reclaimed refrigerant meets the necessary
specifications.
Maintain records of the names and addresses of persons sending material for reclamation and the
quantity of the material (the combined mass of refrigerant and contaminants) by refrigerant type
sent to them for reclamation.

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



Prepare and submit to EPA annual reports detailing the quantity of each refrigerant sent for
reclamation (the combined mass of refrigerant and contaminants), the mass of each refrigerant
reclaimed, and the mass of waste products.
Notify EPA within 30 days of a change in business management, location, or contact information.

3. Refrigerant Wholesalers
The data items required by refrigerant wholesalers are specified in 40 CFR 82.154(c)(3).
i) Data Item


Refrigerant sales records that indicate the name of the purchaser, the date of sale, and the quantity
purchased as well as records indicating that the purchaser is a certified technician (as applicable).

ii) Respondent Activities


Retain invoices from refrigerant sales.

4. Technician Certification Programs
The data items required by technician certification programs are specified in 40 CFR 82.161(b) and 40
CFR Part 82, Subpart F, Appendix D.
i) Data Items


Prepare a one-time application to become an approved technician certification program. The
application will verify:

 Ability to produce multiple versions of examinations for each test site;
 Sufficient internal capacity to process the scoring and the accompanying documentation; and
 Ability to ensure the confidentiality and security of test questions and answers.




Records of the names and addresses of all individuals taking the tests, the scores of all certification
tests administered, and the dates and locations of all testing administered. These records must be
retained indefinitely.
List of technicians certified through the program, including:

 First name, middle initial, and last name of the technician;
 Technician’s city of residence when taking the test;
 Type(s) of certification received; and

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 Date each certification was completed.


Biannual (2x/year) reports on pass/fail rates.

ii) Respondent Activities


Prepare and submit application to become a technician certification organization.



Maintain records of testing events, scores of certification tests, and the dates and locations of tests.



Maintain and publish online lists of technicians certified through programs after January 1, 2017. 2



Prepare and submit reports to EPA every six months on the pass/fail rate and testing schedules.



Organizations that stop certifying technicians must transfer their records to another certifying
program or EPA. Organizations that receive those records must inform EPA within 30 days.

5. Disposal Establishments
The data items required by disposal establishments are specified in 40 CFR 82.155(c).
i) Data Item


Copies of signed statements attesting that refrigerant has been recovered prior to the disposal of
each appliance or copies of a contract from a supplier of multiple appliances that refrigerant will be
recovered prior to delivery at the disposal establishment.

ii) Respondent Activities


Retain copies of signed statements or contracts for each piece of disposed appliance with the name
and address of the person who recovered the refrigerant and the date the refrigerant was
recovered.

6. Technicians
The data items required by technicians are specified in various provisions of subpart F as listed. EPA is
proposing to rescind the recordkeeping and reporting requirements for appliances with a charge size of
50 or more pounds of non-exempt substitute refrigerant (e.g., hydrofluorocarbons). The revised
reporting and recordkeeping provisions at 40 CFR 82.157(l) and (m) would continue to apply to
appliances containing ODS refrigerants.

2

Technicians may opt out of this requirement.

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i) Data Items


Proof of technician certification (40 CFR 82.161(a)(4)).



Records of leak inspections and verification tests (40 CFR 82.157(l)).





Service invoices to owners/operators with information on the identity and location of the appliance,
the date and type of service performed, and the quantity and type of refrigerant added. (40 CFR
82.157(l)).
Records for the disposal of appliances with charges between 5 and 50 pounds which include:

 Company name, location of equipment, date of recovery, and types of refrigerant recovered for
each appliance;

 Quantity of refrigerant recovered from such appliances each calendar month; and
 Quantity and types of refrigerant ultimately transferred for reclamation or destruction.
ii) Respondent Activities


Successfully complete a certification test.



Maintain a copy of certification at their place of business.







Prepare and provide service invoices to owners/operators with each servicing event of an appliance
containing 50 or more pounds of ODS refrigerant .
Prepare and provide records of leak inspections and verification tests on appliances containing 50 or
more pounds of ODS refrigerant (only for appliances exceeding the threshold leak rate).
Prepare and maintain the appropriate records when disposing of appliances with charges between 5
and 50 pounds.

7. Owners/Operators of Appliances with Charge Sizes of 50 or More Pounds
EPA is proposing to rescind the recordkeeping and reporting requirements for owners and operators of
appliances with a charge size of 50 or more pounds of non-exempt substitute refrigerant (e.g.,
hydrofluorocarbons). The revised reporting and recordkeeping provisions at 40 CFR 82.157(l) and (m)
(as presented below) would continue to apply to appliances containing ODS refrigerants.
i) Data Items


Records related to determining the full charge of an appliance, including: the identification of the
owner or operator of the appliance; the address where the appliance is located; the full charge of

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the appliance and the method for how the full charge was determined; if using an established range
for determining full charge, records must include the range for the full charge of the appliance, its
midpoint, and how the range was determined; and any revisions of the full charge, how they were
determined, and the dates such revisions occurred.






Service invoices with information on the identity and location of the appliance, the date and type of
service performed, the name of the person performing the service, the quantity and type of
refrigerant added and the full charge of the system.
Records indicating the leak rate of the appliance, generated every time refrigerant is added to the
appliance.
For appliances that have been found to be above the threshold leak rate, records of:

 Quarterly or annual leak inspections (or installation of an automatic leak detection system,
annual inspections and recalibrations of the system, and a record of each date the system
detected a leak and the location of the leak); and

 Verification tests on repairs.


Requests for extensions to the 30-day repair timeline or the one-year retrofit/retire timeline (as
applicable). Submissions include the following information:

 Date of notification to EPA;
 Identification of the appliance;
 Name of the owner or operator;
 Leak rate;
 Method used to determine the leak rate and full charge;
 Date a leak rate above the applicable allowable rate was discovered;
 Location of leaks(s) to the extent determined to date;
 Any repair work that has been finished thus far, including the date that work was finished;
 Plan to finish the retrofit or retirement of the system (as applicable);
 Reasons why more than one year is necessary to retrofit or retire the system (as applicable); and
 Estimate of when retrofit or retirement work will be finished (as applicable).


Plans to retire/replace or retrofit appliances (as applicable). Plans must include:

 Identification and location of the appliance;
 Type and full charge of the refrigerant used in the appliance;

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 Type and full charge of the refrigerant to which the appliance will be converted, if retrofitted;
 Itemized procedure for converting the appliance to a different refrigerant, including changes
required for compatibility with the new substitute, if retrofitted;

 Plan for the disposition of recovered refrigerant;
 Plan for the disposition of the appliance, if retired; and
 One-year schedule for completion of the appliance retrofit or retirement.





Requests to cease a retrofit/retirement if all leaks are repaired.
Records on mothballed appliances, including the date when a system that is leaking in excess of the
leak rate is mothballed and the date when refrigerant is later added back into the system.
Records on purged or destroyed refrigerant, including information on flow rate, quantity or
concentration of the refrigerant in the vent stream; and periods of purge flow.

ii) Respondent Activities


Retain service invoices containing the information described above.



Retain documentation from leak inspections or on leak detection systems.



Retain documentation on verification tests for repairs when the leak rate is exceeded.



Notify EPA when seeking an extension of time to complete repairs.








Notify EPA when an appliance loses more than 125 percent of its total charge within a calendar year,
including a description of repairs to the appliance.
Prepare and maintain a plan to retire/replace or retrofit leaking appliances (as applicable).
Prepare and submit to EPA requests for extensions to the 30-day repair timeline or the one-year
retrofit/retire timeline (as applicable).
Prepare and maintain a copy of requests for extensions to the 30-day repair timeline or the one-year
retrofit/retire timeline.



Prepare and submit requests to cease a retrofit/retirement if all leaks are repaired.



Prepare and maintain records on mothballed appliances.





Notify EPA when excluding purged refrigerants that are destroyed from annual leak rate
calculations.
Prepare and maintain records on purged or destroyed refrigerant.

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8. Small Can Manufacturers
The data items for small can manufacturers are specified in 40 CFR 82.154(c)(2) and in 40 CFR Part 82,
Subpart F, Appendix E.
i) Data Item


Log forms of results from self-sealing valve testing.

ii) Respondent Activities


Prepare and retain records of results from self-sealing valve tests.

5) Information Collected - Agency Activities, Collection
Methodology, and Information Management
Agency Activities
EPA activities associated with the review of the reports consist of reviewing the following:


Applications to become an independent refrigerant recovery/recycling equipment certifying
organization.



Applications to become a certified refrigerant reclaimer.



Annual reports from reclaimers on their activities.



Certification notices by refrigerant reclaimers that change ownership or enter the market.



Applications to become a technician certification program.



Records from technician certifying programs exiting the market.



Reports submitted by approved technician certification programs.







Extension requests from owners/operators of commercial refrigeration, comfort cooling, and
industrial process refrigeration appliances containing 50 or more pounds of an ODS refrigerant.
Reports from owners/operators of appliances containing 50 or more pounds of an ODS refrigerant
that leak 125% or more of their full charge in a calendar year.
Requests from owners/operators to cease retrofit/retirement plans of appliances containing 50 or
more pounds of an ODS refrigerant.

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Collection Methodology and Management
Reclaimers are required to report annually on activities using EPA Form 5900-404. Small can
manufacturers can use EPA’s sample form 5900-405 to facilitate recordkeeping. Entities are encouraged
to submit the required information in an electronic format to [email protected]. The information
submitted by each member of the regulated community will be stored at EPA headquarters for review
and reference.

Small Entity Flexibility
Several of the recordkeeping and reporting requirements of the rule are intended to permit entities
greater flexibility in complying with the regulation.
Technicians who work on small appliances may take a take-home test rather than a proctored test. This
provision was implemented in recognition that (1) entities servicing small appliances are often small
businesses, (2) many of these entities only rarely perform service on the refrigerant circuit of small
appliances, and (3) the quantity of refrigerant in small appliances is less than five pounds. For similar
reasons, individuals who recover refrigerant from small appliances and motor vehicle air conditioners
when they are disposed of are not required to be certified and are not required to use certified
refrigerant recovery/recycling equipment.
Final persons in the disposal process for small appliances and MVACs may elect not to recover
refrigerant themselves so long as they obtain a signed statement from persons upstream in the disposal
process that the refrigerant has been removed already. The signed statement permits the final disposer
to delegate responsibility for refrigerant removal.
Owners of appliances that leak above a certain level may elect to retrofit or replace their appliances
rather than repair them so long as they develop a retrofit or retirement plan. Owners/operators may
take longer than 30 days to complete repairs or longer than one year to retrofit or replace appliances so
long as they submit documentation to EPA explaining their need for additional time.

Collection Schedule
EPA requires maintenance of records for a minimum of three years. The following information is
required on a specific collection schedule:


Approved equipment testing organizations must notify EPA if a previously certified model line fails
to meet EPA requirements within 30 days of the failed retest or inspection.

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







On a transactional basis, reclaimers must maintain records of the quantity of each refrigerant sent
to them for reclamation (the combined mass of refrigerant and contaminants), the mass of each
refrigerant reclaimed, and the mass of waste products. Reclaimers must report the aggregated
information by refrigerant type to EPA within 30 days of the end of the calendar year.
Programs certifying technicians, excluding federally-run programs, must publish a list of technicians
they have certified after January 1, 2017. Technicians can opt out of having their names published.
If a refrigerant reclaimer changes ownership, the new owner must certify with EPA within 30 days of
the change of ownership.
Owners/operators of appliances containing 50 or more pounds of an ODS refrigerant must prepare a
retrofit or retirement plan within 30 days of:

 Discovering a leak greater than the threshold leak rate; or
 An appliance continues to leak, even after making good faith efforts to repair leaks.






Owners/operators of appliances containing 50 or more pounds of an ODS refrigerant choosing to
request an extension to the retrofit/retirement timeline must do so within seven months of
discovering that the leak rate exceeded the applicable leak rate.
Owners/operators of appliances containing 50 or more pounds of an ODS refrigerant who exclude
purged refrigerants that are destroyed from annual leak rate calculations must submit information
to EPA within 60 days of the first time the exclusion is used by the facility where the appliance is
located.
Owners/operators of appliances containing 50 or more pounds of an ODS refrigerant that leak more
than 125 percent if their full charge in one calendar year must submit a report to EPA detailing
repair efforts. Reports must be submitted by March 1 the year following the exceedance.

6) Estimating the Burden and Cost of the Collection
This section contains tables that provide the numerical basis for the annual burden and cost of this ICR
by detailing the following:


EPA’s rationale in preparing respondent burden and cost tables.



Estimated respondent and Agency burden (hours to complete required activities).



Estimated respondent and Agency labor costs and capital costs associated with those activities.



Universe of estimates.



Calculated burden and cost totals.

The collection activities in Sections 4 and 5 are referenced to develop these estimates. The activities for

17

which EPA estimated burden and cost correspond directly with the activities listed in Sections 4 and 5.

Estimating Respondent Burden
Estimates of respondent burden and cost for the Program are presented below. All hour estimates are
based on EPA's experience implementing this Program and on EPA’s best professional judgment. All
burden hours and costs presented here are annual.

Estimating Respondent Costs
EPA has estimated the total cost per respondent required to complete each activity. The total cost for
each respondent activity is comprised of the following:



Labor Cost (for legal, managerial, technical, clerical, and other employees).
Operating and Maintenance (O&M) Cost (for labor and equipment needed over time as well as for
the purchase of services).

None of the reporting or recordkeeping requirements is expected to have associated capital costs.

i. Estimating Labor Costs
The labor costs reflect the total cost to employ an individual and include estimates of salaries and
overhead costs. EPA estimates the average annual respondent hourly cost (labor plus overhead) for all
affected entities. In deriving these costs, EPA identified applicable standard occupational classification
for each respondent and used the 2017 median hourly rate from the Bureau of Labor Statistics. 3 EPA
then increased these numbers by 110% for overhead. Previously, EPA used only the rate for Heating, AirConditioning, and Refrigeration Mechanics and Installers for all recordkeeping and reporting activities
associated with this ICR. EPA has revised this ICR to more accurately reflect the various types of entities
conducting the activities and their associated costs. The resulting costs outlined in Table 2 are the
average hourly administrative cost of labor plus overhead for private firms.

Bureau of Labor Statistics, U.S. Department of Labor. May 2015 National Occupational Employment and Wage
Estimates United States. Available at http://www.bls.gov/oes/current/oes_nat.htm (visited July 31, 2018).

3

18

Table 2: Labor Costs for Affect Entities
Respondent
Refrigerant Recovery/Recycling
Equipment Testing
Organization

Bureau of Labor Statistics Information
Standard
Median
Occupational
Occupational Title
Wage
Classification
17-2081

Refrigerant Reclaimers

51-8091

Refrigerant Wholesalers

41-4012

Technician Certification
Programs

25-9031

Disposal Establishments
Technicians

49-9021

Owners/Operators

17-2111

Small Can Manufacturers

43-5111

Environmental Engineers
Chemical Plant and
Systems Operators
Sales Representatives,
Wholesale
Instructional
Coordinators
Heating, Air-Conditioning,
and Refrigeration
Mechanics and Installers
Health and Safety
Engineers
Weighers, Measurers,
Checkers, and Samplers

Total

$41.73

$87.63

$29.89

$62.77

$27.39

$57.52

$30.65

$64.37

$22.64

$47.54
$47.54

$42.55

$89.36

$14.51

$30.47

ii. Estimating Capital Costs and Operations and Maintenance Costs
According to the 1995 PRA, burden is 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.” Any activity
that is not usual and customary is considered a burden. As part of the submission to OMB, EPA has
estimated all costs for respondents to comply with required Agency activities that are not incurred by
persons in their normal course of activities. This estimate includes the time needed to review
instructions, maintain records, complete paperwork, gather information, and report information.
There are two types of non-labor costs – capital/start-up costs and O&M costs. One-time capital/startup costs include any produced physical good needed to provide the necessary information. Start-up
capital must be purchased for the specific purpose of satisfying EPA’s reporting or recordkeeping
requirements. Capital goods include computers, machinery, or equipment. Start-up capital costs are
incurred at the beginning of an information collection period and are incurred only once. In addition to
the acquisition of start-up capital, one-time activities associated with the production of capital have also
been evaluated. EPA has considered capital/start-up costs and O&M costs in determining that there are
no non-labor related costs associated with this ICR. O&M costs are those costs associated with a
paperwork requirement incurred continuously over the life of the ICR. They are defined by the PRA as
“the recurring dollar amount of cost associated with O&M or purchasing services.”

19

The following tables summarize the annual respondent burden and cost by respondent type and
reporting and recordkeeping requirement.

1. Refrigerant Recovery/Recycling Equipment Testing Organization
Annual Respondent Burden
Collection Activities

Burden Hours

Labor Costs/Entity

Equipment testing organization applying for approval

8.0

$0

Maintain records of refrigerant recovery/recycling equipment
tested and its performance

0.5

$43.82

Providing notice when equipment fails recertification

0.5

$43.82

Publish list of all certified equipment that includes the name of
the manufacturer and the name or serial number of the model
line online 4

0.5

$43.82

Organizations that intend to test and certify refrigerant recovery/recycling equipment need to apply for
approval from EPA. EPA estimates that an organization would need 8 hours to complete the application
process. The number of refrigerant recovery/recycling equipment testing organizations has remained
unchanged since 1993, however, and thus no burden is included in this ICR analysis.
Each of the two refrigerant recovery/recycling equipment testing and certifying organizations approved
by EPA are estimated to spend 30 minutes each year on: maintaining records of refrigerant
recovery/recycling equipment tested and its performance; providing notice when equipment fails
recertification; and publishing a list of all certified equipment online.

2.

Refrigerant Reclaimers
Annual Respondent Burden

Collection Activities

Burden Hours

Certification by refrigerant reclaimers that change ownership or

5.0

Labor
Costs/Entity
$313.85

In the previous ICR, the burden for preparing the annual activity report was 8.0 hours for submitting the data to
EPA. The burden was reduced because the reporting requirement has been replaced with a requirement to post
the information online, which is already standard practice for testing organizations.

4

20

enter the market
Maintain records of the analyses conducted to verify that
reclaimed refrigerant meets the necessary specifications
Reclaimer recordkeeping
Annual activity report

4.3

$272.00

11.7

$735.12

9.4

$588.09

Based on experience from previous years, EPA estimates that four entities will submit one-time
applications to become certified refrigerant reclaimers. Each submission is estimated to take 5 hours.
Reclaimers must maintain records of analyses conducted to verify that reclaimed refrigerant meets the
necessary specifications. EPA estimates that each reclaimer will spend approximately 1 minute per day
maintaining records, for a total of 4.3 hours annually.
Reclaimers must also maintain records of refrigerant sales transactions. EPA estimates that each
reclaimer will spend approximately 14 minutes per recordkeeping event with a total of 50 events per
year. Therefore, each reclaimer will spend 11.7 hours maintaining records annually.
Reclaimers must maintain records and report annually on the quantity of material sent to them for
reclamation, the amount reclaimed, waste products from the reclamation process, and customer and
sales records. Compiling this information, preparing it for EPA, and submitting it to EPA is estimated to
take approximately 9.4 hours per year for ODS, HFC, and other non-exempt substitute refrigerants.

3.

Refrigerant Wholesalers
Annual Respondent Burden
Collection Activities

Burden Hours

Recordkeeping for refrigerant sales, including
maintenance of technician certification cards from
purchasers employing at least one certified technician

8.7

Labor Costs/Entity
$498.50

EPA estimates that each refrigerant wholesaler must spend approximately 2 minutes each day
maintaining invoices that indicate the name of the purchaser, the date of sale, the quantity, and
verification that the purchaser is a certified technician (as applicable). This results in an annual burden of
8.7 hours.

21

4.

Technician Certification Programs
Annual Respondent Burden
Collection Activities

Burden Hours

Labor Costs/Entity

Technician certification programs applying for approval

5.0

$321.83

Recordkeeping by existing certification programs

5.0

$321.83

0.17

$10.73

Biannual reporting by existing certification programs

2.0

$128.73

Transfer of records when no longer operational

8.0

$514.92

Maintain list of technicians certified

EPA estimates that it will take 5 hours for new organizations to compile the necessary information to
apply for the certification program approval. EPA also estimates that existing technician certification
program spend 5 hours annually maintaining records on technicians certified through their programs.
Technician certification programs are required to publish online a list documenting who they have
certified and what type of certification each individual received. Each of the testing organizations are
also required to submit biannual reports summarizing the numbers of previously certified individuals,
individuals taking the tests, scores of all certification tests, and the dates and locations of all tests
administered. EPA estimates that technician certification programs spend 5 minutes publishing online
lists and 1 hour completing each report. EPA expects programs to publish lists and complete reports
twice a year. Organizations that stop certifying technicians must transfer their records to another
certifying program or EPA. Organizations that receive those records must inform EPA within 30 days.
EPA assumes that 5 programs a year will spend 8 hours transferring records and reporting to EPA.

5.

Disposal Establishments
Annual Respondent Burden
Collection Activities

Maintenance of copies of signed statements or contracts of
previous refrigerant recovery by disposal establishments

Burden Hours

Labor Costs/Entity

15.2

$721.08

Disposal establishments spend an estimated 3.5 minutes per business day (260 events per year)
collecting and maintaining copies of signed statements verifying that refrigerant has been removed from
appliances before they are accepted for disposal.

22

6.

Technicians
Annual Respondent Burden - Certification
Collection Activities

Burden Hours

Labor Costs/Entity

Maintain certification cards

0.017

$0.79

Acquire certification cards

0.017

$0.79

Technicians are expected to spend 1 minute each year maintaining their certification cards. EPA
estimates that approximately 10 percent of the estimated 300,000 technician labor force turns over
each year, necessitating certification. EPA estimates that each new technician will spend 1 minute
acquiring a certification card.
Annual Respondent Burden - Preparing and Maintaining Records
Collection Activities

Burden Hours

Labor Costs/Entity

Provide invoices for serviced appliances with charge sizes 50 to
500 lbs.

0.08

$3.61

Provide invoices for serviced appliances with charge sizes >500
lbs.

0.07

$3.12

Provide leak inspection and verification test records

0.01

$0.58

0.2

$9.51

Maintain disposal records for appliances with charge sizes of 5
- 50 lbs.

Technicians servicing appliances with charge sizes of 50 or more pounds of an ODS refrigerant are
required to provide records of the following: the identity and location of the appliance, the date and
type of service performed, and the quantity and type of refrigerant added. EPA estimates that each
technician will spend two minutes preparing and one minute maintaining each record. The annual
burden hours per respondent was determined by dividing the total invoice burden for all serviced
appliances across the universe of technicians. EPA estimates that appliances containing 50 to 500
pounds of refrigerant will be serviced annually, requiring 1 invoice, and that appliances with 500 or
more pounds will be serviced quarterly, requiring 4 invoices. EPA’s proposal would rescind the
applicability of this recordkeeping requirement for appliances containing HFCs and other non-exempt
substitute refrigerant.
Technicians conducting leak inspections or verification tests on appliances containing 50 to 500 pounds
of ODS refrigerant that had been found leaking above the threshold rate must prepare and provide
records to the owner/operator of that appliance. EPA estimates that each technician will spend 1

23

minute providing each record.
Technicians disposing of appliances with charge sizes between 5 and 50 pounds are also required to
maintain records on: the quantity and types of refrigerant recovered in each calendar month; the
quantity and type of refrigerant transferred for reclamation or destruction; the company name; and
date. EPA estimates that technicians spend 1 minute per month to maintain these records.

7.

Owners/Operators
Annual Respondent Burden - Reporting
Collection Activities

Burden Hours

Labor Costs/Entity

Prepare and submit requests for extension to 30-day repair
timeline

0.5

$44.68

Prepare and submit requests for extension to 1-year
retrofit/retire timeline

0.5

$44.68

Prepare and submit requests to cease a retrofit/retirement if all
leaks are repaired

0.5

$44.68

Prepare and submit report on efforts to repair chronically
leaking appliances

1.0

$89.36

Owners/operators of IPR, comfort cooling, or commercial refrigeration appliances that contain 50 lbs. or
more of an ODS refrigerant may apply to EPA for an extension to the leak repair and appliance
retrofit/retire timeframe. EPA estimates that each request will take 30 minutes to complete.
Owners/operators may prepare and submit requests to cease a retrofit/retirement if they are able to
repair all leaks. EPA estimates an average burden of 30 minutes per request.
Owners/operators of IPR, comfort cooling, or commercial refrigeration appliances that contain 50 lbs. or
more of an ODS refrigerant that leak 125 percent or more of the full refrigerant charge in a calendar
year are required to submit a report to EPA about efforts to identify leaks and repair the appliance. EPA
estimates an average burden of 1 hour per owner/operator with an affected piece of equipment.
Annual Respondent Burden - Recordkeeping
Collection Activities
Maintain records of the full charge of an appliance
Maintain records of the leak rate calculation

24

Burden Hours

Labor Costs/Entity

0.05

$4.47

0.104

$9.31

Maintain purchase and service records

0.156

$7.43

Maintain leak inspection records

0.022

$1.97

Maintain reports on the results of verification tests for repairs
to systems that exceed the leak rate threshold

0.025

$2.23

Develop/maintain plan to retire/replace or retrofit appliances

8.0

$714.84

Maintain records on mothballed equipment

0.025

$2.23

Maintain information on purged/destroyed refrigerant

0.025

$2.23

EPA estimates that owners/operators of appliances will spend 3 minutes per year maintaining records
on the full charge of an appliance. EPA estimates that owners/operators will spend 1 minute per
servicing event maintaining records on leak rate calculations, for an average of slightly more than 6
minutes per year (0.104 hours). 5
Owners/operators of ODS refrigerant-containing appliances with charge sizes of 50 or more pounds are
also required to maintain records for each service or maintenance event. EPA estimates that
maintaining these records takes 1.5 minutes per servicing event, for an average annual burden of
approximately 9 minutes per owner/operator. 6
Owners/operators are required to maintain reports on quarterly and annual inspections and on the
results of verification tests and leak inspections any time the leak rate threshold is exceeded. EPA
estimates that maintaining leak inspection records requires one minute of burden, for an average
annual burden of approximately 3 minutes per owner/operator. 7 EPA estimates that 1.5 minutes is
required to maintain reports on the results of verification tests any time the leak threshold is exceeded.
Owners/ operators planning to retire/replace or retrofit appliances spend 8 hours on developing or
maintaining a plan.
Owners/operators must prepare and maintain records of mothballed appliances. EPA estimates a
burden of 1.5 minutes to prepare and maintain records. EPA also estimates that owners/operators of
appliances normally containing 50 or more pounds of refrigerant spend 1.5 minutes maintaining

As noted above, EPA estimates that appliances containing 50 to 500 pounds of refrigerant will be serviced
annually, requiring 1 leak rate record, and that appliances with 500 or more pounds will be serviced quarterly,
requiring 4 leak rate records.
6
The number of records is based on the total number of equipment and an assumption that appliances containing
50 to 500 pounds of refrigerant will be serviced annually, requiring 1 invoice, and that appliances with 500 or more
pounds will be serviced quarterly, requiring 4 invoices.
7
This is calculated based on the total number of appliances that have been found to be above the threshold leak
rate, and thus require quarterly or annual leak inspections.
5

25

information on purged and destroyed refrigerant.

8.

Small Can Manufacturers
Annual Respondent Burden - Reporting
Collection Activities

Maintain records of self-sealing valve test data and log forms
for 3 years

Burden Hours

Labor Costs/Entity

0.30

$9.14

Manufacturer of small cans of refrigerant are required to conduct tests to verify that self-sealing valves
function and maintain logs of test results. EPA estimates that manufacturers will require 1.5 minutes to
document each test result and that tests will occur monthly for a total of 18 minutes annually.

Estimating the Respondent Universe and Total Burden and
Costs
The respondent universe as well as the frequency of reporting is defined in 40 CFR, Part 82, Subpart F,
and includes refrigerant recovery/recycling equipment testing organizations; averages for the number of
service establishments, disposers, and refrigerant reclaimers that enter the market or change
ownership; refrigerant wholesalers; technician certification programs; technicians acquiring certification
and maintaining certification cards; technicians servicing refrigeration and air-conditioning appliances;
owners of refrigeration and air-conditioning appliances; owners of industrial process refrigeration
appliances; and small can manufacturers.
EPA used past experience, previously reported data, modeling, and estimates from the affected
community to determine the number of respondents (or the respondent universe). The estimates are
based upon EPA's experience in implementing the Program since 1993 and analysis conducted in the
Technical Support Document that accompanies this rulemaking. 8 A listing of these entities follows:


Refrigerant/Recycling Equipment Testing Organizations: Testing organizations for refrigerant
recovery/recycling equipment have remained at two organizations since inception of the program in
1993. Based on past experience, EPA does not anticipate that additional entities will apply to
become approved refrigerant recovery/recycling equipment testing organizations.

See Technical Support Document: Analysis of the Economic Impact and Benefits of Final Revisions to the National
Recycling and Emission Reduction Program. September 2, 2016. Available at:
https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0453-0225.

8

26













Refrigerant Reclaimers: EPA currently has 61 certified refrigerant reclaimers who must submit
annual activity reports. Based on EPA's experience, EPA estimates four reclaimers per year will
submit one-time applications to EPA to be certified.
Refrigerant Wholesalers: EPA assumes that the number of wholesalers is 11,000. This is based on
publicly available data on the number of hardware, and plumbing and heating equipment and
supplies merchants (NAICS code 4237).
Technician Certifying Programs: EPA currently has 72 certified technician certifying programs. Based
on EPA's experience, EPA estimates 5 new organizations per year will submit materials to EPA
requesting that they be authorized to test and certify technicians. EPA assumes that, on average, 5
technician certifying programs will exit the market and need to transfer records to EPA or another
certifying program.
Technicians: EPA assumes that the number of technicians entering the workplace has remained
constant with those that who have left the workforce. This ICR assumes that the number of
technicians has remained constant at 300,000. EPA assumes that 10 percent of the technician labor
force turns over each year (i.e., 30,000 technicians), necessitating certification.
Disposal Establishments: EPA assumes that the number of disposal establishments (7,500) has not
changed since the previous ICR.
Owners/Operators:9

 Based on actual submissions to EPA, the Agency estimates that 4 owners/operators of comfort
cooling, commercial refrigeration, and industrial process refrigeration appliances with charge
sizes of 50 or more lbs. of ODS refrigerant will choose to exclude the amount of purged and
destroyed refrigerant from their leak rate calculations.

 EPA allows owners/operators of industrial process refrigeration, comfort cooling, and
commercial refrigeration appliances with a charge size of 50 or more pounds to submit a written
request for an extension to leak repair requirements. The number of extensions is estimated
partly based on the number of actual extensions filed for ODS industrial process refrigeration
appliances in previous years. EPA also expects additional requests from owners/operators of
comfort cooling and commercial refrigeration appliances due to the new extensions for such
appliances. EPA estimates that 2,412 owners/operators of ODS appliances will prepare and
submit request for extensions each year.

All of the following assumptions about the number of owners/operators of comfort cooling, commercial
refrigeration, and industrial process refrigeration appliances were developed in the Technical Support Document
that accompanies this rulemaking.

9

27

 61 owners/operators of appliances with a charge size of 50 or more pounds of ODS refrigerant
are expected to prepare and submit requests for extensions to the one year retrofit/retire
timeline. This estimate is based on the number of IPR and federally-owned appliances that
historically sought extensions. The number of extensions for IPR is scaled up to account for
extensions requested for comfort cooling and commercial refrigeration appliances.

 EPA estimates that 2,745 owners/operators will develop and maintain the required appliance
retrofit/retirement report at their place of business. EPA assumes that fewer retrofits/
retirements will now occur due to the availability of extensions.

 EPA estimates that 5 percent of owners/operators, or 137 entities, that develop retrofit/retire
plans will submit a request to cease retrofit/retirement.

 Owners/operators must prepare and maintain records of mothballed appliances. EPA estimates
that 2 percent of owners/operators, or 55 entities, will need to maintain these records.

 EPA estimates that 255,083 owners/operators of appliances with charge sizes of 50 or more
pounds of ODS refrigerant would need to maintain annual or quarterly service invoices. The
number of owners/ operators is estimated based on the total number of appliances and the
average number of appliances per model facility in the Technical Support Document associated
with this rule.

 EPA estimates that there are 166,175 events that would exceed the leak rate threshold in IPR,
comfort cooling, and commercial refrigeration appliances containing an ODS refrigerant. For the
purposes of this analysis, EPA assumes that the number of leak events is equivalent to the
number of owners/operators that would need to keep records on the results of the verification
tests when those thresholds are exceeded.

 EPA estimates that there are 1,057 events where IPR, comfort cooling, and commercial
refrigeration appliances would leak 125 percent or more of the full charge in a calendar year.
For the purposes of this analysis, EPA assumes that the number of events is equivalent to the
number of owners/operators that would need to report on leak and repair efforts to EPA.


Small Can Manufacturers: EPA estimates there are 10 manufacturers of small cans of refrigerant
that need to comply with the self-sealing valve requirements.

Almost all of the entities that may be subject to these regulatory actions are small businesses. Additional
information on small business impacts can be found in the 2016 Technical Support Document. 10

See Technical Support Document: Analysis of the Economic Impact and Benefits of Final Revisions to the
National Recycling and Emission Reduction Program. September 2, 2016. Available at:
https://www.regulations.gov/document?D=EPA-HQ-OAR-2015-0453-0225.

10

28

Estimating Agency Burden and Cost
The hourly rate for EPA staff at the GS-13 Step 1 level is $36.24 per hour. This hourly basic rate is from
the 2018 GS salary schedule listed in the Federal Wage Page of the Office of Personnel Management
website https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/. EPA then multiplied
the hourly rate by the standard government benefits and overhead multiplication factor of 1.6. The
resulting rate that was used in estimating annual Agency burden and cost is $57.98 ($36.24 × 1.6).
EPA has used past experience, reporting data, and estimates from the affected community in
determining the number of responses that the Agency would review. The following paragraphs describe
the amount and degree of burden.


Refrigerant Reclaimers: 64 certified refrigerant reclaimers must submit annual activity reports. EPA
will spend one hour reviewing each of the annual reports for a total of 61 hours per year.
Based on EPA's experience, it is assumed that 4 new refrigerant reclaimers per year will submit onetime applications to EPA to be certified. EPA spends one hour reviewing and approving each
certification for a total of four hours per year.



Technician Certifying Programs: 72 certified technician certifying programs must submit biannual
activity reports to EPA. EPA will spend one hour reviewing each biannual activity report, for a total
of 144 hours per year.
Based on EPA's experience, the Agency expects to certify 5 new technician certification
organizations per year. EPA expects to spend two hours reviewing and approving each application,
for a total of 10 hours per year. EPA assumes an equal number of technician certifying programs will
exit the market and need to transfer records to EPA or another entity. EPA assumes 1 hour for
processing these records.



Owners/Operators: EPA estimates that it takes 15 minutes to review and make a determination on
each of the anticipated 2,412 requests from owner/operators of industrial process refrigeration,
comfort cooling, and commercial refrigeration appliances for an extension to the 30-day repair
requirement for mandatory leak repair, for a total of 603 hours per year.
EPA estimates one hour to review and make a determination on anticipated 61 requests from the
owner/operator of industrial process refrigeration, comfort cooling, and commercial refrigeration
appliances for an extension to the one-year retrofit requirement under the leak repair
requirements, for a total of 61 hours a year.

29

EPA estimates that it takes 10 minutes to review each of the anticipated 1,057 reports on IPR,
comfort cooling, and commercial refrigeration appliances that leak 125 percent or more of the full
charge in a calendar year, for a total of 176 hours per year.
EPA estimates that it will take 5 minutes to review each of the anticipated 138 requests to cease
retrofit/retirement.

Bottom Line Burden Hours and Cost Tables
The bottom line burden hours and cost tables for respondents and the Agency are summarized below
for all activities.

30

i) Respondent Tally
Table 3 and Table 4 summarize total annual respondent burden and cost by respondent type and activity
Table 3: Annual Respondent Burden and Cost
Number of
Respondents

Number of
Responses per
Respondent

Burden
Hours per
Response

Annual
Burden
Hours

0

1

8.0

0

1

0.5

1

1

0.5

1

$87.63

1

0.5

1

$87.63

1

5.0

20

$1,225

260

0.02

277

50

0.23

750

$47,047

1

9.37

600

$37,638

11,000

260

0.033

95,333

Apply for approval

5

1

5.0

25

Recordkeeping by existing technician certification
programs

72

1

5.0

360

2

0.08

12

Respondent
Type
Refrigerant
Recovery/
Recycling
Equipment
Testing
Organizations

Activity
Equipment testing organization applying for approval
Maintain records of refrigerant recovery/recycling
equipment tested and its performance
Providing notice when equipment fails recertification
Publish online a list of all certified equipment
Certification by refrigerant reclaimers that change
ownership or enter the market

Refrigerant
Reclaimers

2

Maintain records of analysis conducted to verify that
reclaimed refrigerant meets the necessary specifications
Reclaimer recordkeeping

4

64

Annual activity report
Refrigerant
Wholesalers
Technician
Certifying
Programs

Recordkeeping for refrigerant sales, including
maintenance of technician certification cards from
purchasers employing at least one certified technician

Maintain list of technicians certified

31

Hourly
Labor
Costs

Annual
Labor
Costs
$0

$87.63

$62.77

$57.52

$87.63

$17,408

$5,483,478
$1,609

$64.37

$23,171
$772

Respondent
Type

Number of
Responses per
Respondent

Burden
Hours per
Response

Annual
Burden
Hours

2

1.0

144

$9,269

5

1

8.0

40

$2,575

Maintain copies of signed statements of previous
refrigerant recovery by disposal establishments

7,500

260

0.058

113,750

Technicians acquire certification cards

30,000

1

0.017

501

$23,820

1

0.017

5,010

$238,195

2.28

0.03

42,298

$1,084,003

1.97

0.03

36,475

Provide leak inspection and verification test records

.73

0.017

6,384

$219,900

Maintain disposal records for appliances with charge
sizes of 5 - 50 lbs.

12

0.017

60,000

$2,852,640
$107,762

Number of
Respondents

Activity
Biannual reporting by technician certification programs
Transfer of records when no longer operational

Disposal
Establishments

Technicians maintain certification cards
Provide invoices for serviced appliances with charge
sizes 50 to 500 lbs.
Technicians

Owners/
Operators of
Appliances with
Charge Sizes of
50 or More
Pounds of ODS
Refrigerant

Provide invoices for serviced appliances with charge
sizes >500 lbs.

300,000

Hourly
Labor
Costs

$47.54

$47.54

Annual
Labor
Costs

$5,408,130

$936,617

Prepare and submit requests for extensions to 30-day
repair timeline

2,412

1

0.50

1,206

Prepare and submit requests for extensions to 1-year
retrofit/retire timeline

61

1

0.5

30

$2,709

Prepare and submit requests to cease a
retrofit/retirement if all leaks are repaired

137

1

0.5

69

$6,121

Prepare and submit report on efforts to repair
chronically leaking appliances

$89.36
1,057

Maintain records of the full charge of an appliance
Maintain records of the leak rate calculation
Maintain purchase and service records

32

255,083

1

1.0

1,057

$94,448

2

0.025

12,754

$1,139,647

6.25

0.017

26,588

$2,375,763

6.25

0.025

39,882

$1,896,144

Number of
Respondents

Number of
Responses per
Respondent

Burden
Hours per
Response

Annual
Burden
Hours

Maintain leak inspection records

166,175

2.73

0.017

3,665

$327,486

Maintain reports on the results of verification tests any
time the leak rate threshold is exceeded

166,175

1

0.025

4,154

$371,214

2,745

1

8.00

21,960

$1,962,236

Maintain records on mothballed equipment

55

1

0.025

1

$123

Maintain information on purged/destroyed refrigerant

4

1

0.025

0.1

$3.75

Maintain records of self-sealing valve test data and log
forms for 3 years

10

12

0.025

3

Respondent
Type

Activity

Develop/maintain plan to retire/replace or retrofit
appliances, as applicable

Small Can
Manufacturers

Table 4: Total Annual Respondent Burden
Number of Respondents

Number of Responses

Hour Burden

Labor Costs

573,731

14,583,089

434,359

$24,625,892

33

Hourly
Labor
Costs

$28.98

Annual
Labor
Costs

$91

ii) The Agency Tally
Table 5: Annual Agency Burden and Cost
Number of
Respondents

Number of
Responses per
Respondent

Burden Hours
to Review each
Response

Total Annual
Agency
Hours

Reclaimer annual activity report

64

1

1.0

64

$3,711

Certification by reclaimers that change ownership or enter the market

4

1

1.0

4

$232

Biannual reporting by existing technician certification programs

72

2

1.0

144

$8,350

Technician certification programs applying for approval

5

1

2.0

10

$580

Technician certification programs transferring records

5

1

1.0

5

$290

2,412

1

0.25

603

$34,964

Owners/operators of appliances with 50 or more lbs of ODS refrigerant
prepare & submit requests for extensions to 1 year retrofit/retire timeline

61

1

1.0

61

$3, 516

Owners/operators of appliances with 50 or more lbs of ODS refrigerant
prepare & submit requests to cease a retrofit/retirement if all leaks are
repaired

138

1

0.08

11.5

$667

Owners/operators of appliances with 50 or more lbs of ODS refrigerant
that leak 125 percent or more of the full charge in a calendar year to
submit report on leak and intended repair

1,057

1

0.17

176

$10,2115

Activity

Owners/operators of appliances with 50 or more lbs of ODS refrigerant
prepare & submit requests for extensions to the 30-day repair timeline

Table 6: Total Annual Agency Burden
Number of Respondents

Number of Responses

Hour Burden for Review

Labor Costs

3,820

3,890

1,078

$62,524

34

Total
Agency
Labor Costs

Reasons for Change in Burden
EPA is proposing to revise the leak repair provisions so they apply only to equipment using refrigerant
containing a class I or class II substance. This proposal would remove reporting and recordkeeping
requirements for owners and operators of appliances containing 50 or more pounds of a non-exempt
substitute refrigerant (e.g., HFCs) and technicians servicing such appliances.

Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is estimated to
range from 1 minute to 9.4 hours per response. The average reporting and recordkeeping burden for
this collection is 1.35 hours per response. This estimate includes time for preparing and submitting
reports and maintaining records on-site at the respondents’ places of business.
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 No. EPA-HQ-OAR2017-0629, which is available for online viewing at www.regulations.gov, or in person viewing at the Air
and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Ave., NW, Washington, DC. 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 OAR 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, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket

35

ID No. EPA-HQ-OAR-2017-0629and OMB control number 2060-0256 in any correspondence.

36