1

INFORMATION COLLECTION REQUEST FOR SERVICING OF MOTOR VEHICLE 

AIR CONDITIONERS (RENEWAL)

SUPPORTING STATEMENT 

1. Identification of Information Collection

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

OMB Control Number: 2060-0247

EPA Number: 1617.07

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 (hereafter 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 31242, and codified at 40 

CFR Subpart B (§ 82.30 et seq.). This supporting statement is submitted to justify an extension 

of the approval of use of this information. 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 costs

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 standards 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 capacity to accurately test equipment compliance 

with applicable standards consistent with the SAE standards for handling refrigerant, an absence 

of conflict of interest or financial benefit based on test outcomes, and an agreement to allow EPA 

access to verify application information. Once an independent laboratory 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 refrigerant handling 

equipment. EPA does not anticipate that any organizations will apply to EPA in the future to 
2

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 trained and certified in the proper use of approved refrigerant 

handling equipment. Programs that perform technician training and certification activities must 

apply to the SPD for approval by submitting verification that its program meets EPA standards.

The information requested is used by the SPD to guarantee a degree of uniformity in the testing 

programs for motor vehicle service technicians.

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 SPD. Currently, 19 testing 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 recordkeeping requirements. All required records must be retained on-site 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 person 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 equipment purchaser, the address of the service establishment where the equipment 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 conditioners and that each individual authorized by the purchaser to perform 

service is property trained and certified. The information is used by the SPD to verify compliance with Section 609 of the Act. 

Any person who owns approved refrigerant handling equipment must maintain records of 

the name and address of any facility to which refrigerant is sent. Additionally, any person who 

owns approved refrigerant handling equipment must retain records demonstrating that all persons 

authorized to operate the equipment are currently certified technicians. 

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 containers 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 purchases small 

containers of refrigerant for servicing motor vehicles, the seller must have a reasonable basis for 
3

believing the accuracy of the information presented by the purchaser. In all cases, the seller must 

display a sign where sales occur that states the certification requirements 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. 

Automotive 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. 

Reporting requirements associated with the sale of small containers for resale only are noted in 

Section 609(e) of the Act and 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 certificates to confirm 

compliance with Section 609.

i) Equipment Certification

As per 30 CFR §82.36 (a) (1), the Agency is required either to certify refrigerant 

handling equipment itself or to approve independent laboratories to test and certify equipment. In 

order for EPA to certify equipment, the Agency must 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 equipment 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 laboratories to test equipment. Currently, 

Underwriters Laboratories (UL) and Intertek/ETL Testing Laboratories (ETL) certify equipment 

on a voluntary basis. The Agency established an approval system at 40 CFR §82.38 to evaluate 

procedures of laboratories that may request approval in the future. Information submitted by the 

laboratories 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 provided by independent 

laboratories to evaluate their capacity to properly test refrigerant handling equipment. The 
4

Agency has required only the submission of information that will enable it to ensure that all 

approved laboratories can test equipment under Agency standards and the adopted SAE J 

standards. 

ii) Technician 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 standards 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 conduct 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 compliance with the motor vehicle air conditioning recycling program. 

iv) Purchases of Small Cans

Distributors who purchase small containers of refrigerant must be properly trained and 

certified according to the standards set forth in 40 CFR §82.40, unless the purchaser provides 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 records are used to ensure 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 ensured total compliance with 

Section 609. 

3. Non-duplication, Consultations, and Other Collection Criteria

a) Non-Duplication

The specific information requested by this notice is not currently collected by any other 

office within EPA or any other government agency. 

b) Public Notice Required Prior to ICR Submission to OMB
5

In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in 

the Federal Register soliciting public comments for a 60-day period on 05/04/2012 (77 FR 

26544). No comments were received. EPA will issue a public notice in the Federal Register

soliciting public comment for a 30-day period concurrent with the submission of this ICR to 

OMB.

c) Consultations

In developing the regulations under the Act, EPA established an advisory council for 

issues relating to stratospheric ozone. The Stratospheric Ozone Protection Advisory Council 

(STOPAC) membership included representatives from affected industries, environmental interest 

groups, and academics in related fields. Within STOPAC, subcommittees were formed to look at 

the more detailed issues. The subcommittee on motor vehicle air conditioning met several times,

and discussed all aspects of the proposed regulations for Section 609 of the Act.

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 impossible to comply with Section 609.

Verifications 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 must take place to allow the Agency to approve 

programs under the Act. 

e) General Guidelines

The Section 609 regulations do not exceed any of the guidelines.

f) Confidentiality

This section does not apply because this ICR does not request information 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
6

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.

4411 Automobile Dealers

4413 Automotive Parts, Accessories, and Tire Stores

44711 

45299 All Other General Merchandise Stores

811198 All Other Automotive Repair and Maintenance

Other affected groups include:

 Independent Standards Testing Organizations

 Organizations with Technician Certification Programs

b) Information Requested

i) Data Items, including 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 certification 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 statement 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 conditioners, 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 used 

for equipment testing; the expertise and technical experience of their personnel; thorough 

knowledge of the standards in the appendices to 40 CFR 82 Subpart B; test procedures to be used 

and the rationale for them; absence of a conflict 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 gases

from refrigerant, and a list of testing equipment used.

Technician certification programs interested in certifying technicians are required to 

document that their 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 servicing and 
7

repair of motor vehicle air conditioners, anticipated future technological developments, the 

regulatory requirements imposed by EPA under Section 609 of the Act, the environmental consequences 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 ensure 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 facility name and address to 

which any refrigerant is sent. In addition, the 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 three years.

ii) Respondent Activities

All Entities That Service Motor Vehicle Air Conditioners

 One-Time Equipment and User Certification Forms:

o Compile documentation for a certification that states the following: 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 statement must be signed by the 

owner of the equipment or other responsible officer, and indicate that the 

equipment will be properly used in servicing motor vehicle air conditioners 

and that each individual authorized by the purchaser to perform service is 

property trained and certified. In many cases a form is provided by the 

manufacturer of the equipment. 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 Sent 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. 
8

 Records of Class I or Class II Refrigerant in Small Containers Sold for Re-Sale:

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 Standards 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 standards for the application to EPA.

o Prepare and submit 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.

Substantially 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 supporting information and submit it to EPA.

Technician Certification Programs

 New Technician Certification Program Certification:

o Compile documents and submit to EPA verification that training program 

meets EPA requirements.

 Technician Certification Program Review:

o Conduct periodic program reviews.

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

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

Information Management

a) Agency Activities

 One-Time Equipment and User Certification Forms:
9

o Review and store 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 Refrigerant Sent Off-site:

o No Agency action required.

 Records of Refrigerant Sold 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 

refrigerant 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.

b) Collection Methodology and Management

SPD 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 distribute 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 manufacturer's form, but they

must submit the required information. The information submitted by each service establishment 

is maintained by the EPA Regional offices. 

Independent standards testing organizations must submit to the Agency an application 

documenting their 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. The Agency examines the 

submitted test 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 owners 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. 
10

Technician certification programs must submit to the Agency a verification of their 

compliance with EPA regulations for review and approval by the SPD. Program materials 

include, but are not limited to: video tapes, scripts, manuals, booklets, and software or other 

forms of electronic information. 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 effective method 

to ensure compliance with Section 609. Records 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 contains a provision that allowed 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 small 

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 not 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 independent 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 recovery-only capabilities is a standard part of existing recordkeeping 

procedures 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) Collection 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.
11

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 estimated 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 the 

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. Additionally, in this ICR, the one-time equipment and user certification for 

compilation, preparation, and submission is estimated to require 0.17 hours (10 minutes) per 

establishment, which remain unchanged from the previous ICR. Generally, this one-time 

certification 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 reporting 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 manufacturer, 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 minimal 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 additional 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 the Bureau of Labor Statistics.1 Average hourly wages are multiplied by a factor of 2.1 to 

 

1 Labor rates were retrieved from the “May 2011 National Industry-Specific Occupational Employment and Wage 
12

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 Technicians and Mechanics: $17.39hr 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 estimates that there are no capital/operations and maintenance costs 

associated with the requirements of Section 609, and therefore, with the renewal of this 

information collection request.

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 2011 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.2See Table 2 for EPA estimates of average hourly labor costs for managerial and 

clerical staff, whose wage estimates are based on GS 12 step 2, and GS 7 step 2 hourly rates 

respectively. As shown, EPA estimates that the annual Agency burden for all activities covered 

in this ICR is 188.38 hours at a total cost of $6,223.98 per year.

Wage estimates are based on the following characterizations of occupations:

 GS 12 Step 2 - Managerial: $36.04/hr x 1.6 = $57.65/hr

 GS 7 Step 2 – Clerical (43-4199): $19.57/hr x 1.6 = $31.31/hr

 

Estimates” for the General 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. 

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) provided by the U.S. Bureau of Labor Statistics 

at, http://www.bls.gov/oes/current/naics4_999100.htm.
13

Table 2. Average 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 

costs 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 establishments, 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. Therefore, it is estimated that 2,200 establishments 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 directly 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.

However, based a decrease of number of technician certification programs and on data collected 

in March 2012 from 6 out of 19 technician certification centers, it is estimated that 50,000 new 

MVAC technicians are certified each year. Assuming that MVAC service establishments will 

hire these newly certified technicians and maintain records demonstrating their certification, this 

ICR estimates that there will be 50,000 records regarding certified technicians using proper 

refrigerant handling equipment will be maintained each year. 

The previous ICR estimated that 5,000 establishments per year that send refrigerant offsite for handling, assuming all establishments sent refrigerant fro reclamation. However, because 

most service establishments recycle refrigerant on-site, the 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 reclamation. 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 275purchases of small class I or class II refrigerant 

containers made by uncertified purchasers for resale only. This number is reduced from the 

estimate of 1,370 purchases in the previous ICR, derived from an estimate of CFC-12 vehicles 

on road, which estimated about 80% reduction of the existing CFC-12 vehicle fleet estimated in 

2008. 

There are currently two independent standards testing organizations, and it is unlikely

that any others will apply for approval. Additionally, no significantly identical equipment is 

 

3 BLS, 2011 
14

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: 4,523 hrs.

Total Annual Cost: $208,307

ii) The Agency Tally

Total Annual Burden Hours: 188 hrs.

Total Annual Cost: $6,224

iii) Variations in the Annual Bottom Line

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

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 or

estimated a total annual respondent burden of 6,700 hours. By comparison, this ICR estimates a 

total annual burden of 4,523 hours. Hence, there is a decrease of 2,177 hours since the previously

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

 The number of technician certification programs decreased from 24 to 19 since 

the previous ICR because several programs went out of business.

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

recorded and filed by owners of approved refrigerant handling equipment each 

year. However, this ICR estimates the number to be 50,000. Based on data 

collected in March 20123 from some technician certification centers, it is 

estimated that 50,000 new MVAC technicians are certified each year.

 In 2008 it was estimated that there would be 1,370 purchases of small containers 

of class I and class II refrigerant for resale only by uncertified purchasers. It is 

estimated that at the time (in 2008), 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 the road, or roughly 80% less than there were in 2008. Therefore, to 
15

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 2008, or 275 purchases.

 Finally, the substantially identical equipment approval process is no longer

applicable for CFC-12 and HFC-134a refrigerant handling equipment 

manufactured prior proposal of refrigerant equipment handling regulations. This 

portion of Section 609(b)(2)(B) of the Act and 40 CFR 82.36(b) allowed for 

equipment 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-134a 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-134a that was initially purchased before March 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 today. Therefore, documentation requirements related to this section for 

CFC-12 and HFC-134a have been removed from this ICR.

g) Burden Statement

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

estimated to average 4,523 hours, or less than one hour per response. Burden means the total 

time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and maintaining information, and 

disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a currently

valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 

CFR part 9 and 48 CFR chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OAR-2012-0227, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air and Radiation Docket in the EPA Docket 

Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. 
16

The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 

566-1744, and the telephone number for the Air and Radiation Docket is (202) 566-1742. An 

electronic version of the public docket is available at www.regulations.gov. This site can be 

used to submit or view public comments, access the index listing of the contents of the public 

docket, and to access those documents in the public docket that are available electronically. 

When in the system, select “search,” then key in the Docket ID Number identified above. Also, 

you can send comments to the Office of Information and Regulatory Affairs, Office of 

Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk 

Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2012-0227 and 

OMB Control Number 2060-0247 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 

Hours per 

Response

Total 

Hours/Year

Total Labor 

Costs per 

Response

Total Cost/Year

ENTITIES THAT SERVICE 

MVACs

One-Time Equipment and User 

Certification Forms

Compile, Prepare, and Submit 

Certification 2200 - 0.17 0.17 374 $ 7.82 $ 17,207.74

Records of Technician 

Certification

Maintain Records On-Site of 

Certification of Technicians 50,000 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 275 0.25 0.25 68.75 $ 11.50 $ 3163.20

Subtotal 52595 0.75 4472.75 $ 32.13 $ 205,506.50

INDEPENDENT STANDARDS 

TESTING ORGANIZATIONS

New Independent Standards 

Testing Organization 

Certification
18

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 

Hours per 

Response

Total 

Hours/Year

Total Labor 

Costs per 

Response

Total 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 Technician 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 21 1.00 - 41.00 50 $ 1936.46 $ 2,800.90

ANNUAL TOTAL N/A 4522.75 $ 1968.59 $ 208,307.40
19

Appendix 2

Agency Reporting Burden

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 2,200 0.08 0.08 176 $ 2.50 $ 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 

certification 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