Burden Calculations Table

---

Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents

---

Sheet 1: Summary

ICR Summary Information
Hours per Response	152
Number of Respondents	520
Total Estimated Burden Hours	24,500
Total Estimated Costs	$1,550,000
Annualized Capital O&M	$0
Total Annual Responses	161
Form Number	Not Applicable

---

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – National Volatile Organic Compound Emission Standards for Architectural Coatings (40 CFR Part 59, Subpart D)
Burden Item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
1. Applications	N/A									Labor Rates
2. Surveys and Studies	N/A									Management	$163.17
3. Reporting Requirements										Technical	$130.28
A. Read Instructions c	2	1	2	5	10	5	1	$2,184		Clerical	$65.71
B. Gathering Existing Information	See 3C
C. Write Report
Initial Report c	2	1	2	5	10	5	1	$2,184
Date Code Explanation c	1	1	1	5	5	2.5	0.5	$1,092
Update Date Codes d	2	1	2	52	104	52	10.4	$22,717
Recycled Coatings Report - Mass Balance e	6	1	6	13	78	39	7.8	$17,038
Recycled Coatings Report - Formulation e	4	1	4	13	52	26	5.2	$11,359
Exceedance Fee Annual Report f	8	1	8	47	376	188	37.6	$82,132
Tonnage Exemption Annual Report g	8	1	8	78	624	312	62.4	$136,304
Subtotal for Reporting Requirements					2,014			$275,011
4. Recordkeeping Requirements
A. Read Instructions	See 3A
B. Plan Activities a,c	8	1	8	5	40	20	4	$8,737
C. Implement Activities
Calculate VOC content for Each Product c,h	42	1	42	5	210	105	21	$45,872
Calculate Adjusted VOC for Recycled Coatings i	20	1	20	26	520	260	52	$113,587
Exceedance Fee - Calculations f	64	1	64	47	3008	1504	300.8	$657,055
Tonnage Exemption Calculations g	16	1	16	78	1248	624	124.8	$272,608
D. Record Data
Recycling Volumes i	8	12	96	26	2496	1248	249.6	$545,216
Exceedance Fee f	8	1	8	47	376	188	37.6	$82,132
Tonnage Exemption g	4	1	4	78	312	156	31.2	$68,152
E. Time to Train Personnel	N/A
5. Labeling j,k	67	1	67	87	5829	2914.5	582.9	$1,273,263
Subtotal for Recordkeeping Requirements					22,462			$3,066,623		152	hr/response
Total Labor Burden and Costs (rounded) l					24,500			$1,550,000
Total Capital and O&M Cost (rounded) l								$0
GRAND TOTAL (rounded) l								$1,550,000
Assumptions:
a The respondent universe consists of 520 architectural coating manufacturers. Of these, 78 are considered large manufacturers and 442 are considered small manufacturers. that the number of new respondents submitting the one-time Initial Notification Report and date code explanations will be 1 percent of the total respondent universe of 520, or about 5 per year.
b This ICR uses the following labor rates: $163.17 ($77.70 + 110%) per hour for Executive, Administrative, and Managerial labor; $130.28 ($62.04 + 110%) per hour for Technical labor, and $65.71 ($31.29 + 110%) per hour for Clerical labor. 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 Total number of manufacturers is estimated to be 520; 1 percent or 5 new respondents per year are assumed.
d Assumed that 10 percent of manufacturers update some date codes each year. (520 manufacturers) (0.10) = 52 manufacturers.
e Assumed that 5 percent of manufacturers recycle coatings (520 manufacturers) (0.05) = 26 manufacturers. Of the 26 manufacturers, assumed half of the recycle coating manufacturers would demonstrate compliance using mass balance and the other half using formulations.
f Based on exceedance fee reports received in 2009 (52) and 2010 (39), it is estimated that 47 exceedance fee reports will be submitted per year.
g Assumed that 78 manufacturers will use the tonnage exemption option.
h Based on a time estimate of 1 hour per coating product. (1 hour/product) (42 products/manufacturer) = 42 hours/manufacturer.
i Assumed that 5 percent of manufacturers recycle coatings. (520 manufacturers) (0. 05) = 26 manufacturers.
j Based on an industry estimate of 320 hours needed to modify labels for a company with 200 paint products, or 1.6 hours per product. (1.6 hours/product) (42 products/manufacturer) = 67 hours/manufacturer.
k Assumed that half of the manufacturers would have to modify their labels over 3 years. (520 manufacturers) (0.5)/(3 years) = 87 manufacturers per year.
l Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

---

Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Architectural Coatings (40 CFR Part 59, Subpart D)
Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Cost, $ b
Initial Report c	1	5	5	5	25	0.25	0.5	$1,395.92		Labor Rates
Annual Report: Manufacture of Recycled Coatings - Mass Balance d	1	12.5	12.5	26	325	0.625	1.25	$17,799.19		Management	$73.46
Annual Report: Manufacture of Recycled Coatings - Formulation d	0.5	12.5	6.3	26	163.8	0.315	0.63	$8,970.79		Technical	$54.51
Date Code										Clerical	$29.50
Date Code Reports c	0.5	5	2.5	5	12.5	0.125	0.25	$697.96
Date Code Updates e	0.5	50	25	52	1,300	1.25	2.5	$71,031.18
Annual Report: Exceedance Fee f	4	45	180	47	8,460	9	18	$462,363.70
Annual Report: Tonnage Exemption g	2	75	150	78	11,700	7.5	15	$638,783.88
Maintenance of implementation database	60	1	60	1	60	3	6	$3,668.11
TOTAL (rounded) h					22,100			$1,205,000
Assumptions:
a The respondent universe consists of 520 architectural coating manufacturers. Of these, 78 are considered large manufacturers and 442 are considered small manufacturers. that the number of new respondents submitting the one-time Initial Notification Report and date code explanations will be 1 percent of the total respondent universe of 520, or about 5 per year.
b The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses. Managerial rates 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 Total number of manufacturers is estimated to be 520; 1 percent or 5 new respondents per year are assumed.
d Assumed 26 recycled coating manufacturers; assumed half use mass balance option and half use formulation option.									0.05	26
e Assumed 10 percent of all manufacturers update some date codes each year. (520 manufacturers) (0.10) = 52 manufacturers.									52
f Assumed 47 manufacturers will pay fees on some coatings (see footnote f in Table 1).
g Assumed 78 manufacturers will use tonnage exemption option.
h Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

---

Sheet 4: Capital O&M

There are no Capital and O&M costs associated with this ICR Renewal

---

Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents a	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
Initial Notification	5	1	0	5
Initial Report	5	1	0	5
Annual report for manufacturers and importers of recycled coatings that choose to determine the adjusted VOC content	26	1	0	26
Annual report for manufacturers and importers using the optional exceedance fee	47	1	0	47
Annual report for manufacturers and importers using the optional tonnage exemption	78	1	0	78
			Total	161

---

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 a	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	5	510	0	0	515
2	5	515	0	0	520
3	5	520	0	0	525
Average	5	515	0	0	520
a New respondents include sources with constructed, reconstructed, and modified affected facilities.