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Draft Information Collection Request Supporting 

Statement 

PART A OF THE SUPPORTING STATEMENT

NATIONAL REFRIGERANT RECYCLING AND EMISSIONS REDUCTION PROGRAM

1) Identification of the Information Collection

a) Title and Number of the Information Collection

This information collection request (ICR) is titled “National Refrigerant Recycling and Emissions 

Reduction Program”, EPA ICR Number: 1626.13, Office of Management and Budget (OMB) Control 

Number: 2060-0256.

b) 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 technicians; technician certification programs; equipment testing organizations; 

refrigerant wholesalers and purchasers; refrigerant reclaimers; refrigeration and air-conditioning 

appliance owners; and other establishments that perform refrigerant removal, service, or disposal. OMB 

previously approved this collection under ICR Number 1626.12. 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.). Collection of this information was approved through December 31, 2017.
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EPA is proposing to update the existing requirements under the Program as well as extend them to 

cover appliances containing hydrofluorocarbons (HFCs) and other non-exempt substitute refrigerants. 

EPA is proposing regulatory changes that affect the reporting and recordkeeping requirements, 

including: establishing recordkeeping requirements for the disposal of appliances containing 5 to 50 

pounds of refrigerant; requiring documented leak inspections of certain refrigeration and air 

conditioning appliances; requiring testing and use of self-sealing valves on small containers of MVAC 

refrigerant; and removing outdated recordkeeping and reporting requirements.

New records that would be maintained as part of the proposal include: invoices for servicing events;

results of verification tests; annual and quarterly leak inspection reports; refrigerant removal at disposal; 

and self-sealing valve test results. New reporting requirements would include: lists of refrigerant 

recovery/recycling equipment; lists of certified technicians; and expanded opportunity to request

extensions to the appliance repair and the appliance retrofit/retirement requirements.

EPA has estimated that there are 1,050,390 annual respondents consisting of representatives from the 

air-conditioning and refrigeration and small can manufacturing community. The annual cost for 

respondents for the collection and maintenance of records, as well as reports to EPA, is estimated to 

total $35,931,685.

2) Need For and Use of the Collection

a) 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 for this rulemaking is supplemented by Section 114 which authorizes the EPA 

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

b) 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 by reducing emissions of class I and class II ozone-depleting refrigerants and their substitutes to 

the lowest achievable level during the service, maintenance, 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 recovery, recycling, and reclamation processes.

Some recordkeeping requirements are to facilitate information sharing between regulated entities to 

ensure compliance with Section 608 requirements. Owners/operators of appliances use the information
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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

a) Non-Duplication

The specific information requested is not currently collected by any other EPA office or any other 

government agency.

b) 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. 

c) Consultations

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

for the previous ICR. EPA previously consulted two refrigerant reclaimers, a refrigerant wholesaler, and 

two technician certification programs. EPA also consulted the California Air Resource Board (CARB), 

Autocare Association, and the Automotive Refrigeration Products Institute (ARPI) for the regulatory 

changes to Section 608 that are reflected in this ICR.

d) Effects of Less Frequent Collection

The proposed information collection requirements are either one-time, annual, or occasional 

submissions. All of these reporting requirements are similar to those that exist for ODS refrigerants but 

would be new for non-exempt substitute refrigerants. Additionally, EPA is proposing to remove the (1) 

one-time certification from technicians that they own certified refrigerant recovery equipment, (2) the 

annual report from programs certifying recovery and/or recycling equipment concerning the equipment 

they approve, and (3) the requirement for refrigerant recovery/recycling equipment testing 

organizations to submit information to EPA within 30 days of certification of a new model line of

refrigerant recovery/recycling equipment.
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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, allow entities flexibility in meeting regulatory requirements. The 

removal of this reporting requirement may result in non-compliance or higher costs to the entity (e.g., 

cost for expedited shipment of a necessary part). 

e) General Guidelines

The reporting and recordkeeping requirements do not violate the regulations established by OMB at 5 

CFR part 1320.5(d)(2). 

f) 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.).

g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4) Respondents and Information Requested

a) 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.
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Table 1: NAICS Codes of Potentially Affected Respondents

Industry Category NAICS Codes 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

Durable Goods Wholesalers and Dealers 423 Merchant Wholesalers - Durable Goods

441 Motor Vehicle and Parts Dealers

Educational Services 611 Educational Services

Food Manufacturing 311 Food Manufacturing

General Merchandise Stores 452 General Merchandise Stores

453998 All Other Miscellaneous Store Retailers (except 

Tobacco Stores) 

Grocery and Specialty Food Stores 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

Non-food Manufacturing 322 Paper Manufacturing

323 Printing and Related Support Activities

324 Petroleum Manufacturing

325 Chemical Manufacturing

3254 Pharmaceutical Manufacturing

326 Plastics and Rubber Manufacturing

332 Metals Manufacturing

333 Machinery Manufacturing

334 Computer and Electronic Product Manufacturing

336 Transportation Equipment Manufacturing

3391 Medical Equipment and Supplies Manufacturing
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Industry Category NAICS Codes NAICS Code Definition

339999 Miscellaneous Manufacturing 

Office Buildings 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

Other Warehousing, Storage, and 

Transportation

48 Transportation and Warehousing

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

221 Utilities

Warehouse Clubs and Supercenters 452910 Warehouse Clubs and Supercenters 

Reclaimers 325120 Industrial Gas Manufacturing

423930 Recyclable Material Merchant Wholesalers

562920 Materials Recovery Facilities

562212 Solid Waste Landfill

424690 Other Chemical and Allied Products Merchant 
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Industry Category NAICS Codes NAICS Code Definition

Wholesalers

Refrigerant Wholesalers 325120 Industrial Gas Manufacturing

424690 Other Chemical and Allied Products Merchant 

Wholesalers

42 Wholesale Trade

Service Technicians 238220 Plumbing, Heating, and Air-conditioning Contractors

Disposal Establishments 562920 Materials Recovery Facilities

562212 Solid Waste Landfill

423990 Other Miscellaneous Durable Goods Merchant 

Wholesalers

Service Establishments 811310 Commercial Industrial Machinery and Equipment 

(not Automotive and Electronic) Repair and 

Maintenance

811412 Appliance Repair and Maintenance

Small Can Manufacturers 441310 Automotive Parts and Accessories Stores

325120 Industrial Gas Manufacturing

Certifying Organizations 541380 Environmental Test Laboratories and Services

b) Information Requested

All records pursuant to this ICR must be available onsite at the respondents' place of business for a 

minimum of three years. Entities may submit reports electronically to 608reports@epa.gov or 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. 

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:
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 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.

 Annual list of certified refrigerant recovery/recycling equipment.

 Notice of when a model of refrigerant recovery/recycling equipment fails a three-year recertification 

test.

ii) Respondent Activities

 Prepare and submit an application for refrigerant recovery/recycling equipment testing approval.

 Retain records of recovery/recycling equipment testing and performance and refrigerant 

recovery/recycling equipment that meets EPA standards.

 Notify EPA within 30 days of retesting or inspection if equipment previously certified fails the 

periodic re-test required by the regulation.

 Publish online a list of all certified equipment that includes the name of the manufacturer and the 

name or serial number of the model line and update the list annually.

2. 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;
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 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 reclaimed refrigerant meets the necessary 

specifications.

 Records on the quantity of material sent for reclamation, the amount reclaimed, waste products 

from the reclamation process, and customer and sales records.

 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 certify that they will meet the requirements of 40 CFR 82.164. 

 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.

 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, the quantity, and 

that the purchaser is a certified technician (as applicable).

ii) Respondent Activities

 Retain invoices from refrigerant sales.
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4. Technician Certification Programs

The data items required by technician certification programs are specified in 40 CFR 82.161(b).

i) Data Items

 Application for technician certification approval by EPA. 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 technician 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 

 Date each certification was completed.

 Biannual (2x/year) reports on pass/fail rates and the next year’s testing schedule.

ii) Respondent Activities

 Prepare and submit application for technician certification.

 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.

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

 Prepare and send certification cards to technicians who pass the exam.

 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
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 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 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 40 CFR 82.161(a)(4).

i) Data Items

 Proof of technician certification.

 Leak inspection records.

 Service invoices to owners/operators.

 Records for the disposal of field-installed appliances with charges between 5 and 50 pounds which 

include: the company name, location of equipment, date of recovery, the quantity and types of 

refrigerant recovered, and the quantity and types of refrigerant ultimately transferred for 

reclamation or destruction.

ii) Respondent Activities

 Complete a certification test.

 Maintain a copy of certification at their place of business. 

 When servicing appliances containing 50 or more pounds of refrigerant: prepare service invoices 

with information on the identity and location of the appliance, the date and type of service 

performed, the quantity and type of refrigerant added, the full charge of the system, and the leak 

rate. The technician must provide such service invoices to owners/operators with each servicing 

event.

 Prepare the appropriate records when disposing of field-installed appliances with charges between 

5 and 50 pounds.

7. Owners/Operators of Appliances with Charge Sizes of 50 or More Pounds

The data items required by owners/operators of appliances containing 50 or more pounds of refrigerant 

are specified in 40 CFR 82.157(l) and (m).

i) Data Items
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 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, the full charge of the system, and the leak rate. Typically these are provided by 

the technician with each servicing event.

 Records on either:

 Quarterly leak inspections for appliances with 500 or more pounds or refrigerant and/or annual 

leak inspections for appliances with 50 to 500 pounds of refrigerant; or

 Installation of an automatic leak detection system and annual inspections and recalibrations.

 Records of verification tests on repairs conducted when the leak rate is exceeded.

 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; 

 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.
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 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 steam; 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.

 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). 

 Maintain a copy of requests for extensions to the 30-day repair timeline or the one-year 

retrofit/retire timeline.

 Maintain records on mothballed appliances.

 Notify EPA when excluding purged refrigerants that are destroyed from annual leak rate 

calculations.

 Maintain records on purged or destroyed refrigerant.

8. Small Can Manufacturers

The data items for small can manufacturers are specified in 40 CFR 82.154(c)(2).

i) Data Item

 Log forms of results from self-sealing valve testing.

ii) Respondent Activities

 Conduct tests on self-sealing valves on products.

 Prepare and retain records of results from self-sealing valve tests.
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5) Information Collected - Agency Activities, Collection 

Methodology, and Information Management

a) Agency Activities

EPA activities associated with the review of the reports and recordkeeping requirements for the 

Program consist of reviewing the following: 

 Extension requests from owners/operators of commercial refrigeration, comfort cooling, and 

industrial process refrigeration appliances. 

 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; 

 Reports submitted by approved technician certification programs; and 

b) Collection Methodology and Management

EPA has not developed reporting or application forms, although it has a sample form to facilitate 

recordkeeping by small can manufacturers (insert reference to form). Entities are encouraged to submit 

the required information in an electronic format to 608reports@epa.gov. The information submitted by 

each member of the regulated community will be stored at EPA headquarters for review and reference. 

c) 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 of the facts 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. 
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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. 

d) Collection Schedule

Information collection is required as of (date). 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.

 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.

 Effective January 1, 2018, programs certifying technicians, excluding federally-run programs, must 

create and maintain a publicly-searchable database of technicians they have certified. The database 

must include all technicians certified after January 1, 2017.

 If a refrigerant reclaimer changes ownership, the new owner must certify with EPA within 30 days of 

the change of ownership.

 Owners/operators must prepare a retrofit or retirement plan within 30 days of:

 Discovering a leak greater than the applicable threshold leak rate; 

 Making good faith efforts to repair leaks but before finishing a follow-up verification test; or

 After a failed follow-up verification test.

 Owners/operators 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 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.
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6) Estimating the Burden and Cost of the Collection

This section provides burden 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 the those activities; 

 Universe of estimates; and 

 Calculated burden and cost totals.

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

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

a) 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. The 

overall reporting and recordkeeping burden as a result of the proposed rule is higher compared to 

previous ICRs because 1) the universe of reporters has expanded to include owners/operators and 

technicians who service equipment containing HFC- and other non-exempt substitute refrigerantcontaining appliances and 2) new requirements to document the disposal of mid-sized comfort cooling 

and commercial refrigeration appliances. There are also new requirements related to leak inspection, 

disposal, and self-sealing valves. All burden hours and costs presented here are annual. 

b) 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 
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overhead costs. EPA estimates the average annual respondent hourly cost (labor plus overhead) for all 

affected entities below. In deriving these costs, EPA used the median hourly rate of $21.46 for heating, 

air-conditioning, and refrigeration mechanics and installers1and a median hourly rate of $13.74 for 

weighers, measurers, checkers, and samplers2from the Bureau of Labor Statistics. EPA then multiplied 

these numbers by 110% for overhead. The resulting costs of $45.07 (for heating, air-conditioning, and 

refrigeration mechanics and installers) and $28.85 (for weighers, measurers, checkers, and samplers) are 

the average hourly administrative cost of labor plus overhead for private firms. The cost for weighers, 

measurers, checkers, and samplers is applicable only to small can manufacturers.

ii. Estimating Capital 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 ICR 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.” 

The following tables summarize the annual respondent burden and cost by respondent type and 

reporting and recordkeeping requirement.

 

1

Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment and Wages, May 2014, Heating, 

Air-conditioning, and Refrigeration Mechanics and Installers, on the Internet

at http://www.bls.gov/oes/current/oes499021.htm (visited July 13, 2015).

2

Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment and Wages, May 2014, 

Weighers, Measurers, Checkers, and Samplers, Recordkeeping, on the Internet at 

http://www.bls.gov/oes/current/oes435111.htm (visited July 30, 2015).
18

1. Refrigerant Recovery/Recycling Equipment Testing Organization

Annual Respondent Burden

Collection Activities Burden Hours Labor Costs/Entity

Publish list of all certified equipment that includes the name of 

the manufacturer and the name or serial number of the model 

line online

0.08 $3.76

Maintain records of refrigerant recovery/recycling equipment 

tested and its performance 0.125 $5.63

Each of the two refrigerant recovery/recycling equipment testing and certifying organizations approved 

by EPA are estimated to spend 5 minutes each year publishing a list of all certified equipment online. 

Each refrigerant recovery/recycling equipment testing and certifying organizations are also expected to 

spend 1/8 hour maintaining records of the tests as a part of normal business practices.

2. Refrigerant Reclaimers

Annual Respondent Burden

Collection Activities Burden Hours Labor Costs/Entity

Annual activity report 9.4 $422.23

Reclaimer recordkeeping 11.7 $527.79

Maintain records that analysis conducted to verify that 

reclaimed refrigerant meets the necessary specifications 4.3 $195.29

Certification by refrigerant reclaimers that change ownership 

or enter the market 5.0 $225.33

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

Reclaimers must 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.4 

 

3

In the previous ICR, the burden for preparing the annual activity report was 5.0 hours for ODS appliances only. 

The recordkeeping burden was scaled to include appliances containing HFCs and other non-exempt refrigerants 

based on the inventory of equipment. 

4

In the previous ICR, the burden for maintaining records was 0.125 hours for ODS appliances only. The 

recordkeeping burden was scaled to include appliances containing HFCs and other non-exempt refrigerants based 
19

Therefore, each reclaimer will spend 11.7 hours maintaining records annually. 

Reclaimers must also 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. Therefore, each reclaimer will spend approximately 4.3 hours maintaining 

records annually. 

Based on experience from previous years, EPA estimates that four reclaimers will submit one-time

applications for certification. Each submission is estimated to take 5 hours. 

3. Refrigerant Wholesalers

Annual Respondent Burden

Collection Activities Burden Hours Labor Costs/Entity

Recordkeeping for refrigerant sales, including 

maintenance of technician certification cards from 

purchasers employing at least one certified technician

1.55 $69.67

EPA estimates that each refrigerant wholesaler must spend approximately four minutes 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).5EPA estimates that each refrigerant wholesaler 

performs 25 recordkeeping actions per year, or 1.55 annual burden hours. 

4. Technician Certification Programs

Annual Respondent Burden

Collection Activities Burden Hours Labor Costs/Entity

Technician certification programs applying for approval 5.0 $225.33

Maintain list/database of technicians certified 0.17 $7.51

Biannual reporting by existing certification programs 2.0 $90.13

Recordkeeping by existing certification programs 5.0 $225.33

EPA estimates that it will take five hours for new organizations to compile the necessary information to 

apply for the certification program approval. 

 

on the inventory of equipment.

5

In the previous ICR, the burden for maintaining records was 0.125 hours for ODS appliances only. The 

recordkeeping burden was scaled to include appliances containing HFCs and other non-exempt refrigerants based 

on the inventory of equipment.
20

Technician certification programs are required to publish online a list or database 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 five 

minutes publishing online lists and one hour completing each report. EPA expects programs to publish 

lists and complete reports twice a year. EPA estimates that each technician certification program spends 

five hours annually maintaining records on each technician certified through their programs. 

5. Disposal Establishments

Annual Respondent Burden

Collection Activities Burden Hours Labor Costs/Entity

Maintenance of copies of signed statements of previous 

refrigerant recovery by disposal establishments 13.0 $585.86

Disposal establishments spend an estimated three 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. 

6. Technicians

Annual Respondent Burden - Certification

Collection Activities Burden Hours Labor Costs/Entity

Maintain certification cards 0.017 $0.75

Acquire certification cards 0.017 $0.75

EPA estimates that approximately 10 percent of the estimated 300,000 technician labor force turns over 

each year, necessitating certification. EPA estimates that each technician will spend one minute 

maintaining a copy of the certification card. 

Annual Respondent Burden - Preparing and Maintaining Records

Collection Activities Burden Hours Labor Costs/Entity

Prepare and provide invoices for serviced appliances with 

charge sizes 50 to 500 lbs. 0.14 $6.35

Prepare and provide invoices for serviced appliances with 

charge sizes >500 lbs. 0.12 $5.48
21

Maintain leak inspection records 0.13 $5.92

Maintain disposal records for appliances with charge sizes of 5 

- 50 lbs. 0.41 $18.26

Technicians servicing ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with 

charge sizes of 50 or more pounds are required to provide records of the following: the identity and 

location of the appliance, the date and type of service performed, the quantity and type of refrigerant 

added, the full charge of the system, and the leak rate. EPA estimates that appliances containing 50 to 

500 pounds of refrigerant will be serviced annually and that appliances with 500 or more pounds will be 

serviced quarterly. EPA estimates that each technician will provide eight invoices a year, spending two 

minutes preparing and one minute maintaining each record.6

Technicians disposing of field-installed appliances with charge sizes between 5 and 50 pounds are also 

required to maintain records on: the quantity and types of refrigerant recovered at disposal; the 

quantity and type of refrigerant transferred for reclamation or destruction; the company name; and 

date. EPA estimates that technicians spend one minute per record and will dispose of an average of 24 

pieces of equipment each year. 

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 $22.53

Prepare and submit requests for extension to 1-year 

retrofit/retire timeline 0.5 $22.53

Owners/operators of IPR, comfort cooling, or commercial refrigeration appliances that contain more 

than 50 lbs. of ODS or HFC 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. 

Annual Respondent Burden - Recordkeeping

Collection Activities Burden Hours Labor Costs/Entity

Maintain information on purged/destroyed refrigerant 0.025 $1.13

Develop/maintain plan to retire/replace or retrofit appliances 8.0 $360.53

 

6

In the previous ICR, EPA had assumed a burden of 1.5 minutes to provide invoices. In this ICR, EPA assumes an 

additional burden of 0.5 minutes for documenting the additional information required. 
22

Maintain purchase and service records 0.11 $4.91

Maintain leak inspection records 0.073 $3.27

Maintain reports on the results of verification tests for repairs 

to systems that exceed the leak rate threshold 0.025 $1.13

EPA estimates that owners/operators of appliances normally containing 50 or more pounds of 

refrigerant spend 1.5 minutes maintaining information on purged and destroyed refrigerant. Owners/

operators planning to retire/replace or retrofit appliances spend eight hours on developing or 

maintaining a plan. EPA estimates that one percent of HFC appliances will necessitate a plan. EPA has 

adjusted the number of expected retirements to account for more extensions to the repair timeline. 

Owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing appliances with 

charge sizes of 50 or more pounds are required to maintain records of the following for each refrigerant 

addition: the identity and location of the appliance, the date and type of service performed, the quantity 

and type of refrigerant added, the full charge of the system, and the leak rate. EPA estimates an average 

annual burden of approximately 6.5 minutes per owner/operator. 

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 and that each 

owner/operator will maintain approximately five records. EPA estimates that 1.5 minutes is required to 

maintain reports on the results of verification tests any time the leak threshold is exceeded. 

8. Small Can Manufacturers

Annual Respondent Burden - Reporting

Collection Activities Burden Hours Labor Costs/Entity

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

for 3 years 0.30 $8.66

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. 

c) 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 the number of respondents for established refrigerant recovery/recycling equipment 

testing organizations; averages for the number of service establishments, disposers, and refrigerant 
23

reclaimers that enter the market or change ownership; refrigerant wholesalers; technician certification 

programs; technicians acquiring certification and maintaining certification cards; 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.7A 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 regulations 

during May 1993. Based on past experience, EPA does not anticipate that additional entities will 

apply to become approved refrigerant recovery/recycling equipment testing organizations.

 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 believes that the number of establishments that sell refrigerant has 

remained the same over the past few years. This ICR assumes that the number of wholesalers has 

remained at 200,000.

 Technician Certifying Programs: EPA currently has 88 certified technician certifying programs. Based 

on EPA's experience, EPA estimates five new organizations per year will submit materials to EPA 

requesting that they be authorized to test and certify technicians. 

 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:8

 

7

See Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to 

National Recycling and Emission Reduction Program. August 2015. Available at: [insert docket location]

8

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. For more detail on the methodology and modeling approach, please see: 

Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to National 

Recycling and Emission Reduction Program. August 2015. Available at: [insert docket location]
24

 Based on actual submissions to EPA, the Agency estimates that four owners/operators of 

comfort cooling, commercial refrigeration, and industrial process refrigeration appliances with 

charge sizes greater than 50 lbs. 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 accounts for additional requests expected due to fewer 

comfort cooling and commercial refrigeration appliance retirements and retrofits occurring 

associated with the allowing extensions for non-federal ODS comfort cooling and commercial 

refrigeration appliances and HFC-containing appliances. EPA estimates that 4,556 owners/

operators of ODS and HFC appliances will prepare and submit request for extensions each year.

 61 owners/operators of appliances with a charge size of 50 or more pounds 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 (ODS and HFC appliances), and IPR (HFC 

appliances). 

 EPA estimates that 4,092 owners/operators will develop and maintain the required appliance 

retire/retrofit report on-site at their place of business. EPA assumes that fewer retrofits/

retirements will now occur due to the availability of extension requests.

 EPA estimates that 542,729 owners/operators of appliances with charge sizes of 50 or more 

pounds 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 385,322 events that would exceed the leak rate threshold in IPR, 

comfort cooling, and commercial refrigeration appliances. 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.

 Small Can Manufacturers: There are an estimated 10 manufacturers of small cans of refrigerant that 

need to comply with the self-sealing valve requirements.9

 

9

See Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to 

National Recycling and Emission Reduction Program. August 2015. Available at: [insert docket location]
25

For the entities that may be subject to the proposed regulatory actions, an estimated 950,500 are small 

businesses. Additional information on small business impacts can be found in the Technical Support 

Document.10

d) Estimating Agency Burden and Cost

The hourly rate for EPA staff at the GS-13 Step 1 level is $35.03 per hour. This hourly basic rate is from 

the 2015 GS salary schedule listed in the Federal Wage Page of the Office of Personnel Management 

website http://www.opm.gov/oca. 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 $56.05 ($35.03 × 1.6).

EPA has used past experience and reporting data in addition to estimates from the affected community 

in determining the number of respondents for which the Agency would assume the burden of review or 

response. The following paragraphs describe the amount and degree of burden endured by EPA review 

of required respondents’ reports.

 Refrigerant Reclaimers: EPA currently has 61 certified refrigerant reclaimers who 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 four new refrigerant reclaimers per year will submit 

one-time 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: EPA currently has 88 certified technician certifying programs. Each 

program is required to submit biannual activity reports to EPA. EPA will spend one hour reviewing 

each biannual activity report, for a total of 176 hours per year. 

Based on EPA's experience, the Agency expects to certify five 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. 

 Owners/Operators: EPA estimates that it takes one-half hour to review and make a determination 

on each of the anticipated 4,556 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 2,278 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 

 

10 Technical Support Document: Analysis of the Economic Impact and Benefits of Proposed Revisions to National 

Recycling and Emission Reduction Program. August 2015. Available at: [insert docket location]
26

appliances for an extension to the one-year retrofit requirement under the leak repair 

requirements, for a total of 61 hours a year. 
27

e) 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.

i) Respondent Tally

Table 2 and Table 3 summarize total annual respondent burden and cost by respondent type and activity.

Table 2: Total Annual Respondent Reporting Burden and Costs

Respondent Type Activity Number of 

Respondents

Number of 

Responses 

per 

Respondent

Burden 

Hours per 

Response

Annual 

Burden 

Hours

Annual 

Labor Costs

Owners/ Operators 

of Appliances with 

Charge Sizes of 50 or 

More Pounds

Prepare and submit requests for extensions to 30-day 

repair timeline 4,556 1 0.50 2,278 $102,663

Prepare and submit requests for extensions to 1-year 

retrofit/retire timeline 61 1 0.50 30 $1,366

Refrigerant 

Reclaimers

Reclaimer annual activity report 61 1 9.37 572 $25,756

Certification by Refrigerant Reclaimers that Change 

Ownership or Enter the Market 4 1 5.00 20 $901

Refrigerant 

Recovery/ Recycling 

Equipment Testing 

Organizations

Publish online list of all certified equipment 2 1 0.08 0.17 $8

Technician 

Certification 

Programs

Applying for approval 5 1 5.00 25 $1,127

Maintain list/database of technicians certified

88

2 0.08 15 $661

Biannual reporting by existing technician certification 

programs

2 1.00 176 $7,932

SUBTOTAL varies varies varies 3,116 $140,414
28

Table 3: Total Annual Respondent Recordkeeping Burden and Costs

Respondent Type Activity Number of 

Respondents

Number of 

Responses 

per 

Respondent

Burden 

Hours per 

Response

Annual 

Burden 

Hours

Annual 

Labor Costs

Disposal 

Establishments

Maintenance of copies of signed statements of previous 

refrigerant recovery by disposal establishments 7,500 260 0.050 97,500 $4,393,935

Owners/ Operators

of Appliances with 

Charge Sizes of 50 or 

More Pounds

Maintain information on purged/destroyed refrigerant 4 1 0.025 0.1 $4

Develop/maintain plan to retire/replace or retrofit 

equipment, as applicable 4,092 1 8.00 32,738 $1,475,368

Maintain purchase and service records

542,729

4.35 0.025 59,080 $2,662,486

Maintaining leak inspection records 4.35 0.017 39,386 $1,774,990

Maintain reports on the results of verification tests any 

time the leak rate threshold is exceeded 385,322 1.00 0.025 9,633 $434,123

Refrigerant 

Reclaimers

Reclaimer Recordkeeping

61

50 0.23 714 $32,195

Maintain records that analysis conducted to verify that 

reclaimed refrigerant meets the necessary specifications 260 0.017 264 $11,912

Refrigerant 

Recovery/ Recycling 

Equipment Testing 

Organization

Maintain records of refrigerant recovery/recycling 

equipment tested and its performance 2 1 0.125 0 $11

Refrigerant 

Wholesalers

Recordkeeping for refrigerant sales, including 

maintenance of technician certification cards from 

purchasers employing at least one certified technician

200,000 25 0.062 309,182 $13,933,606
29

Respondent Type Activity Number of 

Respondents

Number of 

Responses 

per 

Respondent

Burden 

Hours per 

Response

Annual 

Burden 

Hours

Annual 

Labor Costs

Small Can 

Manufacturers

Maintain records of self-sealing valve test data and log 

forms for 3 years 10 12 0.025 3 $87

Technician 

Certification 

Programs

Record keeping by existing technician certification 

programs

88 1 5.00 440 $19,829

Technicians

Maintaining certification cards 

300,000

1 0.017 5,010 $225,781

Acquiring certification cards 1 0.017 501 $22,578

Persons servicing CC appliances, and IPR and CR

appliances 50-500 lbs. provide invoices to appliance 

owners/operators

4.23 0.033 42,298 $1,906,185

Persons servicing IPR and CR appliances >500 lbs. provide 

invoices to appliance owners/operators 3.65 0.033 36,475 $1,643,795

Persons servicing appliances maintain leak inspection 

records 8 0.017 39,386 $1,774,990

Technicians disposing of appliances with 5 - 50 lbs. 

refrigerant maintaining records on quantity and types of 

refrigerant recovered at disposal and the quantity and 

type of refrigerant transferred for reclamation or 

destruction

24.32 0.017 121,586 $5,479,395

SUBTOTAL varies varies varies 794,198 $35,791,271

Table 4: Total Annual Respondent Burden

Number of Respondents Number of Responses Hour Burden Labor Costs

1,050,390 24,441,490 797,314 $35,931,685
30

ii) The Agency Tally

Table 5 and Table 6 summarize total annual agency burden and cost by and activity.

Table 5: Annual Agency Burden and Cost

Activity Number of 

Respondents

Number of 

Responses per 

Respondent

Burden Hours to 

Review each 

Response

Total Annual 

Agency Hours

Total Agency 

Labor Costs 

Reclaimer annual activity report 61 1 1 61 $3,419

Certification by refrigerant reclaimers that change ownership or 

enter the market

4 1 1 4 $224

Biannual reporting by existing technician certification programs 88 2 1 176 $9,864

Technician certification programs applying for approval 5 1 2 10 $560

Owners/operators of appliances w/charge sizes of 50 or more lbs 

prepare & submit requests for extensions to 30 day repair 

timeline 

4,556 1 0.5 2,278 $127,681

Owners/operators of appliances w/charge sizes of 50 or more lbs 

prepare & submit requests for extensions to 1 year 

retrofit/retire timeline 

61 1 1 61 $3,398

SUBTOTAL 4,777 varies varies 2,590 $145,148

Table 6: Total Annual Agency Burden

Number of Respondents Number of Responses Hour Burden for Review Labor Costs

4,777 4,863 2,590 $145,148
31

Variations in the Annual Bottom Line

EPA does not anticipate a significant variation (>25%) in the annual respondent reporting 

/recordkeeping burden or cost over the course of the clearance period. Likewise, the government 

burdens and costs are not anticipated to vary significantly.

f) Reasons for Change in Burden

EPA has proposed several regulatory changes to the refrigerant management requirements under 

Section 608 of the CAA, since the previous renewal of this ICR. To minimize the harm that both ODS and 

HFC refrigerants have on the environment and to fully implement the prohibition on venting, EPA 

proposed extending existing requirements under the Program to cover appliances containing HFCs, and 

revising the rule components associated with leak repair, as well as recordkeeping and reporting. 

Further, EPA proposed that manufacturers of small cans of MVAC refrigerant install and test self-sealing 

valves to prevent the release of refrigerant to the atmosphere. EPA has also proposed to remove the 

one-time certification requirement that technicians own recovery equipment and the requirement for 

refrigerant recovery/recycling equipment testing organizations to submit annual reports. These 

regulatory changes have resulted in new requirements for reporting and recordkeeping, as well as 

removed some previous requirements. The net result is an increase in the time required to submit 

reports and maintain records in this ICR.

EPA has also adjusted costs based on updated labor rates.

g) Burden Statement 

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

range from 11 minutes to 20 hours per year for each respondent. The average reporting and 

recordkeeping burden for this collection is 0.03 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. 
32

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-OAR2015-0453, 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 

ID No. EPA-HQ-OAR-2015-0453 and OMB control number 2060-0256 in any correspondence.