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ICR SUPPORTING STATEMENT OUTLINE

Part A of the Supporting Statement

National Refrigerant Recycling and Emissions Reduction Program

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This ICR is entitled “National Refrigerant Recycling and Emissions Reduction Program”, EPA 

ICR Number: 1626.12, OMB Control Number: 2060-0256

1(b) Short Characterization/Abstract

The Environmental Protection Agency (EPA) has developed regulations under the Clean 

Air Act Amendments of 1990 (the Act) establishing standards and requirements regarding the 

use and disposal of class I and class II refrigerants during the service, maintenance, repair, or 

disposal of refrigeration and air-conditioning equipment. Section 608(c) of the Act states that 

effective July 1, 1992 it is unlawful for any person in the course of maintaining, servicing, 

repairing, or disposing of refrigeration or air-conditioning equipment to knowingly vent or 

otherwise knowingly release or dispose of any class I or class II substance used as a refrigerant 

in the equipment in a manner which permits the substance to enter the environment. 

During 1993, EPA promulgated regulations under section 608 of the Act for the recycling 

of ozone-depleting refrigerants recovered during the servicing and disposal of air-conditioning 

and refrigeration equipment. These regulations were published on May 14, 1993 (58 FR 28660) 

and codified in 40 CFR subpart F (§ 82.150 et seq.). 

The regulations require persons servicing refrigeration and air-conditioning equipment to 

observe certain service practices that reduce emissions of ozone depleting refrigerants. The 

regulations also establish certification programs for technicians, recovery/recycling equipment, 

and off-site refrigerant reclaimers. In addition, EPA requires that ozone-depleting refrigerants 

contained "in bulk" in appliances be removed prior to disposal of the appliances and that all 

refrigeration and air-conditioning equipment, except for small appliances and room air 

conditioners, be provided with a servicing aperture that facilitates recovery of the refrigerant. 

Moreover, the Agency requires that substantial refrigerant leaks in equipment be repaired when 

they are discovered. These regulations significantly reduce emissions of ozone-depleting 

refrigerants, and therefore aid U.S. and global efforts to minimize damage to the ozone layer and 

the environment as a whole. 

To facilitate compliance with and enforcement of section 608 requirements, EPA requires 

reporting and recordkeeping requirements of technicians; technician certification programs; 

equipment testing organizations; refrigerant wholesalers and purchasers; refrigerant reclaimers; 
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refrigeration and air-conditioning equipment owners; and other establishments that perform 

refrigerant removal, service, or disposal. The recordkeeping requirements and periodic 

submission of reports to EPA's Office of Air and Radiation, Office of Atmospheric Programs 

occur on an annual, biannual, onetime, or occasional basis depending on the nature of the 

reporting entity and the length of time that the entity has been in service. Specific reporting and 

recordkeeping requirements were published in 58 FR 28660 and codified under 40 CFR subpart 

F (§82.166). Recordkeeping requirements for affected entities consist of the following: 

 programs certifying technicians must maintain records on each technician certified 

through their programs; 

 any distribution or, offer to sell or distribute any refrigerant must retain invoices that 

indicate the name of the purchaser, the date of sale, and the quantity;

 purchasers of refrigerants must maintain proof of technician certification;

 wholesalers of refrigerants must maintain refrigerant sales records;

 approved refrigerant recovery/recycling equipment testing organizations must maintain 

records of refrigerant recovery/recycling equipment testing and performance and 

refrigerant recovery/recycling equipment that meets EPA standards; 

 approved equipment testing organizations shall submit to EPA within 30 days of the 

certification of an new model line of recycling or recovery equipment;

 refrigerant reclaimers must maintain records on their customers and the quantity of 

material sent to them for reclamation;

 disposers of refrigeration and air-conditioning equipment must maintain copies of signed 

statements attesting that the refrigerant has been removed prior to final disposal of each 

appliance; 

 people servicing appliances normally containing 50 or more pounds of refrigerant must 

maintain service documents and provide service invoices to owner or operator; 

 owners or operators of appliances normally containing 50 or more pounds who add their 

own refrigerant must keep records of the amounts of refrigerant purchased and added to 

their appliances; and

 owners of refrigerant recovery equipment must certify that they have acquired and will 

properly use such equipment.

Periodic reports include the following: 

 approved technician certification programs must submit biannual reports on their pass/fail 

rates and the next year’s testing schedule; 

 approved refrigerant recovery/recycling equipment testing organizations must submit an 

annual list of refrigerant recovery/recycling equipment that meet EPA standards and must 

notify EPA whenever a model of refrigerant recovery/recycling equipment fails a threeyear recertification test;

 refrigerant reclaimers must submit annual reports noting the mass of refrigerant 

reclaimed by refrigerant type and the mass of waste products produced; 

 owners of industrial process refrigeration (IPR) equipment (i.e., appliances) whose 
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appliances fail a verification test and owners of industrial process refrigeration appliances 

and federally-owned commercial and comfort cooling appliances who wish to receive an 

extension or exclusion under the leak repair amendment are subject to additional 

reporting and recordkeeping requirements.

Copies of these reports are forwarded by the affected entities and stored at EPA headquarters. 

The previously Office of Management and Budget (OMB)-approved ICR 1626.10

expires on November 30, 2014. EPA has not promulgated any regulation that changes the 

recordkeeping or reporting requirements since the previous ICR renewal. Prior to submission of 

this ICR for renewal, EPA updated and verified the estimates of the number of respondents 

based on Agency experience in reviewing submitted reports from respondents, enforcement data, 

and Agency review of respondent applications for approval. EPA will continue to update the 

estimate of wages, taking into account any guidance provided by EPA's Office of Environmental 

Information and OMB.

EPA has estimated that there are 883,680 annual respondents consisting of representatives from 

the air-conditioning and refrigeration community, including but not limited to service repair 

shops, refrigerant reclaimers, and refrigerant wholesalers. The annual cost of collection and 

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

$14,202,991.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

In order to facilitate compliance with and enforce the section 608 requirements of the 

Act, EPA requires reporting and recordkeeping requirements of technicians, technician 

certification programs, refrigerant recovery/recycling equipment testing organizations, 

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

equipment owners, and other establishments that perform refrigerant removal, service, or 

disposal. Specific reporting and recordkeeping requirements were published in 58 FR 28660 and 

codified under 40 CFR subpart F (§82.166).

2(b) Practical Utility/Users of the Data

The purpose and need of this renewed collection request is to facilitate compliance with 

and enforcement of section 608 of the Act by reducing emissions of class I and class II ozonedepleting refrigerants to the lowest achievable level during the service, maintenance, repair, and 

disposal of appliances. EPA has used and will continue to use these records and reports to 

ensure that refrigerant releases are minimized during the recovery, recycling, and reclamation 

processes.
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This collection is a renewal of the previously OMB-approved Information Collection 

Request (ICR) Number 1626.11. The regulations implementing the above provisions were 

published in 58 FR 28660 and are codified at 40 CFR part 82, subpart F (§82.150 et seq.). 

Collection of this information was approved through November 30, 2014. 

EPA requires reporting and recordkeeping requirements of technicians, technician 

certification programs, refrigerant recovery/recycling equipment testing organizations, 

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

equipment owners, and other establishments that perform refrigerant removal, service, or 

disposal. The recordkeeping requirements and periodic submission of reports are made directly 

to EPA's Office of Air and Radiation.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-duplication

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

any other government agency with the exception of some chlorofluorocarbons (CFCs) listed 

under the Resource Conservation and Recovery Act (RCRA). However, since RCRA concerns 

itself with disposal of wastes and the recycling rule specifically requires that refrigerants be 

recovered rather than disposed, any information currently collected under RCRA would not be 

considered a duplication of effort. 

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

A Federal Register notice announcing our intent to renew this ICR was published July 

14, 2014. No comments were received.

3(c) Consultations

EPA consulted two refrigerant reclaimers, a refrigerant wholesaler, and two technician 

certification programs, all of whom confirmed our burden calculations.

3(d) Effects of Less Frequent Collection

The information requirements in the rule are either one-time, annual, semiannual, or 

occasional submissions depending on the nature of the reporting entity and the length of time 

that the entity has been in service. 

One-time submissions cannot be submitted less frequently by definition. These include 

the following:
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 Application for approval of refrigerant recovery/recycling equipment testing organizations; 

 Testing organization notification of newly certified or decertified recovery devices; 

 Application for approval of technician certification organizations; 

 Recovery device acquisition certification (by service and disposal establishments);

 Refrigerant reclaimer certification; 

 Owners of industrial process refrigeration equipment who need more than 30 days to 

complete repairs or more than one year to retrofit or replace equipment must submit 

documentation to EPA explaining their need for additional time. 

The information that is required to be submitted annually is detailed below. Collecting 

this information less than annually would hinder EPA enforcement efforts. 

 Testing organization notification of all previously certified recovery devices; 

 Approved technician certification organizations must submit a biannual activity report 

that includes the pass/fail rate and testing schedule for the next six months; and 

 Reclaimer reports on the quantities of used refrigerant received and processed. 

3(e) General Guidelines

Section 608(a)(3) of the Act requires maximization of the recapture and recycling of 

class I and class II ozone-depleting refrigerants. Enforcement of these provisions of the Act is 

insured by requiring annual reports of refrigerant recovery/recycling equipment test 

organizations and refrigerant reclaimers.

Biannual activity reports are required of programs certifying technicians. These activity 

reports allow EPA to determine the relative progress and success of these programs. This is 

imperative since each of these programs acts as a third party certifier on behalf of EPA. The 

reports also allow opportunities for feedback from the programs concerning test questions and 

question bank modifications.

There are instances under which EPA is requesting information within 30 days. Newly 

approved refrigerant recovery/recycling equipment testing organizations shall submit a list of all 

certified refrigerant recovery/recycling equipment to EPA within 30 days of the organization's 

approval by EPA. In order to ensure the maximization of recapture and recycling of class I and 

class II ozone-depleting refrigerants as mandated by section 608(a)(3)(B) of the Act, EPA 

established a 30-day reporting deadline for approved refrigerant recovery/recycling equipment 

testing organizations when a new model line of recycling/recovery equipment has been certified 

or when retests of refrigerant recovery/recycling equipment show that a previously certified 

model line fails to meet EPA requirements. A deadline of greater than 30 days, might allow 

refrigerant recovery/recycling equipment that is faulty or below standard into commerce. Once 

substandard refrigerant recovery/recycling equipment entered circulation, the chances of a recall 

are less likely and the opportunity for refrigerant venting from substandard equipment increases.
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To reduce the emissions of class I and class II ozone-depleting refrigerants to the lowest 

achievable amount, EPA is requesting continued collection of information concerning the 

following leak repair reporting and recordkeeping requirements, in accordance with 40 CFR 

82.156:

 Owners/operators of commercial and comfort cooling appliances and owners of IPR who 

decide to retrofit/retire appliances instead of repairing them must maintain a retrofit/retire 

plan at their place of business.

o Those taking the retrofit/retire option have three paths to choose from to 

determine the total time allowed to complete the retrofit/retirement of their 

equipment. The three paths are determined by: (1) If the appliance is custom 

built, the owners or operators may apply to EPA for an extension to the leak 

repair time frames due to a lack of parts availability (i.e., more than 30 weeks 

needed for parts to become available) or (2) other regulations require delays or a 

suitable replacement refrigerant with a lower ozone-depleting potential is not 

available or (3) more than two years are needed for the retrofit/retirement. For

(1) and (2), the owner/operator must submit an extension request in the form of a 

report to EPA within six months after the end of the 30-day period initiated by the 

original determination that their appliance leaked above 35%. They must also 

maintain records adequate to determine that the appliance is custom built and that 

parts are not available. Owners/operators can seek further extensions by 

submitting an additional extension request within 30-days of discovering the need 

for more time. For (3), the owner/operator determines that an additional year is 

required in addition to the original year granted under (1), the owner/operator can 

submit a request in the form of a report for additional time to complete the 

retrofit/retirement.

 Owners/operators who take the leak repair option may seek an exemption to the 30-day 

repair option by submitting a report to EPA within 30 days of determination, but only if they 

site availability of parts as the reason for the request.

o Upon a failed follow-up verification test for IPR or under some circumstances 

owners/operators of federally owned comfort cooling and commercial appliances, the 

owner or operator is required to report to EPA that the verification test failed and 

develop a retrofit/retirement plan within 30-days. The plan is maintained onsite, and 

the original plan must be readily available to EPA upon request. 

o Once retrofit/retirement is required as a result of failed verification, the 

owner/operator of IPR or under some circumstances owners/operators of federally 

owned comfort cooling and commercial appliances may seek relief from the 

retrofit/retirement plan by following one of two options for second repair efforts, in 

accordance with 40 CFR 82.156(i)(6), (i)(3)(ii), and (i)(3)(iii).

1. Report to EPA within 30 days of successful verification that second repair 

attempts held. This report results from the repairs of the same leaks 

subject to the first repair efforts within 30 days of the original failed 
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follow-up verification test.

2. Report to EPA within 30 days that the obligation to retrofit/replace is 

relieved. This report results from an inclusion in the original notification 

to EPA of the parameters used to establish that a leak rate is less than 

35%. Such notification allows the owner/operator 180 days from the 

original failed verification to determine the leak rate using the approved 

parameters. 

The requirements of this collection do not exceed any other guidelines. 

3(f) Confidentiality

The information collected under this ICR renewal is used to facilitate compliance with 

and enforcement of section 608 of the Clean Air Act. The recordkeeping requirements and 

periodic submission of reports are not shared with parties outside of the Federal government. 

The handling and confidentiality of the reporting requirements for assuring computer data 

security; preventing disclosure, proper storage, and proper disposal follow EPA's confidentiality 

regulations (40 CFR 2.201 et seq.)

3(g) Sensitive Questions

This ICR renewal does not ask questions of a sensitive nature. The required 

recordkeeping and reporting requirements do not ask any questions concerning sexuality, 

religious beliefs, or other matters, usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents / North American Industry Classification System (NAICS) Codes

The following is a list of NAICS codes potentially affected by the manifest information 

requirements covered under this ICR: 

NAICS Category

81131 Commercial Industrial Machinery and Equipment (not Automotive and 

Electronic) Repair and Maintenance

811412 Appliance Repair and Maintenance

42193 Recyclable Material Wholesalers (Metal scrap and waste)

541380 Environmental Test Laboratories /Services
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443111 Household Appliance Stores

23511 Plumbing, Heating, Air Conditioning Contractors

42111 Automobile and Other Motor Vehicle Wholesalers

42112 Motor Vehicle Suppliers and New Parts Wholesalers

44131 Automotive Parts and Accessories Stores

311, 445120, 

237990, 236220, 

31212, 31211,

312113, 3118, 

324110, 3254, 

325

Owners/operators of industrial process refrigeration equipment

493210, 311, 

452910, 445110, 

447110, 493120, 

811310, 49312, 

49313

Owners/operators of commercial refrigeration equipment

45, 48, 53, 55, 

72, 622, 531312

Owners/operators of comfort cooling air-conditioning equipment

This listing is not all inclusive, but is consistent with the types of organizations potentially 

impacted by this Information Collection Request.

4(b) Information Requested

(i) Data items - including recordkeeping and reporting requirements

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

for a minimum of three years. Records are required in accordance with 40 CFR §82.166. 
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Reports are submitted from the respondents to EPA headquarters in a written or electronic media 

format. 

Recordkeeping

1. Certified technicians must maintain a copy of their certification. 

2. Programs certifying technicians must display at their place of business a copy of a letter 

stating EPA approval as required in 40 CFR 82, subpart F, appendix D section (g). 

3. Programs certifying technicians must maintain records, which include the names and 

addresses of all individuals taking the test, the scores of all certifications tests 

administered and the dates and locations of all testing administered as detailed in 40 CFR 

82, subpart F, appendix D, section (g). 

4. Persons who sell or distribute any class I or class II substance for use as a refrigerant 

must retain invoices that indicate the name of the purchaser, the date of sale, and the 

quantity of refrigerant purchased.

5. Refrigerant wholesalers are required to keep on file evidence that at least one technician 

of the purchaser is properly certified, and may only sell refrigerant to the purchaser or his 

authorized representative. 

6. Purchasers of any class I or class II ozone-depleting refrigerants who employ certified 

technicians must provide written proof of the certification to the wholesaler who sells 

them refrigerant. 

7. Approved refrigerant recovery/recycling equipment testing organizations must maintain 

records of refrigerant recovery/recycling equipment testing and performance and a list of 

refrigerant recovery/recycling equipment that meets EPA requirements. 

8. Reclaimers must maintain records on a transactional basis of the names and addresses of 

persons sending them material for reclamation and the quantity of the material (the 

combined mass of refrigerant and contaminants) sent to them for reclamation. 

9. Reclaimers must maintain records of the quantity of material sent to them for 

reclamation, the mass of refrigerant reclaimed by refrigerant type, and the mass of waste 

products. 

10. Persons disposing of small appliances, motor vehicle air conditioners (MVACs), and 

MVAC-like appliances must maintain copies of signed statements on-site at their place 

of business verifying that the refrigerant has been previously evacuated from the 

appliance or shipment of appliances. 

11. Persons servicing appliances normally containing 50 or more pounds of refrigerant must 

provide the owner/operator of such appliances with an invoice or other documentation, 

which indicates the amount of refrigerant added to the appliance. 

12. The owners/operators of appliances containing 50 or more pounds of refrigerant must 

keep servicing records documenting the date and type of service, as well as the quantity 

of refrigerant added. 

13. The owners/operators of appliances containing 50 or more pounds of refrigerant must 

keep records of refrigerant purchased and added to such appliances in cases where 

owners add their own refrigerant. 

Reporting
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1. Approved refrigerant recovery/recycling equipment testing organizations shall submit a 

list of all certified refrigerant recovery/recycling equipment to EPA within 30 days of the 

organization's approval by EPA and annually at the end of each calendar year thereafter. 

2. Approved refrigerant recovery/recycling equipment testing organizations shall submit to 

EPA within 30 days of the certification of a new model line of refrigerant 

recovery/recycling equipment the name of the manufacturer and the name and/or serial 

number of the model line. 

3. Approved refrigerant recovery/recycling equipment testing organizations shall notify 

EPA if retests of refrigerant recovery/recycling equipment or inspections of 

manufacturing facilities conducted pursuant to §82.158(j) show that a previously 

certified model line fails to meet EPA requirements. Such notification must be received 

within thirty days of the retest or inspection. 

4. Reclaimers must submit an application seeking approval as an EPA-certified refrigerant 

reclaimer. Certification is required prior to reclamation of any refrigerant consisting in 

part of a used class I or class II ozone-depleting substance that intended for resale to a 

new owner.

5. Reclaimers must report the quantity of material sent to them for reclamation, the mass of 

refrigerant reclaimed by refrigerant type, and the mass of waste products. Reclaimers 

must report this information to EPA annually within 30 days of the end of the calendar 

year. 

6. Certifying programs for technicians must submit an application seeking EPA approval. 

Agency approval is required prior to the organizations’ issuance of Section 608 

certification credentials

7. EPA must receive an activity report from all approved certifying programs by every 

January 30 and June 30 which includes the pass/fail rates and testing schedules as 

detailed in 40 CFR 82 subpart F, appendix D, section (g). 

8. 40 CFR §82.166 (n) requires that persons requesting extensions or exclusions from the 

leak repair requirements must submit in writing the reasons for the request. 

(ii) Respondent Activities 

Refrigerant Recovery/Recycling Equipment Certification - Independent testing of refrigerant 

recovery/recycling equipment is required to ensure that the refrigerant recovery/recycling 

equipment is capable of meeting the standards described in 40 CFR §82.158 and appendices B 

and C of the regulations. To ensure reliability and objectivity of the refrigerant 

recovery/recycling equipment certification programs are required to submit an application to 

EPA. 

Applications for refrigerant recovery/recycling equipment testing approval must include 

written information verifying the following: (l) the list of refrigerant recovery/recycling 

equipment present at the organization that will be used for testing refrigerant recovery/recycling 

equipment; (2) expertise in refrigerant recovery/recycling equipment testing and the technical 

experience of the organization's personnel; (3) thorough knowledge of the standards as they 

appear in 40 CFR §82.158 and appendices B and C of the regulation; and (4) a program for 
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verifying the performance of certified refrigerant recovery/recycling equipment over the long 

term.

The refrigerant recovery/recycling equipment testing organization must certify that it has 

no conflict of interest, and that it receives no direct or indirect financial benefit from the 

outcome of certification testing. The organization must agree to allow the Administrator access 

to records and personnel to verify the information contained in the application.

Organizations testing refrigerant recovery/recycling equipment must notify EPA of 

newly certified refrigerant recovery/recycling equipment, or if equipment previously certified 

fails the periodic re-test required by the regulation. Each such organization must also send an 

annual report to EPA naming all refrigerant recovery/recycling equipment that it has certified to 

date.

Reclaimers - Reclaimers are required to submit to EPA a statement containing the following (in 

accordance with 40 CFR §82.164): (1) the name and address of the reclaimer; (2) the list of 

equipment that will be used to reprocess and to analyze reclaimed refrigerant; (3) a certification 

that the refrigerant will be returned to at least the standard of purity set forth in (AirConditioning, Heating & Refrigeration Institute)’s ARI Standard 700, "Specifications for 

Fluorocarbon Refrigerants"; (4) a certification that the purity of the refrigerant will be verified 

using the methods set forth in ARI Standard 700; (5) a certification that no more than 1.5 percent 

of the refrigerant will be released during the reclamation process; (6) a certification that the 

wastes from the reclamation process will be disposed of in accordance with applicable laws and 

regulations; and (7) a certification that the information provided is true and correct. A 

responsible officer of the reclamation company must sign the statement.

Reclaimers must also submit to EPA annual reports detailing the total amount of used 

refrigerant sent for reclamation and the total amount of refrigerant by refrigerant type and waste 

products recovered (40 CFR §82.166(h)).

Service and Disposal Establishments - Persons maintaining, servicing, repairing, or disposing of 

air-conditioning or refrigeration equipment must submit to EPA a statement which includes the 

following (40 CFR §82.162(a)): (1) a certification that such person has acquired certified 

refrigerant recovery/recycling equipment and is complying with the requirements of the rule; (2) 

the name and address of the purchaser of the refrigerant recovery/recycling equipment; (3) the 

number of trucks operated by the establishment; (4) the name and address of the establishment 

where the refrigerant recovery/recycling equipment is or will be located; and (5) the 

manufacturer's name, the date of manufacture, and the model and serial number of the refrigerant 

recovery/recycling equipment. The owner of the refrigerant recovery/recycling equipment or 

another responsible officer must sign the statement certifying that the information given is true 

and correct.

Disposers are also required to maintain a copy of a signed statement (reference OMB 

form #2060-0256, The United States Environmental Protection Agency Refrigerant Recovery or 
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Recycling Device Acquisition Certification Form) for each piece of disposed equipment, thus 

demonstrating that all of the remaining refrigerant was recovered from the equipment before 

final disposal (40 CFR sections 82.156(f)(2) and 82.166(i)).

Technician Certification Programs - Persons seeking approval of technician certification 

programs are required to submit verification of the following (40 CFR §82.161(c) and appendix 

D): (1) ability to produce multiple versions of examinations for each test site; (2) sufficient 

internal capacity to process the scoring and the accompanying documentation; and (3) ability to 

ensure the confidentiality and security of test questions and answers. Testing organizations have 

to be able to provide proctors for examinations and have to verify the identity of technicians by 

examining photo identification. Technician certification programs are required to submit reports 

to EPA every six months that include information on the pass/fail rate and testing schedules.

Submissions for approval of technician certification programs that have already tested 

and certified technicians are required to include (1) verification that the program meets all of the 

standards set forth in the rule, or (2) verification that the program meets all of the standards set 

forth in the rule except for a few, in which case the program must submit verification that 

appropriate supplementary materials will be provided upon EPA's approval to all persons 

previously certified under the program (40 CFR 82.161(g)).

Technicians - Technicians are required to pass a certification test and to keep a wallet sized 

certification card (40 CFR 82.166(1)).

Owners of Industrial Process Refrigeration - Section 82.166(n) requires that the following 

information listed in (1) - (8) must be submitted by persons requesting extensions or exclusions 

from leak repair. These requirements (40 CFR 82.156) are only applicable in instances where 

owners/operators of appliances leaking above the specified trigger leak rates for the specific type 

of appliance that they own (e.g., federally owned commercial refrigeration appliance).

(1) identification of the facility; 

(2) the leak rate; 

(3) the method used to determine the leak rate and full charge; 

(4) the date a leak rate of greater than the allowable annual leak rate was discovered; 

(5) the location of leaks(s) to the extent determined to date; 

(6) any repair work that has been completed thus far and the date that work was completed; 

(7) the reasons why more than 30 days are needed to complete the work; 

(8) an estimate of when repair work will be completed; 

(9) a plan to fix other outstanding leaks for which repairs are planned but not yet completed 

to achieve a rate below the applicable allowable leak rate; and

(10) identification of the facility and date the original information regarding additional time 

beyond the initial 30 was filed, and notification of the determination that the leak rate no 

longer exceeds the allowable annual leak rate. 
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For instances where the owners or operators intend to establish that the appliance's 

annual leak rate does not exceed the applicable allowable annual leak rate in accordance with 

'82.156(i)(3)(v), the owner or operator is required to include item (9). Item (10) must be 

included within 30 days of determining that the leak rate does exceed the applicable allowable 

annual leak rate. In those cases, items (9) and (10) may replace items (7) and (8). 

The same records that are required to be submitted (above) by those requesting extension 

of compliance deadlines for leak repair, must also be maintained on-site 

Where the owners or operators intend to establish that the appliance's annual leak rate 

does not exceed the applicable allowable annual leak rate in accordance with §82.156(i)(3)(v), 

the owner or operator is required to include item (9). Item (10) must be included within 30 days 

of determining that the leak rate does exceed the applicable allowable annual leak rate. In those 

cases, items (9) and (10) may replace items (7) and (8) above.

The dates and types of verification tests performed and test results must be submitted to 

EPA within 30 days of conducting each test. 

§82. 166(o) requires that the following items are required for those persons wishing an 

extension of the retrofit/retirement requirements:

(1) the identification of the industrial process facility; 

(2) the leak rate; 

(3) the method used to determine the leak rate and full charge; 

(4) the date a leak rate of 35 percent or greater was discovered; 

(5) the location of leaks(s) to the extent determined to date; 

(6) any repair work that has been completed thus far and the date that work was 

completed; 

(7) a plan to complete the retrofit or replacement of the system; 

(8) the reasons why more than one year is necessary to retrofit or replace the system; 

(9) the date of notification to EPA; 

(10) an estimate of when retrofit or replacement work will be completed; 

(11) if time changes for original estimates result in moving the date of completion 

forward, documentation of the reason for these changes; 

(12) and the date of notification to EPA regarding a change in the estimate of when the 

work will be completed. 

Items (11) and (12) are required to be submitted only when such changes result in moving the 

date of completion forward, and will be submitted within 30 days of occurring. 

The same records that are required to be submitted, above, by those requesting extension 

of compliance deadlines for retrofitting, must also be maintained on-site. Items (11) and (12) are 

required to be submitted only when such changes result in moving the date of completion 
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forward, and will be submitted within 30 days of occurring. 

40 CFR 82.166(p)(1) permits persons who wish to exclude purged refrigerants that are 

destroyed from annual leak rate calculations; however, the persons must maintain records on-site 

to support the amount of refrigerant claimed as sent for destruction. Records shall be based on a 

monitoring strategy that provides reliable data to demonstrate that the amount of refrigerant sent 

for destruction corresponds with the amount of refrigerant purged. Records shall include:

(1) flow rate; 

(2) quantity or concentration of the refrigerant in the vent stream; and 

(3) periods of purge flow. 

40 CFR 82.166(q) permits persons to calculate the full charge of an affected appliance by 

establishing a range based on the best available data and the normal operating characteristics and 

conditions for the appliance. The mid-point of the range will serve as the full charge, and where 

records are maintained they shall include:

(1) the identification of the owner or operator of the appliance;

(2) the location of the appliance;

(3) the original range for the full charge of the appliance, its midpoint, and how the range 

was determined; 

(4) any and all revisions of the full charge range and how they were determined; and

(5) the dates such revisions occurred. 

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Agency activities associated with the review of the reports and recordkeeping 

requirements for the National Recycling Program consist of reviewing the following: 

 Applications from independent refrigerant recovery/recycling equipment testing labs that 

wish to certify recovery/recycling equipment;

 Lists of certified refrigerant recovery/recycling equipment submitted annually by testing 

organizations;

 Notices of new refrigerant recovery/recycling equipment certification and of decertification 

of previously certified refrigerant recovery/recycling equipment;

 Applications for service establishment certification;

 Applications for disposer certification;

 Applications for reclaimer certification; 

 Annual reports from reclaimers on their activities; 

 Applications for approval to conduct technician certification programs; 
15

 Reports submitted by approved technician certification programs; and 

 Submissions from owners of industrial process refrigeration equipment. 

5(b) Collection Methodology and Management

EPA has not developed required reporting forms or applications, although it has 

developed a sample form intended to facilitate certification by owners of recovery/recycling 

equipment (reference the enclosed OMB form #2060-0256, The United States Environmental 

Protection Agency Refrigerant Recovery or Recycling Device Acquisition Certification Form). 

Entities are encouraged to submit the required information in a format compatible with their 

existing recordkeeping practices. The information submitted by each member of the regulated 

community will be stored at EPA headquarters for review and reference. 

EPA has determined that periodic on-site inspection is the most effective method to 

ensure compliance with section 608. The records should be kept at the location where service or 

disposal of equipment involving refrigerant is performed or refrigerant is sold, distributed, or 

reclaimed. 

5(c) Small Entity Flexibility

The regulations permit technicians who work on small appliances to become certified 

through passage of a take-home test rather than a proctored test. This provision was 

implemented in recognition of the facts that (1) entities servicing small appliances are often 

small businesses, (2) many of these entities only rarely perform service on the refrigerant circuit 

of small appliances, and (3) the quantity of refrigerant in small appliances is less than five 

pounds. For similar reasons, individuals who recover refrigerant from small appliances and 

motor vehicle air conditioners (MVACs) when they are disposed of are not required to be 

certified at all and are not required to use certified refrigerant recovery/recycling equipment. 

Several of the recordkeeping and reporting requirements of the rule are intended to 

permit entities greater flexibility in complying with the regulation. Final persons in the disposal 

process for small appliances and MVACs may elect not to perform refrigerant recovery 

themselves so long as they obtain a signed statement from persons upstream in the disposal 

process that the refrigerant has been removed already. Thus, the signed statement permits the 

final disposer to delegate responsibility for refrigerant removal. Owners of appliances that leak 

above a certain level may elect to retrofit or replace their appliances rather than repair them so 

long as they develop a retrofit or retirement plan. Thus, the plan permits the owner greater 

flexibility in reducing refrigerant emissions. Owners of industrial process refrigeration 

equipment may take longer than 30 days to complete repairs or longer than one year to retrofit or 

replace equipment so long as they submit documentation to EPA explaining their need for 

additional time. Again, the reporting permits the owner greater flexibility in compliance. 

5(d) Collection Schedule
16

EPA requires maintenance of the following records for a minimum of three (3) years.

 Organizations operating refrigerant recovery/recycling equipment certification 

programs must complete a onetime application for approval from EPA. The approved 

refrigerant recovery/recycling equipment testing organizations must report when new 

equipment passes the certification test, when previously certified equipment fails 

retesting or inspection, and provide an annual report of the equipment that the 

organization has certified.

 Service establishments must complete a one-time certification requirement to EPA.

 Establishments that recover refrigerant from appliances, machines, or other goods at 

disposal must complete a onetime registration requirement. 

 Reclaimers must complete a onetime certification and approved reclaimers must report 

annually on their reclamation activities. 

 Organizations seeking approval to conduct technician certification programs must 

complete a onetime application for approval from EPA to do so, and after approval are 

required to submit a semiannual report to EPA. 

 Owners of industrial process refrigeration equipment must submit a onetime request if 

they wish to obtain an extension or exclusion described above. It is collected so that 

EPA may determine whether an extension or exclusion should be granted. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section provides burden tables that provide the numerical basis for the annual 

burden and cost of this ICR renewal by detailing the following:

 EPA’s rationale in preparing respondent burden and cost tables; 

 estimating respondent and Agency burden (hours to complete required activities);

 estimating respondent and Agency labor costs and costs of capital associated with the 

those activities; 

 developing universe estimates; and 

 calculating burden and cost totals.

The collection activities defined in Sections 4 and 5 are referenced to develop the 

aforementioned estimates. The activities for which EPA has estimated burden and cost 

correspond directly with the activities listed in Sections 4 and 5. 

6(a) Estimating Respondent Burden

Estimates of respondent burden and cost for the rule are presented below. All hour 

estimates are based on EPA's experience implementing this program and on EPA's best 
17

professional judgment. The overall reporting and recordkeeping burden for the rule has dropped 

significantly since the original ICR was developed because much of the burden calculated in the 

original ICR was associated with the start-up of the program, which is now complete. Thus, all 

burden hours and costs presented here are annual. None of the reporting or recordkeeping 

requirements is expected to have associated capital costs.

6(b) Estimating Respondent Costs

Based upon the burden hours, EPA has estimated the labor cost per respondent and the 

capital costs required to complete each activity. The total cost for each respondent activity is 

comprised of the following:

 Labor Cost (for legal, managerial, technical, clerical, and other employees);

 Capital/Start-up Cost (for equipment, machinery, and construction); and

 Operating and Maintenance (O&M) Cost (for labor and equipment needed over time as 

well as for the purchase of services).

(i) Estimating Labor Costs

EPA has consulted the original ICR to obtain the appropriate baseline labor rates for each 

labor category. The labor rates reflect the total cost to employ an individual and include 

estimates of salaries and overhead costs.

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

affected entities below. In deriving these costs, EPA used the median hourly earnings of $21.10

for heating, air-conditioning, and refrigeration mechanics and installers from the Bureau of 

Labor Statistics.

1 EPA then multiplied this number by 110% for overhead ($21.10 x 1.10 = 

$23.21). The resulting cost of $44.31 ($21.10 + $23.21) is the average hourly administrative 

cost of labor plus overhead for a private firm.

(ii) Estimating Capital and Operations and Maintenance Costs

According to the 1995 PRA, burden is the "total time, effort, or financial resources

expended by persons to generate, maintain, retain, or disclose or provide information to or for a 

Federal agency." Any activity that is not usual and customary is considered a burden. This ICR 

renewal includes the time needed to review instructions, maintaining records, completing 

paperwork, gathering information, and reporting information. The Agency has also included 

costs associated with the information collection activities, such as capital costs and operations 

and maintenance (O&M) costs.

As part of the submission to OMB, EPA has estimated all costs for respondents to 

comply with required Agency activities that are not incurred by persons in their normal course of 

 

1 Bureau of Labor Statistics, U.S. Department of Labor, Occupational Employment and Wages, May 2013, Heating, 

Air Conditioning, and Refrigeration Mechanics and Installers, on the Internet 

at http://www.bls.gov/oes/current/oes499021.htm (visited June 20, 2014).
18

activities. Capital used for the routine and usual functioning of a company, or for a technical 

requirement for which there is no reporting or keeping of information, have not been included as 

an ICR capital or O&M cost. 

(iii) Capital/Start-up vs. Operating and Maintenance (O&M) Costs

There are two types of non-labor related costs -- capital/start-up costs and operating and 

maintenance (O&M) costs. One-time capital/start-up costs usually include any produced 

physical good needed to provide the necessary information. Start-up capital must be purchased 

for the specific purpose of satisfying EPA’s reporting or recordkeeping requirements. Capital 

goods include computers, machinery, or equipment. Start-up capital costs are usually incurred at 

the beginning of an information collection period and are usually incurred only once. In addition 

to the actual acquisition of start-up capital, one-time activities associated with the production of 

capital have also been evaluated. The Agency has considered capital/start-up costs and O&M 

costs in determining that there are no non-labor related costs associated with this ICR renewal.

O&M costs are those costs associated with a paperwork requirement incurred 

continuously over the life of the ICR. They are defined by the PRA as "the recurring dollar 

amount of cost associated with O&M or purchasing services." The reporting costs associated 

with this ICR renewal have been included, and include costs for file storage, photocopying, and 

postage. 

(iv) Annualizing Capital Costs

Annualized costs represent the amount of an annuity that would have to be paid over a 

specific period of time that makes an individual indifferent between paying either the stream of 

payments or the up-front costs in one lump-sum. This renewal ICR does not include capital 

costs, since there were none associated with the original ICR. There has not been any 

rulemaking associated with this ICR renewal that would have an associated capital cost.

1. Refrigerant Recovery/Recycling Equipment Testing Organizations 

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Submit to EPA an annual list 

of all refrigerant 

recovery/recycling 

equipment previously 

certified

4.0 $ 177.24

Maintain records of 

equipment tested and its 

performance 

0.125 $ 5.54

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

organizations approved by EPA are estimated to spend four hours each year preparing and 

submitting a list of all refrigerant recovery/recycling equipment previously certified, equipment 

that has failed retests or inspections, and new models that are tested and meet the certification 
19

requirements. EPA estimates that 1/8 hr is required to maintain records of the tests as these 

would be maintained as a part of normal business practices. The $44.31 per hour estimate of cost 

is the average hourly administrative labor cost, including direct labor and overhead, for a private 

firm.

Based on EPA's experience over past years, it is not anticipated that additional entities 

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

2. Certification by Service Establishments that Change Ownership or Enter the 

Market

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Compile information, 

complete certification 

requirements

1.0 $44.31

The estimated burden of one hour is for each service establishment to collect 

information, certify to EPA that it is capable of and will follow requirements of the rule, and 

maintain adequate documentation of employee certification. EPA assumes that it takes each 

service establishment one hour to complete the certification form and submit it to the appropriate 

EPA regional office for the state in which they reside. The $44.31 per hour estimate of cost is 

the average hourly administrative labor cost, including direct labor and overhead, of a private 

firm.

3. Certification by Disposal Establishments that Change Ownership or Enter the 

Market

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Compile information, 

complete certification 

requirements

1.0 $44.31

The estimated burden of one hour is for each disposal establishment to collect 

information and certify to EPA that it is capable of and will follow requirements of the Recycling 

Rule. The $44.31 per hour estimate of cost is the average hourly administrative labor cost, 

including direct labor and overhead, of a private firm. 

4. Maintenance of Copies of Signed Statements by Disposal Establishments

Annual Respondent Burden
20

Collection Activities Burden Hours Annual Labor Costs

Maintain copies of signed 

statements verifying 

evacuation of refrigerant 

13 $576.03

The industry burden is the costs for collecting and maintaining copies of signed 

statements verifying that refrigerant has been removed from appliances before they are accepted 

for disposal. An estimated three minutes (0.05 hrs) per business day is spent filing the 

statements. The estimated annual amount of statements verified per disposal facility is 260, 

assuming these are verified on a daily basis. The $44.31 per hour estimate of cost is the average 

hourly administrative labor cost, including direct labor and overhead, for a private firm. 

5. Certification by Refrigerant Reclaimers that Change Ownership or Enter the 

Market 

Annual Respondent Burden

EPA assumes that it takes an average of five hours for each of these organizations to 

prepare their certification packages. The $44.31 per hour estimate of cost is the average hourly 

administrative labor cost, including direct labor and overhead, for a private firm. 

6. Reclaimer Reporting and Record Keeping

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Submit annual reports to 

EPA Headquarters

5.0 $221.55

Maintain copies of 

transactional records 

6.25 $276.94

Reclaimers must maintain records on quantity of refrigerant received, quantity reclaimed, 

and mass of waste products generated, and report yearly totals to EPA. Compiling this 

information, preparing it for EPA, and submitting it to EPA is estimated to take five hours per 

year. Reclaimers must also maintain records of refrigerant sales transactions; it is assumed that 

each reclaimer will spend 0.125 hours. The amount of recordkeeping actions per reclaimer is 

estimated to be 50. Therefore, each reclaimer will spend 6.25 hours maintaining such records on 

an annual basis. The $44.31 per hour estimate of cost is the average hourly administrative labor 

Collection Activities Burden Hours Annual Labor Costs

Completing certification and 

submitting it to EPA 

Headquarters

5.0 $221.55
21

cost, including direct labor and overhead, for a private firm.
22

7. Refrigerant Wholesalers

Annual Respondent Burden

EPA assumes that each refrigerant wholesaler must spend on average approximately two 

minutes maintaining transactional records indicating the name of the purchaser, date of sale, and 

the quantity of refrigerant purchased, as well as a copy of the certification card for an employee 

of the purchaser. EPA estimates that each refrigerant wholesaler performs 25 recordkeeping 

actions per year. Therefore the estimated annual burden time in hours is 0.83. The $44.31 per 

hour estimate of cost is the average hourly administrative labor cost, including direct labor and 

overhead, for a private firm. 

8. Technician Certification Programs Applying for Approval and Recordkeeping

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Compiling information to 

become approved and 

submitting it to EPA 

Headquarters 

5.0 $221.55

The EPA estimates that it will take five hours to compile the necessary information to 

apply for the certification program approval. The $44.31 per hour estimate of cost is the average 

hourly administrative labor cost, including direct labor and overhead, for a private firm. 

9. Recordkeeping and Biannual Reporting by Existing Technician Certification 

Programs

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Submit biannual reports to 

EPA 2.0 $88.62

Maintain records of the 

applicants’ name, address, 

and scoring results

5.0 $221.55

Ninety-One testing organizations are estimated to spend two hours each year per firm 

submitting statistical information on their tests (1 hour for each six-month report). The biannual 

Collection Activities Burden Hours Annual Labor Costs

Retain invoices indicating 

purchaser, date of sale, and 

quantity of refrigerant 

purchased.

Maintain technician 

certification credentials of 

purchaser’s employee

0.83 $36.78
23

reports summarize information on the numbers of previously certified individuals, individuals 

taking the tests, scores of all certification tests as well as the dates and locations of all tests 

administered. EPA estimates that 5 hours per year are spent on maintaining records of the 

individuals certified. The $44.31 per hour estimate of labor cost is the average hourly 

administrative labor cost, including direct labor and overhead, for a private firm. 

10. Technicians Applying for Certification and Maintaining Certification Cards

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Acquire initial certification 0.0167 $0.74

Maintain certification card 0.0167 $0.74

It is estimated that approximately 10 percent of the estimated 300,000 technician labor 

force turns over each year, necessitating certification. EPA estimates that each technician will 

spend one minute maintaining a copy of the certification card. 

11. Owners of Refrigeration and Air-Conditioning Equipment

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Keep service records for 

appliances containing more 

than 50 lbs of refrigerant 

stating the date and type of 

service, the quantity of 

refrigerant added, and 

quantities of refrigerant 

purchased 

0.025 $1.11

EPA assumes that owners/operators of industrial process refrigeration, comfort cooling, 

and commercial refrigeration equipment (i.e., appliances) with charge sizes greater than 50 lbs 

will maintain service records indicating what was done to their equipment, whether performed by 

in-house service personnel or contracted out, will be maintained as a part of normal operating 

procedures. Approximately two additional minutes may be needed to maintain purchase and 

service orders. The $44.31 per hour estimate of labor cost is the average hourly administrative 

labor cost, including direct labor and overhead, for a private firm. 

12. Persons Servicing Refrigeration and Air-Conditioning Equipment

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Provide service records to 

owners/operators of 

appliances with refrigerant 

0.025 $1.11
24

Collection Activities Burden Hours Annual Labor Costs

charges greater than 50 lbs 

with an invoice stating the 

amount of refrigerant added 

to the appliance 

EPA assumes that owners/operators of industrial process refrigeration, comfort cooling, 

and commercial refrigeration equipment (i.e., appliances) with charge sizes greater than 50 lbs 

will maintain service records indicating what was done to their equipment, whether performed by 

in-house service personnel or contracted out, will be maintained as a part of normal operating 

procedures. Approximately two additional minutes may be needed to maintain purchase and 

service orders. The $44.31 per hour estimate of labor cost is the average hourly administrative 

labor cost, including direct labor and overhead, for a private firm. 

13. Leak Repair Requirements for Owners of Industrial Process Refrigeration 

Annual Respondent Burden

Collection Activities Burden Hours Annual Labor Costs

Submit requests for 30-day 

extensions

(IPR and in limited instances 

federally owned equipment)

0.5 $22.16

Submit requests for retrofit 

extensions

(IPR and in limited instances 

federally owned equipment)

0.5 $22.16

Maintain information on 

purged and destroyed 

refrigerant 

0.025 $1.11

Maintain information on the 

calculation of the full charge 

using a range

0.025 $1.11

Maintain reports on the 

results of verification tests 

(IPR and in limited instances 

federally owned equipment)

0.025 $1.11

Prepare and maintain plan to 

retire, replace, or retrofit 

equipment

8.0 $354.48

The basis of the analysis is the identification of the steps involved in seeking an extension 

to or exclusion from the leak repair provisions. These costs 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 costs. Each hour of industry time is valued at $44.31. This value

represents an average hourly rate of pay for a private firm and is based on anecdotal information 
25

gleaned through the operation of the allowance tracking system during the past years.

Industrial Process Refrigeration, Comfort Cooling, and Commercial Refrigeration 

appliances have the option, and in limited cases are mandated, to create and maintain plans to 

retire/retrofit their equipment under the leak repair requirements of 40 CFR 82.156. The 

estimated burden of 8 hours is for equipment owners who decide not to repair leaks and 

subsequently must develop and maintain a plan showing that the equipment will be retired, 

replaced, or retrofitted. It is further assumed that five percent of all equipment owners will elect 

to proceed with such a plan rather than repair leaks. The $44.06 per hour estimate of cost is the 

average hourly administrative labor cost, including direct labor and overhead, for a private firm. 

6(c) Estimating Agency Burden and Cost

The hourly rate for EPA staff at the GS-9 Step 1 level is $20.11 per hour. This hourly 

basic rate is from the GS salary schedule listed in the Federal Wage Page of the Office of 

Personnel Management website http://www.opm.gov/oca. EPA then multiplied the hourly rate 

by the standard government benefits and overhead multiplication factor of 1.6. The resulting rate 

that was used in estimating annual Agency burden and cost is $32.18 ($20.11 x 1.6).

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

affected community in determining the number of respondents for which the Agency would 

assume the burden of review or response. The following paragraphs describe the amount and 

degree of burden endured by EPA review of required respondents’ reports.

 Each year, EPA will review annual reports submitted by the two testing organizations for 

completeness and to make sure that EPA's list of certified refrigerant recovery/recycling 

equipment is complete. Each evaluation will require one-half hour, for a total of one hour 

per year. 

 EPA assumes, based on previous data, that there are 22,000 to 45,000 service establishments 

in the United States. However due to the continuing phase out of ozone depleting 

refrigerants, EPA assumes that the number of establishments entering the workplace that are 

servicing equipment containing ozone-depleting refrigerants is declining and those 

establishments that leave the workplace is increasing. EPA estimates that five percent of 

45,000 establishments (2,250) are assumed to enter or change ownership annually, 

necessitating certification. EPA personnel are assumed to spend 15 minutes reviewing each 

certification from service establishments. Thus requiring 562.5 hours per year for review.

 EPA estimates that there are 7,500 disposal establishments that are considered new 

companies or change ownership during the year. EPA assumes that the number of 

establishments entering the workplace remains constant with the numbers that leave the 

workplace. Most of these have already fulfilled this one-time certification requirement, but 

five percent of these (375) are assumed to change ownership annually, necessitating 

recertification. EPA Regional personnel are assumed to spend 15 minutes reviewing each 

certification from 375 disposal establishments. Thus requiring 93.75 hours per year for 

review.

 EPA currently has 60 certified refrigerant reclaimers who must submit annual activity 

reports. Based on EPA's experience, it is assumed that four new refrigerant reclaimers per 

year will submit one-time applications to EPA to be certified. EPA is assumed to spend one 

hour reviewing and approving each certification for a total of four hours per year. In 

addition, EPA will spend one hour reviewing each of the annual reports submitted by the 60
26

reclaimers, for a total of 60 hours per year.

 EPA currently has 91 certified technician certifying programs. Each program is required to 

submit biannual activity reports to EPA. EPA will spend one hour each reviewing biannual 

activity reports submitted by the 91 technician testing organizations, for a total of 182 hours 

per year. Based on EPA's experience, the Agency expects to certify five new organizations 

per year. EPA expects to spend two hours reviewing and approving each application, for a 

total of 10 hours per year. 

 EPA estimates that it takes one-half hour to review and make a determination on each of the 

anticipated 15 requests from owner/operators of industrial process refrigeration equipment 

for an extension to the 30-day repair requirement for mandatory leak repair, for a total of 7.5 

hours per year. 

 EPA estimates one hour to review and make a determination on five anticipated request 

from the owner/operator of IPR equipment for an extension to the one-year retrofit 

requirement under the leak repair requirements, for a total of five hours a year. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

The respondent universe as well as the frequency of reporting is defined in 40 CFR 

subpart F, and includes the number of respondents for established refrigerant recovery/recycling 

equipment testing organizations; averages for the number of service establishments, disposers, 

and refrigerant reclaimers that enter the market or change ownership; refrigerant wholesalers; 

technician certification programs; technicians acquiring certification and maintaining 

certification cards; owners of refrigeration and air-conditioning equipment; and owners of 

industrial process refrigeration equipment.

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

affected community in determining the number of respondents (or the respondent universe). The 

estimates are based upon EPA's experience in implementing the rule since 1993. A listing of 

these entities follows:

 Testing organizations for refrigerant recovery/recycling equipment have remained at two 

organizations since inception of the regulations during May 1993. 

 The preamble to the Recycling Rule notes that there are 22,000 to 45,000 service 

establishments in the United States. The continuing phase out of ozone depleting 

refrigerants has resulted in a five percent net loss of service establishments for a total 

number of 42,750. Most service establishments have already fulfilled these one-time 

requirements, but roughly five percent of 42,750 establishments (~2,250) are assumed to 

change ownership annually, thus necessitating recertification. 

 EPA estimates the existence of 7,500 disposal establishments. Most of these have 

already fulfilled this one-time requirement, but five percent of these (375) are assumed 

to change ownership annually, necessitating recertification. 

 EPA currently has 60 certified refrigerant reclaimers who must submit annual activity 

reports. Based on EPA's experience, it is assumed that four (4) reclaimers per year will 

submit one-time applications to EPA to be certified. 
27

 EPA believes that the number of establishments that sell refrigerant has remain over the 

past few years, mainly due to the availability of refrigerant. This ICR renewal assumes 

that the number of wholesalers has remained 200,000.

 EPA currently has 91 certified technician certifying programs. Each program is required 

to submit biannual activity reports to EPA. Based on EPA's experience, five new 

organizations per year are estimated to take 5 hours each to assemble and submit 

materials to EPA requesting that they be authorized to test and certify technicians. 

 Statements from certifying organizations have actually claimed that the number of 

certified technicians entering the workplace is decreasing. Therefore, EPA assumes that 

there is no longer a 10% annual increase in the number of new technicians entering the 

workplace. EPA assumes that the number of technicians entering the workplace has 

remained constant with those that who have left the workforce. Thus this ICR renewal 

assumes that the number of technicians has remained constant at 300,000.

 Under limited circumstances, EPA allows owners/operators of industrial process 

refrigeration equipment with a charge size greater than 50 lbs of an ozone-depleting 

refrigerant to submit a written request for an extension to leak repair requirements. The 

number of occurrences of each of the activities is based on the estimated number of 

requests for extension and/or exclusion by an estimated number of entities that will 

likely choose to make such a request. Based on the volume of requests submitted to 

EPA, the Agency estimates that approximately 20 owners/operators of appliances will 

take advantage of the extensions and exclusion each year. EPA estimates the breakdown 

to be for 15 owners/operators seeking extensions to the 30-day leak repair requirement, 

and 5 owners/operators seeking extensions to the one-year retrofit requirement. 

 Based on actual submissions to EPA, the Agency estimates that two owners/operators of 

comfort cooling, commercial refrigeration, and industrial process refrigeration 

equipment with charge sizes greater than 50 lbs of an ozone-depleting refrigerant will 

choose to exclude the amount of purged and destroyed refrigerant from their leak rate 

calculations. Therefore only two owners/operators are estimated to maintain 

information substantiating the amount of refrigerant purged or destroyed. 

 EPA estimates that 200,000 owners/operators will maintain records showing how they 

calculated the full charge of their equipment using a range. 

 EPA estimates that 5,000 owners/operators will spend 8 hours developing a 

retrofit/retirement plan for their appliances, and maintain the required retire/retrofit 

report on-site at their place of business.

 Owners/operators of refrigeration and air-conditioning equipment with a charge greater 

than 50 lbs of an ozone-depleting refrigerant are required to maintain service records 

documenting the date and type of service, as well as the quantity of refrigerant added, in 

accordance with 40 CFR 82.166(k). EPA assumes that these records are maintained as a 

part of normal business procedures. EPA also assumes that the number of

owners/operators entering the field remains constant (at approximately 20,500) with the 

number of owners/operators whose organizations go out of business. 

 Persons servicing refrigeration and air-conditioning equipment with a charge greater 

than 50 lbs of an ozone-depleting refrigerant are required to provide their customers 
28

with an invoice indicating the amount of refrigerant added to the appliance. EPA 

assumes that these records are submitted as a part of normal business procedures to an 

estimated 20,500 owners/operators who would require service, and in fact are required 

between the two parties in order to initiate payment for services rendered. EPA estimates 

that no more than additional minutes would be needed to meet this requirement.

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for respondents and the Agency are 

summarized below for all activities.

(i) Respondent Tally

ANNUAL RESPONDENT BURDEN AND COST

Activity

Number of 

Respondents

Number of 

Responses 

per 

Respondent

Burden Hours 

(Time) per 

Response

Total Hours per 

Year for all 

Respondents Total Labor Costs 

REPORTING

Refrigerant Recovery/ Recycling 

Equipment Testing Organizations -

Submit reports on approved 

equipment (including new model 

lines and failed retests/inspections)

2 1 4 8 $354.48

Certification by Owners of 

Refrigerant Recovery/ Recycling 

Equipment (or Service 

Established) that Change 

Ownership or Enter the Market

Compile information, complete 

certification requirements

2,250 1 1 2,250 $99,697.50

Certification by Disposal 

Establishments that change 

Ownership or Enter the Market 375 1 1 375 $16,616.25

Certification by Refrigerant 

Reclaimers that Change Ownership 

or Enter the Market 4 1 5 20 $886.20

Reclaimer Annual Activity Report 60 1 5 300 $13,293.00

Technician Certification Programs 

Applying for Approval 5 1 5 25 $1,107.75

Biannual Reporting by Existing 

Technician Certification Programs 91 2 1 182 $8,064.42

Owners/operators of appliances 

w/charge sizes >50 lbs prepare & 15 1 0.5 7.5 $332.33
29

Activity

Number of 

Respondents

Number of 

Responses 

per 

Respondent

Burden Hours 

(Time) per 

Response

Total Hours per 

Year for all 

Respondents Total Labor Costs 

submit requests for extensions to 

30-day repair timeline 

Owners/operators of appliances 

w/charge sizes >50 lbs prepare & 

submit requests for extensions to 1 

yr retrofit/retire timeline 5 1 0.5 2.5 $110.78

SUBTOTAL 2,807 varies varies 3,170 $140,462.70

RECORDKEEPING 

Refrigerant Recovery/ Recycling 

Equipment Testing Organizations 

- Maintain records of refrigerant 

recovery/recycling equipment 

tested and its performance 2 1 0.125 0.25 $11.08

Maintenance of copies of signed 

statements of previous refrigerant 

recovery by disposal 

establishments 7,500 260 0.05 97,500 $4,320,225.00

Reclaimer recordkeeping 60 50 0.125 375 $16,616.25

Refrigerant wholesalers 

recordkeeping for refrigerant sales, 

including maintenance of 

technician certification cards from 

purchasers employing at least one 

certified technician 200,000 25 0.033 165,000 $7,311,150.00

Record keeping by Existing 

Technician Certification Programs 91 1 5 455 $20,161.05

Technicians Acquiring 

Certification Cards 30,000 1 0.0167 501 $22,199.31

Technicians Maintaining 

Certification Cards 300,000 1 0.0167 5,010 $221,993.10

Persons servicing appliances 

w/charge sizes >50 lbs provide 

invoices to appliance 

owners/operators 20,500 1 0.025 512.5 $22,708.88

Owners/operators of appliances 

w/charge sizes >50 lbs maintain 

purchase and service records 20,500 1 0.025 512.5 $22,708.88

Owners/operators of appliances 

w/charge sizes >50 lbs - Maintain 

information on purged/destroyed 

refrigerant 2 1 0.025 0.05 $2.22
30

Activity

Number of 

Respondents

Number of 

Responses 

per 

Respondent

Burden Hours 

(Time) per 

Response

Total Hours per 

Year for all 

Respondents Total Labor Costs 

Owners/operators of appliances 

w/charge sizes >50 lbs -

Develop/Maintain plan to 

retire/replace or retrofit equipment, 

as applicable 5,000 1 8 40,000 $1,772,400.00

Owners/operators of appliances 

w/charge sizes >50 lbs - Maintain 

information on the calculation of 

the full charge using a range, as 

applicable 200,000 1 0.025 5,000 $221,550.00

Owners/operators of appliances 

w/charge sizes >50 lbs - Maintain 

reports on the results of 

verification tests (IPR and in 

limited instances federally owned 

equipment) 100,025 1 0.025 2,500.625 $110,802.69

SUBTOTAL 883,680 varies varies 317,367

 

$14,062,528.45

Total Number of Respondents = 883,680

Total Number of Annual Responses = 7,632,018

Annual Hour Burden = 320,537

Total Labor Costs = $14,202,991

(ii) The Agency Tally

ANNUAL AGENCY BURDEN AND COST

Activity

Number of 

Respondents

Number of 

Responses 

per 

Respondent

Agency 

Burden Hours 

(Time) to 

Review each

Response

Total Agency 

Hours per Year 

for all 

Respondents

Total Agency 

Labor Costs 

REVIEWING & RESPONDING

Refrigerant Recovery/ Recycling 

Equipment Testing Organizations -

Submit reports on approved 

equipment (including new model 

lines and failed retests/inspections)

2 1 0.5 1 $32.18

Certification by Owners of 

Refrigerant Recovery/ Recycling 

Equipment (or Service 2,250 1 0.25 562.5 $18,099.00
31

Activity

Number of 

Respondents

Number of 

Responses 

per 

Respondent

Agency 

Burden Hours 

(Time) to 

Review each

Response

Total Agency 

Hours per Year 

for all 

Respondents

Total Agency 

Labor Costs 

Established) that Change 

Ownership or Enter the Market

Compile information, complete 

certification requirements

Certification by Disposal 

Establishments that change 

Ownership or Enter the Market 375 1 0.25 93.75 $3,016.50

Certification by Refrigerant 

Reclaimers that Change Ownership 

or Enter the Market 4 1 1 4 $128.70

Reclaimer Annual Activity Report 60 1 1 60 $1,930.56

Technician Certification Programs 

Applying for Approval 5 1 2 10 $321.76

Biannual Reporting by Existing 

Technician Certification Programs 91 2 1 182 $5,856.03

Owners/operators of appliances 

w/charge sizes >50 lbs prepare & 

submit requests for extensions to 

30-day repair timeline 15 1 0.5 7.5 $241.32

Owners/operators of appliances 

w/charge sizes >50 lbs prepare & 

submit requests for extensions to 1 

yr retrofit/retire timeline 5 1 1 5 $160.88

SUBTOTAL 2,807 10 7.5 925.75 $29,786.93

Annual Agency Hour Burden = 925.75 hours

Total Agency Labor Costs = $29,787

(iii) Variations in the Annual Bottom Line

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

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

government burdens and costs are not anticipated to vary significantly.

6(f) Reasons for Change in Burden

There have been no regulatory changes associated with this program since the previous 

renewal of the ICR. EPA estimates that there will be a slight increase in the time required to 

submit reports and maintain records due to the inclusion of the time necessary for technicians to 

acquire certification cards in this updated ICR. In the previous ICR, EPA reported the number of 

responses and burden hours for some activities in aggregate. In this renewal, EPA has 

disaggregated this information to represent the expected number of responses through the year 
32

for a given activity; this results in a higher number of responses but does not impact the burden 

hours or cost. Therefore, there is no increase of hours in the total estimated individual respondent 

burden compared with that identified in the ICR currently approved by OMB. EPA has also 

adjusted costs based on updated labor rates.

6(g) Burden Statement 

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

is estimated to range from 1 minute to 8 hours per year for each respondent. This estimate 

includes time for preparing and submitting reports and maintaining records on-site at the 

respondents’ places of business. 

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA's 

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

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

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

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

Docket ID No. EPA-HQ-OAR-2010-1016, which is available for online viewing at 

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

Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., 

NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the 

Reading Room is (202) 566-1744, and the telephone number for the OAR Docket is (202) 566-

1742. An electronic version of the public docket is available at www.regulations.gov. This site 

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

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

electronically. When in the system, select “search,” then key in the Docket ID Number

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

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, 

Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA–HQ–OAR–2010-

1016 and OMB control number 2060-0256 in any correspondence.