Burden Calculation Table

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response	261
Number of Respondents	337
Total Estimated Burden Hours	17,500
Total Estimated Costs	$2,210,000
Annualized Capital O&M	$0
Total Annual Responses	67
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal).
REPORTING/RECORDKEEPING REQUIREMENT a			(A) Respondent Hours per Occurrence (Technical hours)	(B) Number of Occurrences per Respondent per Year	(C) Hours per Respondent per Year (C=A x B)	(D) Number of Respondents per Year	(E) Technical Hours per Year (E=C x D)	(F) Management Hours per Year (F= E x 0.05)	(G) Clerical Hours per Year (G= E x 0.1)	Total Labor Costs per Year b
Reporting
1	Read instructions		2	1	2	30	60	3	6	$8,701		Managerial Labor Rate	$163.17
2	Gather information		1	1	1	30	30	1.5	3	$4,350		Technical Labor Rate	$130.28
3	Initial notification		1	1	1	30	30	1.5	3	$4,350		Clerical Labor Rate	$65.71
4	Update date code		1	1	1	30	30	1.5	3	$4,350
5	Variance application		2	1	2	5	10	0.5	1	$1,450
6	Innovative products application		24	1	24	2	48	2.4	5	$6,960
		Total for Reporting						239		$30,162
Recordkeeping
7	Read instructions		------------------------Included in 1----------------------------
8	Plan activities		2	1	2	300	600	30	60	$87,006
9	Implementation		4	12	48	300	14,400	720	1,440	$2,088,137
10	Charcoal lighter results		1	1	1	5	5	0.3	0.5	$725
		Total for Recordkeeping						17,256		$2,175,868
Total Industry Burden (rounded) c								17,500		$2,210,000		261	hrs/response
a The recordkeeping and reporting requirements of 40 CFR Part 59, Subpart C apply to distributors named on product labels or manufacturers or importers of products. We have assumed that 337 respondents per year will do new reporting or recordkeeping due to changes in products.
b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation." The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal)
			0.869565				$46.22
REPORTING/RECORDKEEPING REQUIREMENT a			(A) Person Hours per Occurrence	(B) Occurrences per Year	(C) Technical Person Hours (C=A x B)	(D) Management Person Hours (D = C x 0.05)	(E) Clerical Person Hours (E=C x 0.1)	Total Cost per Year b
Reporting
	Initial notification		1	30	30	1.5	3	$1,834		Managerial Labor Rates	$73.46
	Update date code		1	30	30	1.5	3	$1,834		Technical Labor Rates	$54.51
	Variance application		8	5	40	2	4	$2,445		Clerical Labor Rates	$29.50
	Innovative products application		8	2	16	0.8	1.6	$978
Total Agency Burden c					133			$7,090
a The recordkeeping and reporting requirements of 40 CFR Part 59, Subpart C apply to distributors named on product labels or manufacturers or importers of products. We have assumed that 337 respondents per year will do new reporting or recordkeeping due to changes in products . We assume that 37 of these respondents will submit reports for Agency review.
b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

The only costs to the regulated industry resulting from information collection activities required by the subject standard(s) are labor costs. There are no capital/startup or operation and maintenance costs.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial notification	30	1	0	30
Update date code	30	1	0	30
Variance application	5	1	0	5
Innovative products application	2	1	0	2
			Total	67

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Sheet 6: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents (E=A+B+C-D)
1	37	37	300	37	337
2	37	37	300	37	337
3	37	37	300	37	337
Average	37	37	300	37	337
1 The recordkeeping and reporting requirements of 40 CFR Part 59, Subpart C apply to distributors named on product labels or manufacturers or importers of products. We have assumed that 337 respondents per year will do new reporting or recordkeeping due to changes in products.