1

Part A of the Supporting Statement

1. Identification of the Information Collection

(a) Title of the Information Collection

"National Volatile Organic Compound Emission Standards for Aerosol Coatings." The 

Environmental Protection Agency (EPA) tracking number for this information collection request 

(ICR) is 2289.02. This is a renewal of a continuing ICR, OMB No. 2060-0617, which is due to 

expire September 30, 2011.

(b) Short Characterization/Abstract

(i) Type of collection.

Compliance with the aerosol coatings rule was required by January 1, 2009. The final 

rule included a requirement for an Initial Notification from all regulated entities to the EPA at 

least 90 days before the compliance date. This notification provides basic information about the 

regulated entity as well as contact information for the certifying official. In addition, this 

notification needs to explain the product date code system used to label products and the 

category code system, if the facility is not using the default category codes included in Table 1 of 

the rule. The regulated entity is required to submit a revised notification if there is a change in 

the information in the Initial Notification, with the exception of changes to product formulations. 

The regulated entity is not required to submit a revised notification if the VOC formulations 

submitted in its Initial Notification change. The regulated entity is required to submit a revised 

notification if the manufacturer, for example, adds a new coating category, changes the product 

date code system or batch definition, or begins to use a VOC that is not listed in the rule. The 

regulated entity is also required to maintain compliance calculations for each of its aerosol 

coatings formulations, maintain records of the date(s) the batch was manufactured, the volume of 

the batch, and the VOC formula for the formulation. Records of these calculations must be 

maintained for 5 years after the product is manufactured, processed, distributed for wholesale, or 

imported for sale or distribution in interstate commerce in the United State, and the regulated 

entity must supply this information to the EPA within 60 days of a written request. Beginning 

this calendar year (2011), each regulated entity must submit a triennial report. The triennial 

report would provide updated VOC formulation data and, for each VOC formulation, the total 

mass of each individual VOC or mixture used as ingredients in the aerosol coatings 

manufactured, imported, or distributed that year. This information must be provided only for the 

second year of the reporting cycle, which in the case of the first report would be information 

from 2010. Subsequent reports will be required at three year intervals. In other words, a report 

containing data from 2013 will be due in 2014, a report containing data from 2016 will be due in 

2017, and so forth. 

New and existing regulated entities will have to submit an initial notification. Regulated 

entities will also be required to submit notifications of changes in the products or company 

information and to maintain records. In addition, regulated entities will be required to submit 
2

triennial reports of formulation data and VOC usage. Respondent and burden estimates are 

included in Tables 2 and 3.

2. Need for and Use of the Collection

(a) Need/Authority for the Collection. 

The EPA is charged under section 183 (e) of the Clean Air Act (CAA), as amended, to 

establish emission standards for aerosol coatings. Section 183(e) of the CAA requires the EPA to 

regulate consumer or commercial products that account for at least 80 percent of the VOC 

emissions, on a reactivity-adjusted basis, in areas that violate the national ambient air quality

standards for ozone. The CAA also directs the EPA to divide the consumer or commercial 

products into four groups, and establish priorities for regulation until all 4 groups are regulated. 

Of the 22 source categories identified and divided into four groups, the aerosol coatings source 

category is in Group III. 

The information collection requirements are based on recordkeeping and reporting 

requirements. These recordkeeping and reporting requirements are specifically authorized by

CAA section 114 (42 U.S.C. 7414). Initial notifications and reports, as described in this 

information collection request, are necessary to enable the Administrator to determine if the 

standards are being achieved. The emission standards require an initial notification report from 

all regulated entities to the EPA 90 days before the compliance date. The regulated entity is 

required to maintain compliance calculations for each of its aerosol coatings formulations. 

Records of these calculations must be maintained 5 years after the product is manufactured, 

processed, distributed for wholesale, or imported for sale or distribution in interstate commerce 

in the United States. The retention of records for 5 years would allow the EPA to establish the 

compliance history of a regulated entity and any pattern of compliance for purposes of 

determining the appropriate level of enforcement action. Historically, the EPA has found that the 

most flagrant violators frequently have violations extending beyond the 5 years. The EPA would 

be prevented from pursuing the worst violators due to the destruction or nonexistence of records, 

if records were retained for less than 5 years.

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. Similarly, some respondents may qualify for, and seek, 

either a small quantity manufacturer exemption or a compliance extension. The estimates for 

completing these reports are included in the estimates for the Initial Notification.

(b) Practical Utility/Users of the Data.

The data collected under this ICR are essential to ensure compliance with the rule and to 

evaluate its effectiveness. 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, and (3) to better assess the efficacy of the 

reactivity-based approach, including the manner in which the program’s requirements are being 

achieved. These activities are essential to compliance assurance.
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3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication

The subject emission standards are delegated to the EPA and information is sent directly 

to the appropriate EPA Regional Office. The EPA has not duplicated the recordkeeping and 

reporting requirements for regulated entities that may be subject to the rule covered under this 

ICR.

(b) Public Notice Required Prior to ICR Submission to OMB

On May 2, 2011 the EPA published a notice in the Federal Register (76 FR 24476) entitled,

Agency Information Collection Activities: Proposed Collection; Comment Request; National 

Volatile Organic Compound Emission Standards for Aerosol Coatings. The purpose of the notice 

was to announce that the EPA was planning to submit this continuing ICR to OMB for review 

and approval, and to solicit comments on the proposed continued collection. The EPA received 

no comments during the comment period.

(c) Consultations

Significant input and information was received from the affected industry, State and local 

governments, and environmental groups during development of the rule. In addition, in preparing 

to submit this ICR to OMB for renewal, the EPA contacted parties within the affected industry to 

obtain information on the universe of affected sources and feedback on accuracy of the burden 

estimates.

Table 1.

CONSULTATIONS

Dave Darling National Paint and Coatings Association

Heidi McAuliff National Paint and Coatings Association

Clark Ferris Perry Chemical Manufacturing

Mark Kruzer Sherwin Williams

(d) Effects of Less Frequent Collection

This ICR rule includes the minimum requirements needed to demonstrate compliance 

with the rule. The proposed rule requested comment on the feasibility and need for a requirement 

for regulated entities to submit to the Agency their VOC formulations for each product or 

product formulation in the initial report and on a periodic basis thereafter. Numerous 

commenters provided input on the need, or lack of need, for additional reporting requirements, in 

general, and the annual reporting of formulation data, in particular. Some commenters, mostly

aerosol industry representatives, contended that no additional periodic reporting was warranted. 

Others, particularly regulatory agencies and environmental groups, stated their belief that the rule 
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is not enforceable without additional reporting. Based on this input, and the EPA’s own review, 

the EPA has determined that initial reporting of formulation data and ongoing reporting on a 

triennial basis are needed. The initial reporting is needed to ensure that the rule is implementable 

as a practical matter. The triennial reporting will enable the EPA to better assess the efficacy of 

the reactivity-based approach, including the manner in which the programs requirements are 

being achieved.

(e) General Guidelines

This ICR adheres to the guidelines for Federal data requesters, as provided at 

5 CFR 1320.6. Initial notifications and reports, as described in this information collection 

request, are necessary to enable the Administrator to determine if the standards are being 

achieved. The emission standards require an initial notification report from all regulated entities 

to the EPA 90 days before the compliance date. The regulated entity is required to maintain 

compliance calculations for each of its aerosol coatings formulations. Records of these 

calculations must be maintained 5 years after the product is manufactured, processed, distributed 

for wholesale, or imported for sale or distribution in interstate commerce in the United States. 

The retention of records for 5 years would allow the EPA to establish the compliance history of a 

regulated entity and any pattern of compliance for purposes of determining the appropriate level 

of enforcement action. Historically, the EPA has found that the most flagrant violators frequently 

have violations extending beyond the 5 years. The EPA would be prevented from pursuing the 

worst violators due to the destruction or nonexistence of records, if records were retained for less 

than 5 years. Triennial reports of formulation and usage data are also required, as discussed 

above.

(f) Confidentiality

All information submitted to the EPA for which a claim of confidentiality is made will be 

safeguarded according to the EPA 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 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979). 

(g) Sensitive Questions

This section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondent/NAICS Codes

Respondents to this information collection are manufacturers, distributors, and importers 

of aerosol coatings. These regulated entities fall within the North American Industry

Classification System (NAICS) Code 32551, "Paint and Coating Manufacturing" and NAICS 

Code 325998 "All Other Miscellaneous Chemical Production and Preparation Manufacturing". 
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(b) Information Requested

(i) Data items. Regulated entities are required to maintain records of the following 

at the location specified in §59.511 (a)(4)for each product subject to the product-weighted 

reactivity limits:

Recordkeeping

 Product category;

 All product calculations;

 The product-weighted reactivity;

 Weight fraction of all ingredients including water, solids, each VOC, and 

any compounds assigned a reactivity factor of zero, as specified in §59.505.

 A copy of each notification submitted, the documentation supporting each 

notification, and a copy of the label for each product.

Reporting

 Initial report (including small quantity manufacturer exemption requests);

 Supplemental report; 

 Variance application; and

 Triennial report.

(ii) Respondent activities. 

The respondent activities required for all manufacturers and importers of regulated products are 

listed in Tables 2 and 3. Both new and existing sources must read the rule and understand the 

rule requirements. Respondents must also submit notifications and supplemental reports 

according to the requirements specified in the rule. Respondents must submit triennial reports of 

formulation and usage data. Each source must maintain all applicable records for 5 years.

5. The Information Collected—Agency Activities, Collection Methodology, and 

Information Management 

(a) Agency Activities.

A list of Agency activities is provided in Tables 4 and 5.

 (b) Collection Methodology and Management.

Reports submitted to the Agency and records maintained by the regulated entities may be 

tabulated and published for use in compliance and enforcement programs.

(c) Small Entity Flexibility.

The EPA has included a small quantity manufacturer exemption. This exemption is 

targeted to particularly small entities that would otherwise bear particularly high costs for 

compliance relative to the small amount of products they produce and, therefore, the small 
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amount of total VOC emissions from such products. In addition, there are provisions that allow 

facilities additional time to develop compliant products if they have not previously developed 

products to meet the limits of the California Air Resource Board aerosol coating rule, which 

contains identical limits to the EPA’s final rule. The EPA maintains that the majority of facilities 

that would qualify for this extended compliance time would likely be small entities. Finally, 

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.

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is 

shown in Table 2. 

6. Estimating the Burden and Cost of the Collection

Tables 2 through 5 document the individual burden items for the recordkeeping 

requirements resulting from the ICR. The individual burdens are expressed under standardized 

headings 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. 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.

(a) Estimating Respondent Burden.

The average annual burden estimates for reporting, recordkeeping, and labeling 

requirements are presented in Tables 2 and 3 for all manufacturers. These numbers were derived 

from estimates based on the EPA's experience with other standards and from information 

obtained from the industry representatives listed under “Consultations”. Because this is a 

renewal of an existing ICR, these estimates represent the average annual burden that will be 

incurred by the affected industry in the 3-year period beginning October 1, 2011. The hours 

shown in column A of Table 2 are the burden estimate per manufacturer.

(b) Estimating Respondent Costs.

(i) Estimating Labor costs.

Tables 2 and 3 also presents estimated costs for the required recordkeeping and reporting 

activities. Industry labor rates are based on an average of occupational wage rates for the affected 

NAICS groupings 3256 and 3259 (from the United States Department of Labor, Bureau of Labor 

Statistics, 2010, http://data.bls.gov/oes/search.jsp?data_tool=OES). Management wages were 

based on industrial production managers, technical wages were based on health and safety 

engineers, and clerical rates were based on production, planning, and expediting clerks. The 

resultant average wage rates were: management ($45.99); technical ($37.60); and clerical 
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($21.19). To estimate the actual labor costs to be used in Table 2, an overhead of 125 percent 

was added to the raw labor rates resulting in the following loaded labor rates: management 

($103); technical ($85); and clerical ($48). There are no capital or O&M costs associated with 

the ICR.

 Labor rates and associated costs are based on the hourly rates estimated above in 

paragraph 6(b) as follows: $48 for clerical personnel, $85 for technical personnel, and $103 for 

management personnel. For the estimated industry burden, the number of clerical hours is 

assumed to equal 10 percent of the number of technical hours (see Table 2). For the estimated 

government burden, the number of management hours is assumed to equal 5 percent of the 

number of technical hours and the number of clerical hours is assumed to equal 10 percent of the 

number of technical hours (see Table 4 ).

(ii) Estimating Capital/Startup and Operation and Maintenance Costs. No capital/startup and 

operation and maintenance costs are associated with this rulemaking. 

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs. No capital/startup and 

operation and maintenance costs are associated with this rulemaking.

(c) Estimating Agency Burden and Cost

 Because the information collection requirements were estimated as an incidental part of 

the standard development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of 

respondents are required under section 183(e) of the Act, no operational costs will be incurred by 

the Federal government. Examination of records to be maintained by the respondents will occur 

incidentally as a part of the periodic inspection of sources that is part of the EPA's overall 

compliance and enforcement program and is not attributable to this ICR. The only costs that the 

Federal government will incur are costs associated with the review of reported information, as 

presented in Tables 4 and 5. 

(d) Estimating the Respondent Universe and Total Burden Costs

The following assumptions were used to determine the respondent universe and 

total burden and costs for industry to comply with the various requirements of the rule:

 The total number of regulated entities in Year 1 will be 63;

 Assumes 10 percent of respondents will request a variance.

 Assumes each respondent will have one incident per year that will require 

supplemental reporting (also referred to as a “notice of change” report)

 Total number of respondents in Year 2 will be 64 and in Year 3 will be 65.

 Same 10% requesting a variance;

 Assumes each respondent will have one incident per year that will require 

supplemental reporting
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 Assumes each respondent will maintain records on 37 formulations (average for 

industry).

 Assumes 9 respondents per year will be required to respond to enforcement 

questions, or other Agency requests for information.

 Assumes each respondent will submit a triennial report of formulations and VOC 

usage.

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent Tally

The bottom line respondent burden hours and cost for years 1 and 2, presented in Table 2, 

are calculated by summing all total costs for the reporting activities and the total costs for the 

recordkeeping activities. The annual burden and costs are 9,478 hours and $786,475.

The bottom line respondent burden hours and cost for Year 3, presented in Table 3, are 

calculated by summing all total costs for the reporting activities and the total costs for the 

recordkeeping activities. The annual burden and costs for year 3 are 17,838 hours and 

$1,527,927. Thus, the annual average burden equals the sum of the burden hours in Years 1 

(9,478), 2 (9,478), and 3 (17,838), divided by 3, or 12,265 and the cost of years 1 and 2 

($786,475 each year) and year 3 ($1,527,927) divided by 3, or $1,033,626.

(ii) Agency Tally

The bottom line Agency burden and costs are presented in Tables 4 and 5. The average 

annual cost to the federal government is $81,795 ($48,582 year 1, $48,582 year 2, $148,222 year 

3).

(iii) Variations to the annual bottom line.

The EPA anticipates that the annual burden after Year 3 will be equal to the burden in 

Year 2 for 2 of every 3 years and equal to Year 3 for 1 of every 3 years.

(f) Reasons for Change in Burden.

Year 1 and 2 burden estimates include an initial number of respondents that will be 

required to perform recordkeeping and reporting activities, and assumes 1 additional initial and 

supplemental reports will be required to be completed due to new aerosol coating product 

formulations being introduced into the market, or changes in existing aerosol coatings 

formulations. Beginning in Year 3, triennial reports will be submitted, increasing the burden for 

those years where a report is due.

(i) Agency Tally

The bottom line Agency burden and costs are presented in Tables 4 and 5. The average 

annual cost to the federal government is $81,795.

(ii) Variations in the annual bottom line. 
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No significant variations in the annual respondent burden or cost are expected over the 3-

year period beginning on October 1, 2011.

(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 133 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 currently valid OMB control number. The 

OMB control numbers for the 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, the EPA has established a public docket for this ICR 

under Docket ID Number EPA-HQ-OAR-2006-0971, 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 

Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 

8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number 

for the Reading Room is (202) 566-1744, and the telephone number for the Air and Radiation 

Docket and Center is (202) 566-1742. An electronic version of the public docket is available at 

www.regulations.gov. This site can be used to submit or view public comments, access the index 

listing of the contents of the public docket, and to access those documents in the public docket 

that are available electronically. When in the system, select “search,” then key in the Docket ID 

Number identified above. Also, you can send comments to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 

20503, Attention: Desk Officer for the EPA. Please include the EPA Docket ID Number EPAHQ-OAR-2006-0971 and OMB Control Number 2060-0617 in any correspondence.
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Table 2.Industry Recordkeeping & Reporting Costs

(D)

(A) (B) (C) (E) (F)

Burden Item Person 

Hours per 

Occurrence

NOTES Number of 

Occurrences 

per 

Respondent 

per Year

NOTES Person 

Hours per 

Respondent 

per Year

Dollars 

per 

Hour

Person 

Hours/Respondent

(clerical)

(D=.1 x tech 

hours)

Respondents 

per

NOTES Total Hours 

per Year

Total

(C=AxB) Year (F=(C+D)xE) Cost in 

Year 1 ($)

Reporting

 Read instructions 4 1 4 103 1 a 4 412

 Gather information 4 1 4 85 .4 1 a 4.4 359

 Initial report (incl. small quantity manufacturers) 25.25 1 25.25 85 .4 1 b 25.65 2,631

 Supplemental report 4 1 4 85 .4 63.5 279 22,809

 Variance or compliance extension application 24 1 24 103 0.1 a 2.4 247

 Responding to the EPA request for data 60 1 60 103 9 540 55,620

Recordkeeping

 Read instructions (above)

 Plan activities 16 1 16 103 1 a 16 1,648

 Calculation of reactivity 0.5 c 37 d 18.5 85 1.85 11 b 224 18,274

 Maintenance of batch information 0.250 e 481 120 85 12 63.5 f 8382 684,276

Total Industry Burden- complying with rule

9478

$ 

786,276

Additional Burden- variance $ 

199 
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TOTAL INDUSTRY BURDEN- Year 1 and 2 each 9478 $ 

786.475

NOTES: Average for first year of existing manufacturer 149

a- Assumes up to 1 new aerosol coating manufacturers each year. Same 10% requesting variance

Average in Year 2 for new manufacturer (same as Year 

1 for existing) 149

b- Assumes 10 manufacturers add new coating category each year Average cost per respondent 149 $12,385

c- Same average time for calculating formulations for new category.

d- Uses average of all existing manufacturers. Likely to be an overestimate for both new manufacturers and for 

existing manufacturers adding a new coating category

e- Same estimate as Year 1 for existing manufacturers.

f- 60 existing manufacturers plus 1 new 
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Table 3. Respondent Cost in Year 3 and Average for First 3 Years

(A) (B) (C) (D) (E) (F)

Burden Item Person 

Hours 

per 

Occurren

ce

NOT

ES

Number 

of 

Occurren

ces per 

Respond

ent per 

Year

NOT

ES

Person 

Hours 

per 

Respond

ent per 

Year

Dolla

rs 

per 

Hour

Person

Hours/Respon

dent

(clerical)

(D=.1 x tech 

hours)

Respondents per NOT

ES

Total 

Hours per 

Year

Total

(C=AxB) Year (E=(C+D) 

x F

Cost in Year 

1 ($)

Reporting

 Read instructions 4 1 4 103 1 a 4 412

 Gather information 4 1 4 85 .4 1 a 4.4 359

 Initial report (incl. small quantity 

manufacturers)

25.25 1 25.25 85 .4 1 b 25.65 2,165

 Supplemental report 4 1 4 85 .4 65 286 23,348

 Variance or compliance extension 

application

24 1 24 103 0.1 a 2.4 247

 Responding to the EPA request 

for data

60 1 60 103 9 540 55,620

For triennial report

 Establish account for NEI 2 1 2 85 .2 65 143 11,674

 Enter general information into 

database

0.5 1 0.5 85 .1 65 39 3,075

 Enter product formulations into 

database

0.25 37 9.25 85 .925 65 661 53,992
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 Enter company wide volumes of 

coating constituents into database

2 1 2 85 .2 65 143 11,674

Recordkeeping

 Read instructions

 Plan activities 16 1 16 103 1 a 16 1,648

 Calculation of reactivity 0.5 c 37 d 18.5 85 1.85 11 b 244 18,274

 Maintenance of batch information 0.250 e 481 120 85 12 65 f 8580 700,440

For triennial report

 Calculate company wide volume 

usage of coating constituents

56 g 1 56 85 5.6 65 f 4004 326,872

 QA/QC and review 40 h 1 40 103 65 f 2600 267,800

 Read instructions/take training for 

reporting- support

4 1 4 85 .4 65 f 286 23,348

 Read instructions/take training for 

reporting- management

4 1 4 103 65 f 260 26,780

Total Industry Burden- complying 

with rule 17,838

$ 

1,527,728

Additional Burden- variance $ 

199 

TOTAL INDUSTRY BURDENYear 3 17,838 1,527,927

NOTES:

a- Assumes up to 2 new aerosol coating manufacturers in first 2 years (added both in Year 

2). Same 10% requesting variance Average cost per respondent 275 $23,507

b- Assumes 10 manufacturers add new coating category each year

c- Same average time for calculating formulations for new category. Average cost for triennial report per respondent 125 $11,157
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d- Uses average of all existing manufacturers. Likely to be an overestimate for both new 

manufacurers and for existing manufacturers adding a new coating category

e- Same estimate as Year 1 for existing manufacturers.

Total Year 

Costs

f- 60 existing manufacturers plus 1 new 

Average Cost for 

Year 1 149 $12,385 

$ 

786,475

g- Assumes 2 days to gather information and 2.0 hours to sum all information for each 

constituent- assumes an average of 20 different constituents used by facility

Average Cost for 

Year 2 149 $12,385

$ 

786,475

h- assumes review of all information by senior official of company

Average Cost for 

Year 3 274 $23,507 $ 1,527,927 

Average of first 3 

years 191

$ 

15,902

$ 

1,033,626
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Table 4. Government Recordkeeping & Reporting Costs Years 1 and 2 

(A) (B) (C) (D) (E) (F) (G)

Burden Item Person Hours per 

Occurrence

Number of Occurrences 

per Respondent per Year

Person Hours per 

Year @ $72 

(Technical) 

Person Hours per Year 

@ $100 (Management)

Person Hours per 

Year @ $36 

(Clerical)

Total Person 

Hours per Year

Total Cost Per 

Year ($)

(C=AxB) (D = C x 0.05) (E = C x 0.01) (F=C+D+E)

 Initial report 8 1 8 0.4 0.08 8.48 619

 Supplemental report 4 61 244 12.2 2.44 258.64 18,876

 Variance application 16 1 16 0.8 0.16 16.96 1,238

 Supplemental data 

request

40 9 360 18 3.6 381.6 27,850

Total Government Burden 72 628 31.4 6.28 665.68 $ 48,582 
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Table 5. Government Burden- Year 3- and Average for First 3 Years

(A) (B) (C) (D) (E)

Burden Item Person Hours 

per 

Occurrence

Number of 

Occurrences per 

Respondent per 

Year

Person Hours 

per Year @ $72 

(Technical) 

Person Hours per 

Year @ $100 

(Management)

Person Hours per 

Year @ $36 (Clerical)

Total Person 

Hours per 

Year

Total Cost Per 

Year ($)

(C=AxB) (D = C x 0.05) (E = C x 0.01) (F=C+D+E)

 Initial report 8 1 8 0.4 0.08 8 619

 Supplemental report 4 62 248 12.4 2.48 263 19,185

 Variance application 16 1 16 0.8 0.16 17 1,238

 Develop Database and Report 

Forms for Triennial Report

300 1 300 15 3 318 23,208

 Populate Database for triennial 

report

12 62 744 37.2 7.44 789 57,556

 QA/Review data for triennial 

report

600 1 600 30 6 636 46,416

Total Government Burden 128 1916 95.8 19.16 2,031 $ 148,222 

Year 1 665.68 $ 48,582.08 

Year 2 665.68 $ 48,582.08 

Year 3 2,031 $ 148,221.76 

Average of 3 years 1121 $ 81,795.31