U.S. Environmental Protection Agency
Information Collection Request
Title: National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal)
OMB Control Number: 2060-0348
EPA ICR Number: 1764.09
Abstract: The National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) were proposed on April 2, 1996, promulgated on September 11, 1998, and most recently amended on June 25, 2013. These standards apply to manufacturers, importers, and distributors of consumer products. This information is being collected to ensure compliance with 40 CFR Part 59, Subpart C.
In general, all National Volatile Organic Compound Emission Standards for Consumer and Commercial Products require initial notifications and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to these emission standards.
Any owner/operator subject to the provisions of this part shall maintain a file of these measurements and retain the file for at least three years following the date of such measurements, maintenance reports, and records, except for charcoal lighter material compliance test information, which must be retained for at least five years. All reports required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. In the event that there is no such delegated authority, the EPA regional office can review them. All other reports are sent to the delegated state or local authority. In the event that there is no such delegated authority, the reports are sent directly to the EPA regional offices. The use of the term "Designated Administrator" throughout this document refers to the U.S. EPA or a delegated authority such as a state agency. The term "Administrator" alone refers to the U.S. EPA Administrator.
The “Affected Public” includes manufacturers, importers, and named distributors of consumer products. The burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by federal employees or government contractors and may be found in Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal). None of the affected facilities in the United States are owned by state, local, tribal or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond.
Based on our consultations with industry representatives, the respondent universe is expected to be as follows for the three-year period covered by this ICR:
Total number of affected sources is 3,000;
Total number of respondents will be 337;
Number of respondents performing “new” recordkeeping will be 10 percent, or about 300 per year;
Number of “new” respondents submitting the one-time Initial Notification Report will be 1 percent of the total affected sources, or about 30 per year;
Number of respondents submitting variance applications will be 5; and
Number of respondents submitting innovative products applications will be 2.
Supporting Statement A
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
The EPA is required under Section 183(e) of the Clean Air Act (Act) to regulate VOC emissions from the use of consumer and commercial products. Pursuant to Section 183(e)(3), the EPA published a list of consumer and commercial products and a schedule for their regulation on March 23, 1995 (60 FR 15264). Consumer products were included in Group I of the list, and standards were promulgated on September 11, 1998 and are codified at 40 CFR Part 59, Subpart C.
The reports and recordkeeping activities required under the rule enable the EPA to determine whether or not consumer products manufactured or imported for use in the U.S. meet the VOC content limits. Minimal reporting is required. Initial reporting consists of information needed by EPA to (1) identify the universe of manufacturers and importers subject to the rule; (2) determine the date of manufacture of products; (3) ascertain the location of formulation and batch records for purposes of compliance assurance; and (4) have on record a responsible company official as a primary contact. Notification that a regulated entity has revised its date code system will enable EPA to have access to the most current codes.
Respondents seeking a variance are required to submit an application which includes the grounds upon which the variance is being sought, the proposed date for coming into compliance, and a plan for achieving compliance.
Companies desiring to market a product under the “innovative products” provisions are required to submit documentation of the VOC emissions from the use of the product as compared to emissions from a product formulated in compliance with the table of standards.
Recordkeeping, consisting of maintenance of formulation data and batch records, enable EPA to determine whether a product offered for sale was, in fact, manufactured with VOC content in compliance with the limits. There is no required testing except for one-time emission testing of charcoal lighter fluid formulations.
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.
Agency enforcement personnel will use the information collected to (1) identify manufacturers and importers subject to the rule; and (2) ensure that consumer products comply with the VOC content standards. These activities are essential to compliance assurance.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Electronic copies of records may also be maintained in order to satisfy Federal recordkeeping requirements.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication.
For all other reports, if the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to either the delegated state or local agency. If a state or local agency has adopted its own standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. In the final rulemaking notice, the EPA prepared a regulatory flexibility analysis (FRFA) which examined the impact of the final rule on small entities (See 63 FR 48829, September 11, 1998). The EPA determined that almost 80 percent of the affected companies are small entities. This percentage was applied to the total number of consumer products firms affected by this ICR.
Companies subject to the rule can apply for variances in cases where the company, because of extraordinary reasons beyond reasonable control, cannot comply with the rule. While all variance applications will receive close scrutiny, the EPA will give full consideration to the special needs of small manufacturers and importers.
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
These standards require the respondents to maintain records of charcoal lighter material compliance test information for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five years. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.
Otherwise, these reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (88 FR 31748) on May 18, 2023. No comments were received on the burden published in the Federal Register for this renewal.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 337 respondents will be subject to the standard over the three-year period covered by this ICR.
Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Society of Chemical Manufacturers & Affiliates (SOCMA) at 571-348-5100 and the Personal Care Products Council (PCPC) at 202-331-1770. In this case, no comments were received.
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
The Agency does not intend to provide payments or gifts to respondents as part of this collection.
ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
The respondents to the recordkeeping and reporting requirements are manufacturers, importers, and named distributors of consumer products. Manufacturers of consumer products fall within standard industrial classification (SIC) 284, including “Soap, Detergents, Cleaning Preparations” and “Perfumes, Cosmetics, and Other Toilet Preparations;” SIC 287, “Agricultural Chemicals;” and SIC 289, “Miscellaneous Chemical Products.” The corresponding North American Industrial Classification System (NAICS) codes are 3256, “Soap, Cleaning Compound, and Toilet Preparation Manufacturing;” 3253, “Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing;” and 3259, “Other Chemical Product and Preparation Manufacturing.”
The number of respondents is calculated using the following table that addresses the three years covered by this ICR:
Number of Respondents |
|||||
|
Respondents That Submit Reports |
Respondents That Do Not Submit Any Reports
|
|||
Year |
(A) Number of New Respondents 1 |
(B) Number of Existing Respondents |
(C) Number of Existing Respondents that keep records but do not submit reports |
(D) Number of Existing Respondents That Are Also New Respondents |
(E) 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.
Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 337.
In this ICR, all the data that are recorded or reported is required by the National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C).
A source must make the following reports:
Notifications |
|
Initial notification |
§59.209(d) |
Notification of change of date coding system |
§59.209(e) |
Application for variance |
§59.206(a) |
Documentation of “innovative products” |
§59.204(d) |
A source must keep the following records:
Recordkeeping |
|
Records of formulations in use |
§59.209(a) |
Records of composition of each batch of production |
§59.209(a) |
Records of charcoal lighter materials testing |
§59.209(c) |
Respondent Activities |
Read instructions. |
Write the notifications and reports listed above. |
Enter information required to be recorded above. |
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for collecting, validating, and verifying information. |
Develop, acquire, install, and utilize technology and systems for processing and maintaining information. |
Develop, acquire, install, and utilize technology and systems for disclosing and providing information. |
Train personnel to be able to respond to a collection of information. |
Transmit, or otherwise disclose the information. |
The total number of annual responses per year is calculated using the following table:
Total Annual Responses |
||||
(A)
Information Collection Activity |
(B)
Number of Respondents |
(C)
Number of Responses |
(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports |
(E) 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 |
The number of Total Annual Responses is 67.
12d. Respondent Burden Hours and Labor Costs
Table 1 at the end of this document records the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.
The total annual labor hours are 17,500. Details regarding these estimates may be found in Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 261 hours per response.
We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
This ICR uses the following labor rates:
Managerial $163.17 ($77.70 + 110%)
Technical $130.28 ($62.04 + 110%)
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.
The total annual labor costs are $2,210,000. Details regarding these estimates may be found at the end of this document in Table 1.
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
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.
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.
Agency Activities |
Review notifications required to be submitted by industry. |
Audit facility records. |
Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS. |
14b. Agency Burden and Labor Cost
The average annual Agency burden and cost over next three years is estimated to be 133 labor hours at a cost of $7,090; see below in Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal).
The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.
We assume that burdens for managerial tasks take 5% of the time required for technical tasks, because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks, because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.
This cost is based on the average hourly labor rate as follows:
Managerial $73.46 (GS-13, Step 5, $45.91 + 60%)
Technical $54.51 (GS-12, Step 1, $34.07 + 60%)
Clerical $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. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal).
14c. Agency Non-Labor Costs
There are no anticipated non-labor costs for the Agency.
REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
The increase in burden from the most recently approved ICR is due to an adjustment(s). The adjustment increase in burden from the most recently approved ICR is due to a correction in the calculation for clerical labor hours. The most recently approved ICR incorrectly estimated clerical labor hours by multiplying technical labor hours by 0.01 (1%). This calculation was corrected to multiply technical labor hours by 0.1 (10%). As described above in Section 6(e)(i), clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records. Although the supporting statement for the most recently approved ICR indicated there are 732 respondents, this was based on the sum of all values listed in column D of Table 1, which resulted in double counting. This has been corrected to 337 respondents as described in Sections 1(b) and 6(d), above. However, the number of respondents listed for each line item of Table 1 is unchanged; therefore, this correction did not result in a decrease in the estimated burden. There is an increase in costs from the most recently approved ICR due to the labor hour correction and the use of updated labor rates. This ICR uses labor rates from the most recent Bureau of Labor Statistics report (September 2022) to calculate respondent burden costs.
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
The Agency does not intend to publish information gathered through this infromation collection.
DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The Agency plans to display the expiration date for OMB approval of the information collection on all instruments.
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.
BURDEN STATEMENT
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 261 hours 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 valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.
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) |
(B) |
(C) |
(D) |
(E) |
(F) |
(G) |
|
||
Reporting |
|
|
|
|
|
|
|
|
||
1 |
Read instructions |
|
2 |
1 |
2 |
30 |
60 |
3 |
6 |
$8,701 |
2 |
Gather information |
|
1 |
1 |
1 |
30 |
30 |
1.5 |
3 |
$4,350 |
3 |
Initial notification |
|
1 |
1 |
1 |
30 |
30 |
1.5 |
3 |
$4,350 |
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 |
||
|
|
|
|
|
|
|
|
|
|
|
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. |
||||||||||
Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal)
REPORTING/RECORDKEEPING REQUIREMENT a |
(A) |
(B) |
(C) |
(D) |
(E) |
|
|||
Reporting |
|
|
|
|
|
|
|||
|
Initial notification |
1 |
30 |
30 |
1.5 |
3 |
$1,834 |
||
|
Update date code |
1 |
30 |
30 |
1.5 |
3 |
$1,834 |
||
|
Variance application |
8 |
5 |
40 |
2 |
4 |
$2,445 |
||
|
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. |
|||||||||
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 18Q Supporting Statement Instructions_draft |
| Author | McGrath, Daniel |
| File Modified | 0000-00-00 |
| File Created | 2024-08-01 |