1

INFORMATION COLLECTION REQUEST ( ICR 1617.07) FOR SERVICING OF

MOTOR VEHICLE AIR CONDITIONERS

SUPPORTING STATEMENT

1. Identification of Information Collection

a) Title : "Servicing of Motor Vehicle Air Conditioners"

OMB Control Number : 2060

- 0247

EPA Number : 1617.0 7

b) Short Characterization/Abstract

History. Section 609 of the Clean Air Act Amendments of 1990 (Act) provides general guidelines for motor vehicle air conditioning (MVAC) refrigerant handling and MVAC servicing. It states that “no person repairing or servicing motor vehicles for consideration may perform any service on a motor vehicle air conditioner involving the refrigerant for such air conditioner without properly using approved refrigerant recovery and/or recovery and recycling equipment (here afte r referred to as “refrigerant handling equipment”) and no such person may perform such service unless such person has been properly trained and certified

. ” In 1992, EPA developed regulations under section 609 that were published in 57 FR 3124 2 , and codifie d at 40 CFR Subpart B (§ 82.30 et seq. ). The information required to be collected under the Section 609 regulations is currently approved for use through December 31, 200 8

. This supporting statement is submitted to justify an extension of the approval of u se of this information. Pursuant to new requirements under the Paperwork Reduction Act, a notice was published in the Federal Register

on October 4, 2005 , announcing the intent to extend the renewal of this Infor mation Collection Request and requesting co mment on the renewal. Descriptions of the recordkeeping and reporting requirements mandated by section 609 and delineated in 40 CFR 82 subpart B are summarized below in this section. The chart located at the end of this document displays the

estimated cost s of these requirements.

Approved Refrigerant Handling Equipment. In accordance with Section 609(b)(2)(A), 40 CFR 82.36 requires that refrigerant handling equipment be certified by EPA or independent standards testing organization. Certification standar ds are particular to the type of equipment and the refrigerant to be recovered, and must be consistent with the Society of Automotive Engineers (SAE) standards for MVAC equipment

.

Approved independent standards testing organizations. Section 609(b)(2)(A ) of the Act requires independent laboratory testing of refrigerant handling equipment to be certified by EPA. The Stratospheric Protection Division ( SPD ) requires independent laboratories to submit an application that documents : the organization’s capacit y to accurately test equipment compliance with applicable standards consistent with the SAE standards for handling refrigerant, an absence2

of conflict of interest or financial benefit based on test outcomes , and an agreement to allow EPA access to verify a pplication information

. Once an independent laborato ry has been approved by EPA, the application is kept on file in the SPD. Two laboratories

– Underwriters Laboratories

Inc . and Intertek/ ETL Testing Laboratories

– are currently approved to test refrigera nt handling equipment. EPA does not anticipate that any organizations will apply to EPA in the future to become approved independent standards testing organizations. Therefore, annual hours and costs related to information submitted by these organizations have been eliminated.

Technician training and certification. According to Section 609(b)(4) of the Act, automotive technicians are required to be t rained and certified in the proper use of approved refrigerant handling equipment. Programs that perform technician training and certification activities must apply to the S PD for ap p roval by submitting verification that its program meets EPA standards.

Th e information requested is used by the S PD to guarantee a degree of uniformity in the testing programs for motor vehicle service techni cians.

Due to rapid developments in technology, the Agency requires that each approved technician certification program conducts periodic reviews and updates of test material, submitting a written summary of the review and program changes to EPA every two years (as per 40 CFR §82.40 (c))

. After the test has been approved by EPA, a hard copy remains on file with

S PD. Curren tly, 19 t esting programs are approved by EPA to train technicians in the proper use

of refrigerant handling equipment. Five of these programs are designed specifically for individual company’s own employees.

Certification, reporting and recordkeeping. To facilitate enforcement under Section 609, EPA developed several record keeping requirements. All required records must be re tained on

- si te for a minimum of three years, unless otherwise indicated (40 CFR §82.42 (b))

.

Section 609(c) of the Act states that by January 1, 1992

, no perso n may service any motor

vehicle air conditioner without being properly trained and certified, nor without using properly approved refrigerant handling equipment. To this end, 40 CFR 82.42 (a) states that by January 1,

1993

, each service provider must have submitted to EPA on a one

- time basis a statement signed by the owner of the equipment or another responsible officer that provides the name of the equip

ment purchaser, the address of the service establishment where the equipmen t will be located , the manufacturer name, equipment model number, date of manufacture, and equipment serial

number. The statement must also indicate that the equipment will be properly used in servicing

motor vehicle air condition ers and that each individ ual authorized by the purchaser to perform service is property trained and certified

. The information is used by the SPD to verify compli ance with Section 609 of the Act.

Any person who owns approved refrigerant handling equipment must maintain records of the name and address of any facil ity to which refrigerant is sent. A dditionally, any person who owns approved refrigerant handling equipment must retain records demonstrating that all persons authorized to operate the equipment are currently certified t echnicians.3

Finally, any person who sells or distributes a class I or class II refrigerant that is in a container of less than 20 pounds must verify that the purchaser is a properly trained and certified technician, unless the purchase of small containe rs is for resale only. In that case, the seller must obtain a written statement from the purchaser that the containers are for resale only, and must indicate the purchaser's name and business address. When a certified technician purchas es small

contain ers of refrigerant for servicing motor vehicles, the seller must have a reasonable basis for believing the accuracy of the information presented by the purchaser. In all cases, t he seller must display a sign where sales occur that states the certification req uirements for purchasers.

2. Need for and Use of the Collection

a) Authority for the Collection

The information requested for all entities that service motor vehicle air conditioning is required by Section 609(d) of the Act and 40 CFR 82.36, 82.40, 82. 42

. This includes certification of both approved equipment and properly trained personnel. Section 609(b)(2)(A) and 40 CFR 82.38 require the approval of independent standards testing organization by EPA. A utomotive air conditioning technician certification programs are referred to in Section 609(b)(4) , and applicable requirements for program certification are detailed in 40 CFR 82.40

. R eporting requirements associated with the sale of small containers for resale only are noted in Section 609(e) of the Act

a nd 40 CFR 82.42(b)(3). The reporting requirements for the motor vehicle recycling program are

derived from Section 114 of the Act.

b) Practical Utility/Users of the Data

MVAC service establishments are required

, by Section 609 of the Act

, to have purchased approved refrigerant handling equipment and to have only properly trained and certified personnel using the equipment by January 1, 1992. They must submit certification form or

statement to EPA by January 1, 1993 certifying that the MVAC service establishment has acquired and is properly using, approved equipment and that each individual authorized to use the equipment is properly trained and certified

. The Agency uses the certifi cates to confirm compliance with Section 609.

i) Equipment Certification

As per 30 CFR §82.36 (a) (1), t he Agency is required either to certify refrigerant handling equipment itself or to approve independent laboratories to test and certify equipm ent. In order for EPA to certify equipment, the Agency m ust be provided with information that proves the equipment’s ability to recover and/or recycle refrigerant according to the SAE J standards adopted into the appendices at 40 CFR part 82, subpart B

. Certification standards are particular to the type of equi pment used and refrigerant being recovered.

Since EPA does not have the capabilities to test all refrigerant handling equipment on a national scale, the Agency relies on approved l aboratories to test equipment. Currently,4

Underwriters Laborato ries (UL) and Intertek/ ETL Testing Laboratories (ETL) certify e quipment on a voluntary basis. The Agency established a n approval system at 40 CFR §82.38 to evaluate procedures of laboratories that may request approval in the future

. Information submitted by the

labo ratories must include documentation of their capacity to accurately test equipment, an absence of a conflict of interest or financial benefit based on test results, and agreement to allow EPA access to verify information. The SPD uses the information provi ded by independent

laboratories to evaluate their capacity to properly test refrigerant handling equip ment. The Agency has required only the submission of information that will enable it to e nsure that all approved laboratories can test equipment under Ag ency standards and the adopted SAE J

standards.

ii) Te chnician Certification Programs

Technicians must pass a test at the completion of a certification program in order to perform any service or repair on MVACs and in order to use the approved equipment as stipulated in Section 609 and 40 CFR 82.34, 82.40. Technician certification programs must submit verification to EPA of their compliance with standards set forth in 40 CFR 82.40. SPD uses certification program information to ensure that Agency standar ds are met, and that they are at least as stringent as the SAE J standards of the Society of Automotive Engineers

. Because of the rapidly changing nature of the motor vehicle air conditioning market, EPA requires that technician certification programs con duct internal reviews and update their program periodically. By requiring a written summary of the review and any program changes to be reported to EPA every two years, the Agency ensures the accuracy of the information, and maintains parity among testing programs.

iii) Refrigerant Sent Off

- site

EPA requires service establishments to record the name and address of any off

- site facility which is reclaiming refrigerant , per 40 CFR §82.42 (b)(1)

. This information is used to verify compli ance with the motor vehicle air conditioning recycling program.

iv) Purchases of Small Cans

D istribu tors who purchase small containers of refrigerant must be properly trained and certified according t o the standards set forth in 40 CFR § 82.40, unless the purchaser provi des a written statement verifying that the small containers were purchased for resale only. The seller may keep the initial statement from a distributor and update the file with the amounts of refrigerant purchased in the form of small containers. These re cords are used to e nsure that small containers of refrigerant are not available for non

- certified technicians. By requiring only minor additions to the existing invoice procedures, the Agency has e nsured total compliance with

Section 609.

3. Non

- duplicat ion, Consultations, and Other Collection Criteria5

a) Non

- D uplication

The specific information requested by this notice is not currently collected by any other office within EPA or any other government agency.

b) Public Noti c e Required Prior to ICR Su bmission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPA will issue a public notice in the Federal Register soliciting public comments for a 60

- day period.

c ) Consultations

In developing the regulations under the Act, EPA established an advisory council for issues relating to stratospheric ozone. The Stratospheric Ozone Protec tion Advisory Council (STOPAC) membership included representatives from affected industries, environ mental interest groups, and academics in related fields. Wi thin STOPAC, subcommittees were formed to look at

the more detailed issues. The subcommittee on motor vehicle air condi tioning met several times

, and discussed all aspects of the proposed regulations for Section 609 of the Act. The Federal Register Notice required under 5 CFR 1320.8(d) soliciting comments on this collection of

information

, was published on 9/4/98 (63 FR 47284); no comments were received.

To update this ICR, information was recently obtained from six technician certification organizations

.

d ) Effects of Less Frequent Collection

The equipment certification time table was established by Congress in Section 609. Since

the certification submission is a one

- time occurrence, a less frequent collection of this information would make it impossib le to comply with Section 609.

V erification s of applications for technician certification programs and independent standards testing organizations are required to be submitted to EPA under Section 609 of the Act.

The review is a one

- time occurrence and mu st take place to allow the Agency to approve programs under the Act.

e) General Guidelines

Th e Section 609 regulations do not exceed any of the guidelines.

f ) Confidentiality6

This section does not apply because this ICR does not request inf ormation of a confidential nature.

g) Sensitive Questions

This section does not apply because this ICR does not request information of a sensitive

nature.

4. The Respondents and the Information Requested

a) Respondents / NAICS Codes

The following is a list of NAICS codes for organizations potentially affected by the information requirements covered under this ICR . It is meant to include any establishment that may service or

maintain motor vehicle air conditioners.

441 1 Automobile Dealers

4413 Aut omotive Parts, Accessories, and Tire Stores

447 11

45299 All Other General Merchandise Stores

8111 98 All Other Automotive Repair and Maintenance

Other affected groups include:

Independent Standards Testing Organizations Organizations with Te chnician Certification Programs

b) Information Requested

i) Data Items, inclu ding Recordkeeping Requirements

All entities that service motor vehicle air conditioners must send to EPA

, on a one

- time

basis

, certification of an appropriate MVAC refrigerant handling device

. This certifica tion must

include the name of the purchaser of the equipment, address of the establishment where the equipment will be located , name of equipment manufacturer, model number, date of

manufacture , and serial number . The state ment must be signed by the owner of the equipment or other responsible officer

, and must indicate that the equipment will be properly used in servicing

motor vehicle air condition ers
, and that each individual authorized by the purchaser to perform

service is property trained and certified.

Independent laboratory testing of refrigerant handling equipment is designed to ensure that the equipment is capable of safely meeting the standards set forth by EPA in appendices to 40 CFR 82 Subpart B. To establish a degree of uniformity to the equipment certification programs, EPA requires organizations to submit applications documenting : the equipment used7

for equipment testing; the expertise and technica l experience of their personnel; thorough knowledge of the stan dards in the ap pendices to 40 CFR 82 Subpart B; test procedures to be used

and the rationale for them; absence of a confli ct of interest or financial benefit based on test results; and agreement to allow EPA access to verify information. Specific reporting requirements may include: equipment ability to remove moisture, oil, and non

- condensable gas es from refrigerant

, and a list of testing equipment used.

Technician certification programs interested in certifying technicians are required to

document that th eir program meets EPA standards. An acceptable program includes the following components: adequate training through on

- the

- job or on

- site instructional training, or

self

- study; a test that effectively covers all relevant standards dealing with the servici ng and repair of motor vehicle air conditioners

, anticipated future technological developments

, the regulatory requirements imposed by EPA under Section 609 of the Act

, the environmental conse

quences of the release of refrigerant during the servicing and repair of motor vehicle air

conditioners

, and the adverse effects of stratospheric ozone depletion ; a test grader who receives no benefit based on test results; means of identifying the individual taking the test; the measures

taken at the test site to e ns ure that the tests are completed honestly by each technician; individual proof of certification in the form of a certificate or card and unique certification number.

Certification programs are required to conduct a periodic review of their test material and

submit to EPA a written program review summary and any material changes every two years.

Service establishments that own approved refrigerant handling equipment and send used refrigerant off

- site for recycling or reclamation must record the facil ity name and address to which any refrigerant is sent. In addition, t he seller of small containers to an uncertified purchaser must be provided with a written statement that the containers are for resale only. The statement must also contain the purchaser’ s name and address . Finally, any person who owns equipment must retain records demonstrating that all technicians authorized to operate the equipment are certified pursuant to the Clean Air Act. All of these records must be kept on

- site

for a minimum of th ree years.

ii) Respondent Activities

All Entities That Service Motor Vehicle Air Conditioners

One

- Time Equipment and User Certification F orm s :

o Compile documentation for a certification that states the following: The name of the purchaser of the equip ment, address of the establishment where the equipment will be located, name of equipment manufacturer, model number, date of manufacture, and serial number. The statement must be signed by the owner of the equipment or other responsible officer, and indic ate that the equipment will be properly used in servicing motor vehicle air condition ers and that each individual authorized by the purchaser to perform service is property trained and certified. In many cases a form is provided by the8 manufacturer of the equip ment. Prepare and submit completed certification to
EPA.

Records of Certified Technicians:

o Maintain records on

- site , for a minimum of three years, demonstrating that all equipment users are properly trained and certified

.

Records of Refrigerant Se nt Off

- site:

o Record and file the facility address to which any refrigerant is sent for off

- site reclamation or recycling. Recordkeeping is required for a minimum of three

years.

Records of Class I or Class II Refrigerant in Small Containers S old for Re

- S ale :

o Verify that purchaser is properly trained and certified

.

o Compile

, file , and keep for a minimum of three years written statements from uncertified purchasers verifying their intent to only resell the small containers of refrigerant.

Independent Stand ards Testing Organizations

New Independent Standards Testing Organization Certification

o Research SAE J standards on MVAC refrigerant handling equipment.

o Compile test methodology, a list of required equipment, and other information regarding the SAE standa rds for the application to EPA.

o Prepare and s ubmit application to EPA that documents capacity to accurately test whether refrigerant handling equipment complies with the applicable

standards , an absence of conflict of interest or financial benefit based on test results and an agreement to allow EPA access to verify information to ensure that the testing program fulfills the applicable SAE J standards , adopted in the appendices at 40 CFR part 82, subpart B, for recycling and recovery equipment.

Substantiall y Identical Equipment

Substantially Identical Equipment Owners or Manufacturers

o Locate information that will verify that the equipment can perform to the applicable SAE J standards, including process flow sheets and a list of
components.

o Compile supportin g information and submit it to EPA

.

Technician Certification Programs

New Technician Certification Program Certification:9 o Compile documents and s ubmit to EPA verification that training program

meets EPA requirements

.

Technician Certification Program Re view:

o Conduct periodic program review s

.

o Prepare and submit summary of program review to EPA every two years

.

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

Informa tion Management

a) Agency Activities

One

- Time Equipment an d User Certification F orms :

o Review and s tore certification applications and supporting documents from all entities that have purchased approved refrigerant handling equipment

.

Records of Certified Technicians:

o No Agency action required.

Records of Refrig erant Sent Off

- s ite:

o No Agency action required.

Records of Refrigerant S old for Re

- Sale :

o No Agency action required.

New Independent Standards Testing Organization Certification :

o Review applications from independent labs that request approval to certify

r efrigerant handling equipment.

New Technician Certification Program Certification:

o Review applications from new technician certification programs.

Technician Certification Program Review:

o Review summaries of certification program updates every two years.10

b) Collection Methodology and Management

S PD and the EPA regional offices have planned and allocated resources for the efficient and effective management and use of this information. The Agency has developed a sample form that manufacturers may distrib ute to service establishments that have purchased approved refrigerant handling equipment. An establishment may submit the form provided by the manufacturer of the equipment. Entities are not required to use the manu facturer's form, but they

must submit t he required information. The information submitted by each service establishment is maintained by the EPA R egional offices.

Independent standards testing organizations must submit to the Agency an application documenting their capacity to accurately tes t whether refrigerant handling equipment complies with the applicable standards , an absence of conflict of interest or financial benefit based on test results, and an agreement to allow EPA access to verify information . The Agency examines the

submitted te st procedures for their ability to meet the SAE standards as specified in Section 609 of the Act. These applications may be submitted manually or electronically, as long as they are made available for Agency review.

Equipment manufacturers or equipment ow ners that are interested in having their equipment determined substantially identical must submit information to the Agency for an evaluation of the equipment. The information provided is kept on file at EPA for reference.

Technician certification progra ms must submit to the Agency a verification of their compliance with EPA regulations for review and approval by the S PD. Program materials include, but are not limited to: video tapes, scripts, manuals, booklets, and software or other

forms of electronic i nformation. Testing of technicians may be performed either manually or electronically. The certification programs and their review reports are kept on file at EPA for

reference.

The Agency has determined that periodic on

- site inspection is the most eff ective method

to e nsure compliance with S ection 609. R ecords should be kept at the location where service involving refrigerant is performed or where small containers of refrigerant are distributed for

resale.

c) Small Entity Flexibility

Section 609 cont ains a provision that allow ed small entities (i.e., those which performed service on fewer than 100 motor vehicle air conditioners during the calendar year 1990) an

additional year to comply with the provisions of Section 609.

EPA expects a small number of technician certification programs and independent equipment standard testing organizations to apply for approval. The requirement to submit the program application for Agency approval is not burdensome and is not expected to prevent small11

entities from developing programs. The Act does not require programs to be developed, only that

once developed they be submitted to EPA.

The substantially identical determination is designed to examine equipment sold before the regulations were proposed and that had n ot been certified by an approved independent laboratory. This provision will benefit small entities that may have purchased recycling or recover equipment in a good faith effort to recover refrigerant prior to a regulatory mandate.

EPA does not expect any new indepen dent standards testing programs to apply for approval.

The name and address of the refrigerant handling facility to which refrigerant is sent by

an establishment with recover y

- only capabilities is a standard part of existing record keeping

pr ocedures for business transactions. The regulations regarding records maintained by persons who sell small containers of refrigerant solely require that the resale

- only statement be added into invoicing procedures for sales to uncertified purchasers

.

d) C ollection Schedule

All entities operating at the time the regulations were introduced were required to submit certification forms to EPA by January 1, 1993. The certification for refrigerant handling equipment is intended as a one

- time information request for the life of the equipment

.

After the initial EPA approval, technician training programs must review their programs periodically to account for technological developments. A summary of the program review and any changes must be submitted to EPA every two years

.

6. Estimating the Burden and Cost of the Collection

a) Estimating Respondent Burden

The basis of the analysis is the identification of the principal steps involved in complying with EPA recordkeeping and reporting requirements and the e stimated burden associated with each step. The burden has been estimated by identifying the number of times the step will be undertaken and the number of hours required to complete each step. Appendix 1 presents th e estimated annual respondent burden and costs for information collection activities associated

with Section 609 of the Act.

Time required for completion of each activity is derived from the estimates in the previous ICR, with several exceptions. In this ICR, the maintenance of records of technician

certification (of photocopying and filing the technician’s certification card) is estimated to require 0.083 clerical work hours per establishment (5 minutes) , which remain unchanged from the previous ICR. Add itionally , in this ICR, the one

- time equipment and user certification for compilation, preparation, and submission is estimated to require 0.1 7 hours (10 minutes) per12

establishment, w h ich remain unchanged from the previous ICR. Generally, this one

- time

cer tification is submitted by a new motor vehicle service facility, or by first

- time refrigerant handling equipment owners or lessees, or when there’s been a change in ownership on an existing service facility , consistent with the recordkeeping a and reportin g requirements on 40

CFR 82.42

. This labor burden includes completion and mailing of a prepared form . The form requires information on establishment name , name of the equipment owner or lessee

, address, and telephone number, as well as equipment manufactur er, model number, serial number, and

year

.

In this ICR, 1.5 hours has been allotted per establishment to conduct the reviews, and 0.5

hours has been allotted per establishment to prepare and submit the summary , which are unchanged from the time allotted in the previous ICR

.

It should be noted that m inimal records need to be developed by industry establishments,

and these records can be stored as hard copies; there is no need for the creation (or maintenance)

of a database system . Therefore, no additiona l hours or costs are required for these activities.

b) Estimating Respondent Costs

i) Estimating Labor Costs

Respondent labor costs (hourly rate plus overhead and fringe) are estimated using data

from t he Bureau of Labor Statistics. 1 A verage hourly w ages are multiplied by a factor of 2.1 to reflect the estimated additional costs for overhead and fringe . General recordkeeping tasks are assigned to administrative assistants, whereas preparations of applications and reports are assigned to managers. The following job characterizations were used in Table 1 :

General and Operations Manager : $ 45.74 /hr x 2.1 = $ 96.05

Executive Secretaries and Administrative Assistants : $ 21.91 /hr x 2.1 = $ 46.01

Automotive Service Tech nicians and Mechanics: $17. 39 hr x 2.1 = $36. 52

Table 1 . Average Hourly Establishment Labor Costs Managerial Clerical Technical $ 96.05 $ 46.01 $ 36. 52

ii) Estimating Capital and Operations and Maintenance Costs

The Agency estimat es that there are no capital/operations and maintenance costs

assoc iated with the requirements of S ection 609, and therefore

, with the renewal of this information collection request.

1 Labor rates were retrieved from the “May 2011 National Industry

- Specific Occupational Employment and Wage
Estimates” for the Gener al and Operations Manager (11

- 1021), Executive Secretaries and Administrative Assistants (43

- 6011), and Automotive Service Technicians and Mechanics (49

- 3023) provided by the U.S. Bureau of Labor Statistics at, http://www.bls.gov/oes/2011/may/oes_nat.htm#43

- 0000

.13

c) Estimating Agency Burden and Cost

The basis of this analysis is the identification of the steps involved in implementing and operating the system. The costs associated with each step have been estimated by identifying the number of times the step will be undertaken, the number of hours required to complete each step,

and the total dollar cost. Appendix 2 presents the estimated Agency burden hours and costs associated with the information collection activities for this ICR. Agency labor costs are based on

the 20 11 GS Salary Schedule for the locality pay area of Washington

- Baltimore

- Northern Virginia, DC

- MD

- PA

- WV

, which are multiplied by 1.6, the standard government benefits multiplier. 2 See Table 2 for EPA estimates of average hourly labor co sts for managerial and

clerical staff , whose wage estimates are based on GS 1 2 step 2, and GS 7 step 2 hourly rates respectively . As shown , EPA estimates that the annual Agency burden for all ac tivities covered

in this ICR is 188.38 hours at a total cost o f $ 6,223.98 pe r year.

Wage estimates are based on the following characterizations of occupations:

GS 1 2 Step 2

- Managerial: $ 3 6.04 /hr x 1.6 = $ 5 7.65 /hr GS 7 Step 2

– Clerical (43

- 4199) : $ 19. 5 7 /hr x 1.6 = $ 31. 3 1/hr

Table 2 . Avera ge Hourly Agency Labor Costs

Managerial Clerical $ 57.65 $ 31. 31

Estimates of burden hours are based on assumptions that filing and recording information will take very little time. Specific estimates are detailed in Appendix 2. No additional hours or

co sts will be incurred for preparation or development of a recordkeeping database. For the establishment activities that simply require on

- site recordkeeping, EPA has no correlated burden. Similarly, for the activities currently not applicable to any establi shments, EPA has no correlated

burden.

d) Estimating the Respondent Universe and Total Burden and Costs

An average estimate of 180 equipment certification forms are received and processed by

EPA each month . T herefore, it is estimated that 2

, 200 establi shments will compile and submit

one

- time certification forms to EPA each year. While these certification forms were historically sent by respondents to EPA Headquarters and then forwarded on to EPA Regional offices, as appropriate, they are now sent direct ly from establishments to EPA Regional offices.

The previous ICR estimated that there will be 55 ,000 records of technicians maintained in

establishments per year demonstrating that all equipment users are properly trained and certified.

2 Labor rates were retrieved from the “May 2011 National Industry

- Specific Occupational Employment and Wage Estimates” for the Federal Executive Branch (NAICS Code 999100) provide d by the U.S. Bureau of Labor Statistics

at, http://www.bls.gov/oes/current/naics4_999100.htm

.14

However, b ased a decrease of n umber of technician certification programs and on data collected

in March 20 12 from 6 out of 19 technician certification centers

, it is estimated that 5 0 ,000 new MVAC technicians are certified each year

. Assuming that MVAC service establishm ents will hire these newly certified technicians and maintain records demonstrating their certification , this

ICR estimates that there will be 5 0 ,000 records regarding certified technicians using proper refrigerant handling equipment will be maintained eac h year

.

The previous ICR estimate d that 5

, 000 establishments per year that send refrigerant off

site for handling , assuming all establishments sent refrigerant fro reclamation. However, b ecause most service establishments recycle refrigerant on

- site, th e number of entities that send refrigerant off

- site for recycling/reclamation is very low . The agency estimates that 3% of the total servicing establishments currently operating in the United States ( 4100)

, 3 will send the refrigerant off

- site for reclamati on. Therefore, 120 facilities are estimated to keep record and file off sire facility address of refrigerant sent for reclamation.

It is estimated that there are 27 5 purchases of small class I or class II refrigerant containers

made by uncertified purch asers for resale only. Th is number is reduced from the estimate of 1,370 purchases in the previous ICR

, derived from a n estimate of CFC

- 12 vehicles on road

, which estimated about 80% reduction of the existing CFC

- 12 vehicle fleet estimated in 2008

.

T her e are currently two independent standards testing organizations, and it is unlikely that any others will apply for approval. Additionally , no significantly identical equipment is expected

to be submitted to the Agency for review.

There are currently 19 technician certification programs that must submit program reviews every other year. It is estimated that EPA will review 1 program per year.

.

e) Bottom Line Burden Hours and Cost Tables

i) Respondent Tally

Total Annual Burden Hours: 4,522. 7 5 hrs. Total Annual Cost: $ 2 08

, 307

. 40

ii) The Agency Tally

Total Annual Burden Hours: 188.38 hrs. Total Annual Cost: $ 6,223.98

iii) Variations in the Annual Bottom Line

Changes to the annual bottom line are due to a more accurate estimate in hourly wage s

3 BLS, 201115

and a shift in the time requirements and number of reporting establishments. See below for a more complete discussion of these changes.

f) Reasons for Change in Burden

The previously approved ICR ’s supporting statement described an estimated burden o r estimated a total a nnual respondent burden of 2,865 hours. By comparison, this ICR estimates a

total annual burden of 4,522. 7 5 hours

. Hence, there is a decrease of 2,177. 2 5 hours and a decrease of $ 54,6 37

. 07 since the previously approved ICR. This change can be attributed to the following factors.

In the previous ICR, respondent hourly wages were $47.73, $18.83, and $17.53 for managers, administrative assistants, and technicians, respectively. In this ICR, to increase accuracy, wages have been estimated based on the most current Bureau

of Labor Statistics (20 11 ) national averages for managers

, administrative

assistants , and technicians to be $ 4 5.74

, $ 21.91

, and $17. 39

, respectively

. These baseline wages were then multiplied by a factor of 2.1 to incorpor ate overhead and fringe costs into the hourly cost estimate , resulting in estimated hourly cost s of $ 96.05

, $ 46. 01 , and $36. 52

.

The number of technician certification programs decreased from 2 4 to 19 since the previous ICR because several program s went ou t of business.

In this ICR, time requirements for each EPA activity related to establishments’ report submissions have been estimated

. Additionally, wages for clerical and managerial EPA work has been estimated based on the 20 11 GS Salary Schedule

for the locality pay area of Washington

- Baltimore

- Northern Virginia, DC

- MD

PA

- WV. T hese baseline wages were multiplied by a factor of 1.6, the standard government benefits multiplier, to arrive at an accurate hourly cost.

The previous ICR estimated that 55 ,000 new technician certifications would be

rec orded and filed by owners of approved refrigerant handlin g equipment each year. However, this ICR estimates the number to be 5 0 ,000. B ased on data

collected in March 20 123 from some technician certification center s, it is

estimated that 5 0 ,000 new MVAC technicians are certified each year. The time allotted to this activity in the last ICR was 0. 083 hours per certification ; no change in time allotted per certification is expected on this ICR. 0. 083 hours.

The previ ous ICR estimated that equipment and user certification form compilation and submission would require 0. 17 hours per establishment. That

estimate remains unchanged in this ICR.

In 20 08 it was estimated that there would be 1,370 purchases of small containe rs of class I and class II refrigerant for resale only by uncertified purchasers. It is16 estimated that at the time (in 200 8 ), there were an estimated 3 million R

- 12 MVACs on the road. Today, it is estimated that there are only 600 thousand R

- 12

MVACs on th e road, or roughly 8 0 % less than there were in 200 8 . Therefore, to
account for the decreased market for small containers of CFC

- 12 refrigerant, this

ICR estimates that the number of purchases for resale only by uncertified purchasers of small cans will be 80 % less than in 200 8

, or 27 5 purchases

.

Finally, the substantially identical equipmen t approval process is no longer applicable for CFC

- 12 and HFC

- 134a refrigerant handling equipment manufactured prior proposal of refrigerant equipment handling regulatio ns . This portion of Section 609(b)(2)(B) of the Act and 40 CFR 82.36(b) allowed for equip ment that was purchased before the proposal of the regulations to be approved by EPA if it was substantially identical to equipment that had been certified by the EPA or approved independent laboratory. The substantially identical equipment regulation only relates to CFC

- 12 recovery and recycling equipment initially purchased before September 4, 1991; CFC

- 12 recovery

- only equipment initially purchased before April 22, 1992; HFC

- 134 a recovery and recycling, or recovery

- only equipment initially purchased before March 6, 1996; equipment that recovers but does not recycle any single, specific refrigerant other

than CFC

- 12 or HFC

- 134 a that was initially purchased before Marc h 6,1996; or equipment that recovers and recycles HFC

- 134a and CFC

- 12 refrigerant using common circuitry that was initially purchased before March 6, 1996. Because the average lifetime of such equipment is roughly 7 years, all such equipment is

obsolete to day. Therefore, documentation requirements related to this section for

CFC

- 12 and HFC

- 134a have been removed from this ICR.

g) Burden Statement

The industry reporting burden for this collection is estimated in Appendix 1 . It includes

the time needed to comply with EPA's certification requirements and Agency reviews. The total respondent burden is estimated at 4, 5 22. 7 5 hours.

The Agency burden for this collection is estimated in Appendix 2 . It includes the time needed to record, review, and file all cer tification applications and related materials. The total Agency burden is estimated at 188.38 hours.

Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing responde nt burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2137), 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460; and to the Office of Information a nd Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA ICR number and OMB control number in any correspondence.17 

### Appendix 1

Industry Reporting Burden

INFORMATION COLLECTION

ACTIVITY Frequency/

Number of Responses per

Year Labor Hours per Response Costs

General and Operations Manager $ 96.05 Automotive

Service

Technicians

and

Mechanics $ 36.52 Executive

Secretaries

and

Administrative

Assistants

46.01 Total

Labor

Hours Average

Total

Hours Total Labor

Costs per Response Average Cost/Year

ENTITIES THAT SERVICE

MVACs

One

- Time Equipment and User

Certification Forms Compile, Prepare, and Submit

Certification 22 00

- 0.1 7 0.17 3 74 $ 7.82 $ 17,207

. 74

Records of Technician

Certification

Maintain Records On

- Site of

Certification of Technicians 5 0 ,000 0.08 0.08 4000 $ 3.68 $ 184

. 040.00

Records of CFC

- 12 Refrigerant

Sent Off

- Site

Record and file off

- site facility

address 120

- 0.25 0.25 30 $ 9.13 $ 1,095.60

Records of CFC

- 12 Refrigerant

Sold

Verify certification of purchaser N/A N/A N/A N/A N/A N/A N/A N/A

Obtain and file written statements from purchaser verifying intent to only resell small containers 27 5 0.25 0.25 68. 7 5 $ 11.50 $ 31 63.20

Subtotal 52700 0.75 4472. 7 5 $ 32.13 $ 205, 506

. 50

INDEPENDENT STANDARDS

TESTING ORGANIZATIONS

New Independent Standards Testing Organization

Certification18

INFORMATION COLLECTION

ACTIVITY Frequency/

Number of Responses per

Year Labor Hours per Response Costs

General and Operations Manager $ 96.05 Automotive

Service

Technicians

and

Mechanics $ 36.52 Executive

Secretaries

and

Administrative

Assistants

46.01 Total

Labor

Hours Average

Total

Hours Total Labor

Costs per Response Average Cost/Year

Research SAE standards on MVAC recovery equipment

- N/A N/ A N/A N/A N/A N/A N/A Compile information for application

to EPA

- N/A N/A N/A N/A N/A N/A N/A Prepare and submit application to

EPA

- N/A N/A N/A N/A N/A N/A N/A

Subtotal N/A N/A N/A N/A N/A N/A N/A

TECHNICIAN

CERTIFICATION PROGRAMS

New Tech nician Certification Program Certification

Compile documents and submit to EPA for verification of program 1 N/A N/A 40 40 40 $ 1,840.40 $ 1,840.40 Technician Certification Program

Review

Conduct periodic program reviews 10 0 .5 0 .5 5 $ 48.03 $ 480.25 Prepare and Submit summary of program review to EPA every two

years 10 0.50 0.50 5 $ 48.03 $ 480.25

Subtotal 2 1 2.00

- 2.00 50 $ 1936.46 $ 2, 800.90

ANNUAL TOTAL N/A 4 522. 7 5 $ 1968.59 $ 208, 307

. 4019 

### Appendix 2

Agency Reporting Bur den

INFORMATION

COLLECTION ACTIVITY Frequency/

Number of Responses per

Year Labor Hours per Response Costs

Manager Clerical Total

Labor

Hours Average

Total

Hours Total Labor

Costs per Response Average

Cost/Year $ 57.65 $31. 31

One

- Time Equipment and

User Certification Forms

Review and file applications 2

, 2 00 0.08 0.08 176 $ 2. 5 0 $ 5,510.56

New Independent Standards Testing Organization

Certification

Review applications from testing organizations who request to certify equipment 0

- - $

- $

-

New Technician Certification Program Certification Review applications from new

technician certification

programs 1 10 10 10 $ 576.50 $ 576.50

Technician Certification Program Review

Review summaries of

certifi cation program updates
every two years 9.5 0.25 0.25 2.375 $ 14.41 $ 136.90

Annual Total 188.38 $ 593.41 $ 6,223.98