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### Supporting Statem ent for Reporting and Recordkeeping Requirem ents for National Volatile Organic Com pound Em ission Standards for Autom obile Refinish Coatings
1. Identification of the Information Collection 1 (a) Title of Information Collection

. Nation al Volatile Organic Compound Emission Standards for Automobile Refinish Coatings. T h e information collection request (ICR) number is 1765.0 6 . The OMB control number is 2060

- 0353. This is a renewal I CR. 2 (b) Short Characterization /Abstract . All manuf

acturers and importers of coatings and coating components subject to 40 CFR Part 59 Subpart B

-- National Volatile Organic Compound Emission Standards f or Consumer a nd Commercial Products must submit an initial report. The initial report must include the na me and mailing address of the manufacturer or importer. The rule requires that containers of all subject automobile refinish coatings and coating components display the date of manufacture or a code indicating the date of manufacture. All manufacturers a nd importers of subject coatings and coating components must submit an explanation of all date codes used on automobile refinish coating and coating component containers. Date code explanations can be submitted with the initial report. Thereafter, respon dents must submit explanations of any new date codes within 30 day s of their first use. The information collection includes initial and periodic reporting necessary for the EPA to ensure compliance with the promulgated federal rule for automobile refinis h coatings. The rule will be enforced through random sampling of coatings to determine VOC content. Respondents are manufacturers and importers of automobile refinish coatings and coating components. 2. Need for and Use of the Collection 2 (a) Need/Au thority for the Collection. The EPA is required under Section 183(e) of the Clean Air Act (Act) to regulate VOC emissions from the use of consumer and commercial products. Pursuant to Section 183(e)(3), the EPA published a list of consumer and commercia l products and a schedule for their regulation (60 FR 15264). Automobile refinish coatings were included in Group 1 of the list. The standards for such coatings were promulgated on September 11, 1998 (63 FR 48806) and are codified at 40 CFR part 59, subp art B. The reports required under the rule enable the EPA to identify all coating and coating component manufacturers and importers in the United States, and to determine which coatings and coating components are subject to the rule based on dates of man ufacture.2

2 (b) Practical Utility /Users of the Data . Agency enforcement personnel will use the information collected to identify manufacturers and importers subject to the rule and to determine which coatings and coating components are subject to the r ule by dates of manufacture. 3. Nonduplication, Consultations, and Other Collection Criteria 3 (a) Nonduplication. The information collected pursuant to the rule is not collected by any other Federal agency . Several States regulate automobile refini sh coatings and require certain recordkeeping and reporting activities. These State rules generally affect body

shops; the federal rule affects coating and coating component manufacturers and importers. There is much more recordkeeping associated with th e State rules because of the large number of body shops in the country . The federal rule affects approximately 30 manufacturers and importers, and contains reporting requirements different from those of the State rules. 3 (b) Public Notice Required Pri or to ICR Submission to OMB . Notice of this I CR appeared in the March 2 3 , 20 1 0 , Federal Register 7 5 FR 13759 . The notice contained a 60

- day public comment period, which ended on Ma y 2 4 , 20 1 0. The EPA received no comments. 3 (c) Consultations . Input and information was solicit ed from the affected industry and State and local governments during the renewal process , some of whom are listed in table 3. 3 (d) E ffects of Less Frequent Collection. Less frequent information collection would decrease the margin of assurance that manufacturer s are continuing to meet the standards. This I CR includes one

- time initial reports. After the initial report, the only reports required are those explaining any new date codes. To determine whether a coating is subje ct to the rule, explanations of date codes are necessary

. 3 (e) General Guidelines. This I CR adheres to the guidelines for Federal data requestors, as provided at 5 CFR 1320.6. 3 (f) Confidentiality. All information submitted to the Agency for whic h a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2,3

Subpart B
-- Confidentiality of Business I nformation (see 40 CFR 2; 41 FR 36092, September 1, 1976; amended by 43 FR 39999, Se ptember 8, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). 3 (g) Sensitive Questions . None of the reporting or recordkeeping requirements contain sensitive questions. 4. The Respondents and the Information Requested 4 (a) Respond ents/NAICS Codes. Respondents to this information collection are manufacturers and importers of automobile refinish coatings and coating components. Manufacturers of automobile refinish coatings and coating components fall within standard industrial cla ssification (SI C) 2851, "Paints, Varnishes, L acquers, Enamels, and Allied Products" and North American I ndustry Classification Sy stem (NAI CS) code 325510, “Paint and Coating Manufacturing.” I mporters of automobile refinish coatings and coating components fall within SI C 5198, "Wholesale Trade: Paints, Varnishes, and Supplies ," NAI CS code 422950, “Paint, Varnish and Supplies Wholesalers,” and NAI CS code 444120, “Paint and Wallpaper Stores.” 4 (b) Information Requested. (i) Data items. The reportin g requirements of the rule are listed below. Re ports Regulation Reference In itial report 59.426(a) Explanation of date codes 59.426(a) (ii) Respondent Activities . The respondent activities required are listed in the first column of table 1. 5. The Information Collected -- Agency Activities, Collection Methodology, and Information Management. 5 (a) Agency Activities. A list of activities required of the EPA is provided in table 2. 5 (b) Collection Methodology and Managemen ts4

The information collected under this rule w ill not warrant be ing maintained on a computerized database since the reports are so few in number. Also, s ince the reported information is simple and straightforward, no standardized reporting forms will be developed. 5 (c) Small Entity Flexibility. Since the reporting requirements of the rule are minimal, no alternative reporting requirements are instituted for small entities. 5 (d) Collection Schedule. All subject manufacturers and importers must s ubmit to the EPA an explanation of all date codes display ed on containers of automobile refinish coatings and coating components within 30 day s of first use, or within 180 day s of becoming subject to the rule, whichever is later. All manufacturers and imp orters of subject coatings and coating components must submit an initial report within 180 day s of becoming subject to the rule. 6. Estimating the Burden and Cost of the Collection 6 (a) Estimating Respondent Burden. The average annual burden estimat es for reporting requirements are presented in table 1 for all manufacturers. These numbers were derived from estimates based on the EPA's experience with other standards, and from information obtained from the industry representatives listed in table 3. These estimates represent the average annual burden that will be incurred by the affected industry

over a 3
- ye ar period. The hours shown in column A of table 1 are the burden estimate per manufacturer. 6 (b) Estimating Respondent Costs. (i) Estim ating Labor Costs. Table 1 also presents estimated costs for the required reporting activities. L abor rates and associated overhead costs are based on hourly rates of $ 99 for management personnel, $ 7 0 for technical personnel, and $4 4 for clerical person nel. These rates were estimated using a March 2010 civilian wage table from the Bureau of Labor Statistics, multiplied by 1.6 to account for benefits and overhead.

(ii) Estimating Capital and Operations and Maintenance Costs . There are no capital or operations and maintenance costs associated with the se reporting activities. 6 (c) Estimating Agency Burden and Cost .5

Because reporting requirements on the part of respondents are required under section 112 of the Act, no operational costs will be incurred by the Federal government. The only costs that the Federal government will incur are costs associated with the review of reported information, as presented in table 2. Hourly labor rates are estimated at $9 9 for management personnel, $ 71 for technic al personnel, and $3 4 for clerical personnel. These rates were determined by multiply ing the hourly

rates from the 20 1 0 General Schedule (GS) Locality Pay Tables (tenth step) for GS

- 15 (management), GS

- 13 (technical), and GS

- 7 (clerical), by a factor of 1 .6 to account for benefits and overhead. 6 (d) Estimating Respondent Universe and Total Burden Costs The EPA estimates that there are approximately 30 automobile refinish coating and coating component manufacturers and importers. Two requirements in th e rule create a burden on respondents: submitting an initial report, and submitting an explanation of date codes used on coating and coating component containers. The EPA estimates that one new coating or coating component manufacturer or importer will be come affected by the rule each y ear. A new regulated entity

must submit an initial report and provide an explanation of any dates codes that are used to indicate the manufacture date of its products. The EPA also estimates that 10 percent (3) of the exis ting regulated entities will change their date coding sy stem each y ear and will have to submit an explanation of the new sy stem. 6 (e) Bottom Line Burden Hours and Costs/Master Tables . (i) Respondent Tally . The bottom line respondent burden hours an d costs, presented in table 1, are calculated by summing the person

- hours column and by summing the cost column. The annual burden and cost averaged over 3 ye ars is 14 hours and $ 1,038
.

(ii) The Agency Tally . The bottom line Agency

burden and cost, presented in table 2 is calculated in the same manner as the respondent burden and cost. The estimated annual burden and cost averaged over 3 ye ars is 4 hours and $ 232
.

(iii) Variations in the annual bottom line
. This I CR includes reading the rule, the initial report, and date code explanations as one

time burden and cost items. To develop the estimates of annual average burden, these one

- time activities were averaged over 3 ye ars. The only other activity

is reporting of any

new date code explanat ions. 6 (f) Reasons for Change in Burden . There are no change s to the burden estimate s .6

6 (g) Burden Statement. The annual public reporting and recordkeeping burden for this collection of information is e s timated to average 4 hours per respon se per ye ar. 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, i nstall, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

appli cable 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 conduc t or sponsor, 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 o n 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 unde r Docket I D No. EPA
- HQ
- OAR
- 2003
- 0120, which is available for public viewing at the Air and Radiation Docket and I nformation 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Air and Radiation Docket and Informatio n Center 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 sy stem, select “search,” then key in the Docket I D Number identified above. Also, y ou can send comments to the Office of I nformation and Regulatory Affairs, Office of Management and Budget, 725 17 th S treet, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket I D No. EPA
- HQ
- OAR
- 2003
- 0120 and OMB control number 2060

- 0353.7

Table 1. AVERAGE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING OVER THREE YEARS

A B C D E F Burden I tem Person Hours Per Occurrence (hrs/man.) Number of

Occurrences Per Respondent Per Year Person Hours

Per Respondent Per Year (a) (C=AxB) Dollars

Per Hour (a) Respondents

Per Year (b) Total Hours

Per Year (E=CxD) Total Cost

Per Year (c) 1. Applications Not Applicable 2. Surveys and Studies Not Applicable 3. Reporting Requirements A. Read I nstructions 2 1 2 70 1 2 $1 40 B. Gather Existing I

nformation In cluded in 3.C C. Write Report In itial Report 2 1 2 9 9 1 2 (d) $1 98 Date Code Explanation 4 1 4 70 1 4 (d) $2 80 Update Date Codes 2 1 2 70 3 6 (e) $ 420 4. Recordkeeping Requirements Not Applicable 5. L abeling (f) Not Applicable Total 14 $ 1038 a All tasks are assumed to be performed by a technical person ($ 70 /hr) unless otherwise noted. b Total number of manufacturers was estimated to be 30. c Costs were calculated by multiplying the total number of hours by the hourly wages. d This assumes there is one new regulated entity every year. e Assumed that 10% of manufacturers will update their codes each year. f Although the rule requires the date (or code) to appear on the label, such labeling is already performed.8

Table 2. AGENCY BURD EN AND COSTS A B C D E F Reports EPA Hours Per Occurrence Occurrences Per Year Person Hours Per Year (Technicall) C=AxB Person Hours Per Year (Management) D=Cx0.05 Person Hours Per Year (Clericall) E=Cx0.1 Total Cost Per Year (a)

In itial Report 1 1 1 0 .05 .1 $ 79 Date Code Report 0.5 1 0.5 0.03 0.05 $ 40 Date Code Updates 0.5 3 1.5 0.08 0.15 $113 Total 3 0.16 0.3 $ 232 a L abor rates: technical, $ 71 /hr; management, $9 9 /hr; clerical, $3 4 /hr. Table 3. Consultations In dustry Representatives Ema il Robert Redding, Automotive Service Association b.redding@att.net Jim Sell, National Paint and Coatings Association JSell@paint.org State Representatives Dave Nordberg, Oregon Department of Environmental Quality nordberg.dave@deq.state.or.us Ed Wong , California Air Resources Board ewong@arb.ca.gov