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 : 1617.0 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 perso n repairing or servicing motor vehicles for consideration may perform any s ervice 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 after referred to as “refrigerant handling equipment”) and no such person may perform such service unless such person has been properl y trained and certified

. ” In 1992, EPA developed regulations under section 609 that were publishe d in 57 FR 3124 2 , 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 sectio n 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 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) standard s 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 accuratel y 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 laborato ry has been approved b y EPA, the application is kept on file in the SPD. Two laboratories

– Underwriters Laboratories In c . and Intertek/ETL Testing Laboratories

– are currentl y approved to test refrigerant handling equipment. EPA does not anticipate that any organizations will apply to EPA in the future to2

become approved independent standards testing organiz ations. 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 S PD for ap p roval by submitting verification that its program meets EPA standards. The 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 summ ary of the review and program changes to EPA every two years (as per 40 CFR §82.40 (c))

. After the test has been approved b y EPA, a hard copy remains on file with S PD. Currently , 19 t esting programs are approved by EPA to train technicians in the proper us e of refrigerant handling equipment. Five of these programs are designed specificall y 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 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 equipment will be located , the manufacturer name, equipment model number, date of manufa cture, 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 individual 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 technicians. Finally , any person who sells or distributes a class Ior cl ass 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 purchas es small contain ers of refrigerant for servicing motor vehicles, the seller must have a reason able basis for3

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 b y Section 609(d) of the Act and 40 CFR 82.36, 82.40, 82.42

. This includes certification of both approved equipment and properl y trained personnel. Section 609(b)(2)(A) and 40 CFR 82.38 require the approval of independent standards testing organization b y EPA. Automotive air conditioning technician certification programs are referred to in Section 609(b)(4) , and applicable require ments 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 and 40 CFR 82.42(b)(3). The reporting requirements for the motor vehicl e 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 onl y 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 properl y using, app roved 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), the 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

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 ty pe of equipment used and refrigerant being recovered. Since EPA d oes 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 , Underwriters Laborato ries (UL) and Intertek/ETL Testing Laboratories (ETL) certify e quip ment on a voluntary

basis. The Agency

established an approval sy stem at 40 CFR §82.38 to evaluate procedures of laboratories that may request approval in the future

. In formation 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 properl y test refrigerant handling equip ment. The4

Agency has required only the submission of information that will enable it to ensure that all approved laborat ories can test equipment under Agency 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 s ervice 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 inform ation 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 rapidl y changing nature of the motor vehicle air conditioning market, EPA requires that technician certification programs conduct internal reviews and update their program periodicall y. 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 istributors 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 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
- D uplication The specific information requested b y this notice is not currentl y collected by any other office within EPA or any other government agency. b) Public Noti c e Required Prior to I CR Submission to OMB5

In compliance with the Paperwork Reduction Act of 1995 , EPA issue d a public notice in the Federal Register soliciting publ ic 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 peri od concurrent with the submission of this I CR 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 Protec tion 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 condi tioning met several times , and discussed all aspects of the proposed regulati ons for Section 609 of the Act. To update this I CR, 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. V erificatio n 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 must take place to allow the Agency to approv e programs under the Act. e) General Guidelines Th e 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 / NAI CS Codes The following is a list of NAI CS codes for organizations potentially affected by the information requirements covered under this I CR . It is meant to include any establishment that may

service or maintain motor vehicle air conditioners. 441 1 Automobile Dealers 4413 Automotive Parts, Accesso ries, and Tire Stores 447 11 45299 All Other General Merchandise Stores 8111 98 All Other Automotive Repair and Maintenance Other affected groups include: In dependent Standards Testing Organizations Organizations with Technician Certification Programs b) In formation 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 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 b y 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 safel y meeting the standards set forth b y 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 appendic es 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 inc lude: 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 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 and7

repair of moto r 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 vehic le 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 ar e 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 ye ars. 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. Inaddition, the seller of small containers to an uncertified purchaser must be provided with a written statement that the containers are for resale onl y. The statement must also contain the purchaser’s name and address . Finall y, 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 F orm s : 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 b y the owner of the equipment or other responsible officer, and indicate th at 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 the 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 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 ye ars.8  Records of Class I or Class II Refrigerant in Small Containers S old for Re

- Sale : o Verify

that purchaser is properl y trained and certified

. o Compile , file , and keep for a minimum of three ye ars 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 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 ba sed 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

I dentical Equipment

 Substantially

I dentical 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 s ubmit to EPA verification that training program meets EPA requirements

.

 Technician Certification Program Review: 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 and User Certification F orms :9 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 require d.

 Records of Refrigerant 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 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 upd ates every two years. 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

distribute to service establishments that have purcha sed 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 the required information. The information submi tted 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

test whether refrigerant handling equipment compl ies 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 equip ment 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 S PD. 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 perf ormed either manuall y 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 S ectio n 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 contains 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 ye ar to comply with the provisions of Section 609. EPA expects a small number of technician certification program s 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, onl y 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 b y 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 recovery- onl y 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 solel y require that the resale

- onl y 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 periodicall y 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 anal ys is 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 I CR, with several exceptions. In this ICR, the maintenance of records of technician certification (of photocopyingand 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. Addition ally , in this I CR, the one - time equipment and user certification for compilation, preparation, and submission is estimated to require 0.1 7 hours (10 minutes) per establishment, wh ich remain unchanged from the previous ICR. Generally , this one

- time certific ation 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 req uirements 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 ye ar . 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 b y industry establishments, and these records can be stored as hard copies; there is no need for the creation (or maintenance) of a database sy stem . Therefore, no additional ho urs 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 Wage12

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 foll owing 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. 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

estimates 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. c) Estimating Agency Burden and Cost The basis of this anal ys is is the identification of the steps involved in implementing and operating the s ys tem. The costs associated with each step have been estimated by identifying the number of times the step will be und ertaken, 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 I CR. 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 hourl y labor costs for manag erial and clerical staff

, whose wage estimates are based on GS 1 2 step 2, and GS 7 step 2 hourly rates respectivel y . As shown , EPA estimates that the annual Agency burden for all ac tivities covered in this I CR 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 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

Estimates” for the General and Operations Manager (11

- 1021), Executive Secretaries and Administrative Assistants (43

- 6011), and Automotive Service Te chnicians 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/na ics4_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 app ropriate, they

are now sent directl y 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 trai ned and certified. However, b ased a decrease of number 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 ye ar . Assuming that MVAC service establishments 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 each ye ar . The previous ICR estimate d that 5 , 000 establishments per ye ar that send refrigerant off

site for handling , assuming all establishments sent refrigerant fro reclamation. However, b ecause 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 currentl y operating in the United States ( 4100) , 3 wi ll 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 27 5 purchases of small class Ior class II re frigerant containers made by uncertified purchasers for resale only

. Th is 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 appl y for approval. Additionally , no significantl y identical equipment is

3 BLS, 201114

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: 4,52 3 hrs. Total Annual Cost: $ 2 08 , 307 ii) The Agency Tally Total Annual Burden Hours: 188 hrs. Total Annual Cost: $ 6,22 4 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 previousl y approved IC R ’s supporting statement described an estimated burden or estimated a total annual respondent burden of 6,700 hours. By comparison, this I CR estimates a total annual burden of 4,52 3 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 2 4 to 19 since the previous ICR because several program s went out of business.

 The previous ICR estimated that 55 ,000 new technician certifications would be rec orded and filed b y owners of approved refrigerant handlin g equipment each ye ar. However, this I CR estimates the number to be 5 0 ,000. B ased on data collected in March 20 123 from some technician certification centers, it is estimated that 5 0 ,000 new MVAC technicians are certified each ye ar.

 In 20 08 it was estimated that there would be 1,370 purchases of small containers of class I and class II refrigerant for resale onl y b y uncertifie d purchasers. Itis 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 onl y 600 thousand R
- 12 MVACs on the road, or roughl y 8 0 % less than there were in 200 8 . Therefore, to15 a ccount 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 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 equip ment that was purchased before the proposal of the regulations to be approved b y EPA if it was substantially identical to equipment that had been certified b y 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 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 roughl y 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 I CR. g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 4, 5 2 3 hours, or less than one hour per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable in structions 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 spo nsor, and a person is not required to respond to, a collection of information unless it display s 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 I CR 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 holiday s. 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 electronicall y. When in the sy stem, select “search,” then key in the Docket ID Number identified above. Also, yo u 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 i n 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 MV** **ACs One**  **- Ti**  **me 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** 52 595 0.75 4472. 7 5 $ 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** 2 1 1 .00

- 41 .00 50 $ 1936.46 $ 2, 800.90 **ANNUAL TOTAL N/A**  **4 522.**  **7 5**  **$ 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**  **- Ti**  **me 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 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**