Supporting Statement

For

Information Collection Request

Engine Emission Defect Information Reports and

Voluntary Emission Recall Reports (Renewal)

ICR Number 0282.15

OMB Number 2060-0048

42 USC 7521 § 206

42 USC 7521 § 207

42 USC 7521 § 213

40 CFR Part 85

40 CFR Part 89

40 CFR Part 90

40 CFR Part 91

40 CFR Part 92

40 CFR Part 94

40 CFR Part 1048

40 CFR Part 1051

40 CFR Part 1068

Certification and Compliance Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency
ICR #0282.15 Supporting Statement

Page 2

1. Identification of the Information Collection

1(a) Title and Number of The Information Collection

Engine Emission Defect Information Reports and Voluntary Emission Recall Reports

(Renewal). EPA Number 0282.15, OMB Control Number 2060-0048.

1(b) Short Characterization/Abstract

Under Section 206(a) of the CAA (42 USC 7521), engine manufacturers may not legally 

introduce their products into US commerce unless EPA has certified that their production 

complies with applicable emission standards. Section 213(d) extends all emission certification 

and compliance provisions to non-road engines and vehicles. During the certification process, 

manufacturers must demonstrate that their products comply with applicable emissions standards 

throughout their useful lives. However, EPA's own in-use testing has shown that some engines 

exceed the emissions standards during their useful lives for a variety of reasons. Those reasons 

include defects in materials or design or other factors. 

Per sections 207(c)(1) and 213 of the Clean Air Act (CAA), when emission testing shows 

that a substantial number of properly maintained and used engines produced by a manufacturer 

do not conform to emission standards, the manufacturer is required to recall the engines. When 

manufacturers learn of the existence of emission-related defects in 25 engines or more (10 in the 

case of locomotives) of the same class and model year, they are required to submit a Defect 

Information Report (DIR). DIRs contain information about the engines on which a defect has 

been found and a description of the defect and its effects on engine performance and emissions. 

EPA uses these reports to target potentially nonconforming classes of engines for future testing, 

to monitor compliance with applicable regulations and to order a recall, if necessary. 

Manufacturers can also initiate a recall voluntarily by submitting a Voluntary Emission 

Recall Report (VERR). VERRs contain information such as the procedures used by

manufacturers to notify engine owners, the identification of engines affected, and repairs to be 

completed on recalled engines. Manufacturers also submit progress reports that track the number 

of engines repaired. VERRs and VERR updates allow EPA to determine whether the 

manufacturer conducting the recall is acting in accordance with the CAA and to examine and 

monitor the effectiveness of the recall campaign. 

This information is collected by the Heavy-duty and Nonroad Engine Group (HDNEG), 

Certification and Innovative Solutions Division (CISD), Office of Transportation and Air Quality 

(OTAQ), Office of Air and Radiation (OAR), U.S. Environmental Protection Agency (EPA). 

Besides CCD, this information could be used by the Office of Enforcement and Compliance and 

the Department of Justice for enforcement purposes. Non-confidential portions of the 

information submitted to EPA could be disclosed to the public upon request. This information is 

used by trade associations, environmental groups, and the public. Respondents may submit this 

information in an electronic format and EPG stores it in a database. 
ICR #0282.15 Supporting Statement

Page 3

EPA estimates that approximately 75 engine manufacturers will respond to this collection 

with an approximate cost of $2,293,648.

2. Need For and Use of the Collection

2(a) Need/Authority for The Collection

EPA's emission compliance programs, including-emissions related recalls, are statutorily 

mandated; the agency does not have discretion to cease these functions. Sections 207(c)(1) and 

213 of the Clean Air Act (CAA) mandate engine manufacturers to conduct recalls when in-use 

emission testing shows that a substantial number of properly maintained and used engines of the 

same class or engine family do not conform to emission standards.

Section 208(a) of the Clean Air Act provides EPA with the authority to require a 

manufacturer to "make reports and provide information the Administrator may reasonably

require to determine whether the manufacturer or other person has acted or is acting in 

compliance" with Title II of the Clean Air Act and applicable regulations. Regulations 

implementing such reporting requirements are codified at:

 40 CFR part 85, subpart T (On-highway, Heavy-duty Truck Engines)

 40 CFR part 89, subpart I (Non-road Compression-ignition Engines)

 40 CFR part 90, subpart I (Non-road Spark-ignition Engines)

 40 CFR part 91, subpart J (Marine Spark-ignition Engines)

 40 CFR part 92, subpart E (Locomotives and Locomotive Engines)

 40 CFR Part 94, subpart E (Marine Compression-ignition Engines)

 40 CFR Part 1068, subpart F (General provisions for engines certified under:

o Part 1033 – Locomotives

o Part 1039 - Non-road Compression-ignition Engines

o Part 1042 - Marine Compression-ignition Engines

o Part 1045 - Marine Spark-ignition Engines

o Part 1048 – Large Spark-ignition Engines

o Part 1051 – Recreational Vehicles (Snowmobiles and All Terrain Vehicles only)

o Part 1054 - Non-road Spark-ignition Engines

o Stationary engines certified under Parts 1039, 1048 and 1054)

The information collected under this information collection request is needed to identify

potentially noncomplying engines. Those engines are then targeted for future testing to ensure 

that they comply with emission standards throughout their useful lives
ICR #0282.15 Supporting Statement

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2(b) Practical Utility/Users of The Data

EPA uses the information requested to ensure compliance with the Clean Air Act's in-use 

emission requirements. This information collection enables EPA to ensure that engine 

manufacturers are complying with applicable in-use emission regulations, measure the impact of 

non-road engines' emissions on air quality, and take corrective actions as needed.

DIRs notify EPA of the existence of defects in a significant number of engines that may

cause engine emissions to exceed applicable standards. These reports enable the Agency to take 

action, as needed. VERRs are used to determine if a manufacturer is acting in accordance with 

the Clean Air Act and to examine and monitor the effectiveness of the recall campaign. 

Measures of effectiveness include the procedures the manufacturer is following to notify vehicle 

owners and provide timely repairs, the percentage of vehicle owners that are responding to recall 

notification and the number of engines that are being repaired. 

The information will be received and used by HDNEG/CISD/OTAQ/OAR. Nonconfidential portions of the information submitted to EPG is available to and used by importers, 

environmental groups, members of the public and local, state and federal government 

organizations.

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

3(a) Non-duplication

The information requested under this ICR is required by statute. Because of its 

specialized nature, the information collected is not available from any other source.

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

An announcement of the public comment period for this ICR renewal was published in 

the Federal Register on April 30, 2010 (75 Federal Register 22776). No comments were

received. 

3(c) Consultations

In updating this information collection request, EPA consulted manufacturers of on-road

and nonroad engines. The consultations with the manufacturers' representatives sought to clarify

burden estimates, employee mix in the responses, and the clarity of the requirements associated 

with this ICR. EPA consulted the following respondents:

 Del R. Nelson, Project Engineer Emissions

Arctic Cat, Inc.

601 Brooks Ave. South

Thief River Falls, MN 56701

phone: 218-681-9799 (ext. 4121)

dnelson@arcticcatinc.com
ICR #0282.15 Supporting Statement

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 Jean-Michel Desaulniers

Bombardier Recreational Products, Inc.

726, rue Saint-Joseph

Valcourt, Quebec Canada J0E 2L0

Phone: 450-532-6188

jean-michel.desaulniers@brp.com

 Larry Keller

Polaris Industries, Inc.

2100 Highway 55

Medina, MN 55340

Phone: 651-408-7253

larry.keller@polarisind.com

 Ravinder Singh

Cummins Inc.

500 Jackson St.

Columbus, IN 47201

Phone: 284-576-5504

ravinder.d.singh@cummins.com

3(d) Effects of Less Frequent Collection

This information is only collected when certain circumstances which potentially involve 

non-compliance with statutory and regulatory requirements trigger these events. Thus, 

manufacturers are required to provide this information only when potential violations exist. Less 

frequent collection of DIRs and VERRs would allow potential violations to go undetected. 

Follow-up progress reports on voluntary recalls are collected quarterly for up to six quarters. 

These progress reports or updates are used to monitor the progress of a recall campaign, 

observing the promptness with which engines subject to the recall receive the remedial repair. 

Experience has shown that the quarterly reporting interval, which corresponds to most 

manufacturers’ internal cycles, is generally the minimum interval for effective oversight of a 

recall campaign.

3(e) General Guidelines

DIRs and VERRs are required by regulation to be submitted not more than 15 days after 

an emissions-related defect is found (or in the case of a VERR, within 15 days after vehicle 

owner notification) to affect 25 or more engines (10 for locomotives) of the same model year or 

engine family. If information necessary to complete the written report is not available to the 

respondent within 15 days, the respondent may submit the missing information when it becomes 

available. 
ICR #0282.15 Supporting Statement

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Applicable regulations do not require respondents to submit information more frequently 

than on a quarterly basis on a per defect basis. Respondents must report defects within 15 days 

after becoming aware of them. A respondent may become aware of additional defects shortly

after having submitted a report. This new defect will have its own timeline.

This collection also requires manufacturers to retain records on defects for five years 

from the date of manufacture of the vehicle.

3(f) Confidentiality

Any claimed confidential business information that meets the criteria set forth by 5 

U.S.C. §552 and 40 CFR Part 2 will be treated as such.

3(g) Sensitive Questions

No questions of a sensitive nature are asked.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

Respondents are manufacturers of non-road engines within the following North American 

Industry Classification System (NAICS) codes:

● 333618 Other Engine Equipment Manufacturing

● 336312 Gasoline Engine and Engine Parts Manufacturing

4(b) Information Requested

(i) Data Items 

Subsections A through E below list most of the data items requested under this 

information collection. Some of these data items are required to be kept in records and 

submitted only upon request. The lists in these sections are meant to give an idea of what is 

usually requested. For a complete list of all data items applicable for each type of engine, please 

refer to the regulations listed in Section 2(a). 

A. Defect Information Reports (DIRs)

Manufacturers are required to submit defect information reports only when their data 

indicates that an emission-related defect may exist in a substantial number of properly maintain 

engines. The term “substantial number” has different definitions in some of the regulations 

covered by this collection; however, the majority of the regulations define this term as 25

engines or more (10 for locomotives). Part 1068 establish thresholds based on projected sales 

(40 CFR 1068,501(e)). 
ICR #0282.15 Supporting Statement

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Manufacturers must report within 15 working days (21 days for engines subject to Part 

1068) after a defect is found in a substantial number of engines. These requirements apply only 

to engines which have already been sold to the public and remain in effect for five years after the 

model year in which the engine was certified. For engines subject to Part 1068, the requirements 

apply for the entire useful life of the engine or five years after the end of the model year, 

whichever is longer [40 CFR 1068.501(b)(4)]. 

Data items requested in Defect Information Reports include:

 The manufacturer's corporate name

 A description of the defect

 A description of the class or category of engines

 Number of vehicle or engines estimated or known to have the defect and 

explanation of derivation.

 The address of the plant(s) where they were produced

 Evaluation of the emissions impact and any driveability problems it might cause

 Available emissions data related to the defect

 Indication of any anticipated manufacturer follow-up

B. Voluntary Emission Recall Reports (VERRs)

Manufacturers have the option to voluntarily initiate a recall. If the recall involves 25 

engines or more (one for locomotives), they must notify EPA about the recall within 15 days of 

the date they first started to notify engine owners about the recall.

Information items requested in Voluntary Emission Recall Reports include:
ICR #0282.15 Supporting Statement

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 A description of the class or category of engines being recalled

 A description of the modifications or repairs made to correct the defects

 A description of the method being used to identify and contact the owners

 A description of any conditions for eligibility for repair and any reasons for the 

conditions

 A description of the procedure to be followed by the owner to obtain repairs and where 

the repairs can be obtained

 If repairs are not being performed at dealers, a description of who will perform the repairs 

and where the defect will be remedied

 Copies of the letters of notification to be sent to the vehicle owners

 A description of the system for assuring an adequate supply of parts is available for the 

repairs and that they are performed in a timely manner.

 Copies of all necessary instructions to be sent to the persons who are to perform the 

repairs

 A description of the impact of the proposed changes on fuel consumption, driveability, 

and safety of the engines

 A sample of any labels to be applied to the participant engines identifying the recall being 

performed

C. VERR Progress Reports

VERR Quarterly Progress Reports document the progress of voluntary recalls. 

Manufacturers of on-highway, heavy-duty truck engines, non-road compression ignition engines 

and locomotives are required to submit VERR quarterly reports for six quarters following the 

beginning of any recall campaign (40 CFR 85.1904(b) and 40 CFR 92.404(b)). These reports 

must be submitted no later than 25 working days after the end of each calendar quarter.

Manufacturers of non-road spark-ignition engines need to submit only one report within 

18 months of the start of owner notification (40 CFR 90.804(b)). Marine engine manufacturers 

need to submit a report one year from the start of owner notification (40 CFR 90.804(b)). Other 

variations may exist among the different categories of engines.

Data items include:

 Recall campaign number

 Date of owner notification and completion

 Number of engines involved

 Number of engines known or estimated to be affected by the defect

 Number of or engines brought in and inspected as part of the campaign

 Number of engines found to have the defect after inspection

 Number of engines actually receiving repair

 Number of engines determined to be unavailable due to exportation, theft, scrapping or 

other reasons

 Number of engines determined to be ineligible because of improper maintenance or use
ICR #0282.15 Supporting Statement

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 Copies of any service bulletins sent to dealers which relate to the defect that had not 

previously been reported

 Copies of all communications transmitted to vehicle owners which relate to the defect to 

be corrected not previously submitted

 Revisions to any of the information previously submitted

 Vehicle owner contact information upon request

For non-road and marine spark-ignition engines only:

 Methods used to notify owners and dealers

 Number of engines known or estimated to be affected

 Number of engines actually being repaired

 Number of owners and dealers involved

 Number of engines determined to be ineligible because of improper maintenance or use

D. Recordkeeping Requirements

Manufacturers are required to keep records of all the data gathered to compile the reports 

for at least five years (40 CFR parts 85.1906(b), 90.805(b), and 91.905(b)). Recalls related to 

recalls under Part 1068 must be kept for at least three years after that last required report was 

submitted (40 CFR 1068.530). Locomotive and locomotive engine manufacturers under Part 92

however, must keep these records for eight years (40 CFR 92.406(b)). Manufacturers are 

required to make all records available to EPA upon request (40 CFR Parts 85.1906(b), 90.805(b), 

91.905(b), and 92.406(b)).

The following information must also be maintained in a form suitable for inspection, such 

as electronic storage devices or databases:

 The names and addresses of vehicle or engine owners:

 To whom notification was given

 Who received remedial repair or inspection

 Who was determined not to be eligible because of improper maintenance or use

(ii) Respondent Activities

The activities manufacturers need to perform to comply with the requirements of each 

type of report are as follows:

 Monitor engine performance by collecting information on the frequency of customer or 

dealer complaints and findings by their own research departments (customary business 

practice)

 Review instructions and regulations

 Compile data

 Prepare and submit report

 Maintain records
ICR #0282.15 Supporting Statement

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

Information Management

5(a) Agency Activities

EPA officials carry out the following activities:

 Review regulations

 Answer respondents' questions

 Review reports for completeness and compliance with regulations

 Analyze reports to determine the impact of the situation described in the report on 

emission levels

 Evaluate manufacturers' procedures to determine if the problem is being addressed 

correctly and how effective a recall campaign is

 Recommend, if needed, additional compliance activities such as further testing or 

research

 Identify engine classes that may need follow up in the future

 Summarize and store the information electronically

5(b) Collection Methodology and Management

EPA currently makes extensive use of electronic media in gathering and evaluating 

information; therefore, EPA prefers to receive the reports electronically. However, it is the 

manufacturers' choice to submit their reports on paper if they so prefer.

Once the data is received, the information is entered into a database and reviewed for 

completeness. If the manufacturer chooses to make hard copy submittals, then EPA manually

enters the information into the database. The reviewer analyses the information to ensure 

compliance with the CAA and applicable regulations. 

5(c) Small Entity Flexibility

The information requested is considered to be the minimum needed to effectively

maintain the emission control programs' integrity and comply with the requirements of the Clean 

Air Act. Further measures to simplify reporting requirements for small businesses do not appear 

prudent or necessary.

5(d) Collection Schedule

DIRs are collected on occasion only. If the defect requires a recall, a reporting scheduled 

is triggered. Sections 4(b)(i)(A) through 4(b)(i)(D) describe the schedule.
ICR #0282.15 Supporting Statement

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6. Estimating the Burden and Cost of the Collection

Please refer to Table 1 in the attachment for details.

6(a) Estimating Respondent Burden

Burden estimates were taken from the previous ICR and revised to reflect experience 

gained by EPA and comments from fewer than 10 respondents consulted by EPA. 

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

To estimate labor costs, EPA used the Bureau of Labor Statistics' publication 

Occupational Employment and Wages, 2008. EPA then increased the hourly wage estimates by

a factor of 2.1 to account for benefits and overhead. The specific rates used are listed below. 

These are mean hourly rates.

Table 2

Labor Costs Estimates

Occupation SOC Code 

Number

Mean Hourly Rate 

(BLS)

2.1 Factor for 

Overhead and 

Benefits

Mechanical Engineers 17-2141 $38.74 $81.35

Engineering Managers 11-9041 $59.04 $123.98

Lawyers 23-1011 $62.03 $130.26

Secretaries, Except Legal, Medical and 

Executive

43-6014 $14.93 $31.35

(ii) Estimating Capital and Operations and Maintenance Costs

Operation and Maintenance costs (O&M Costs) associated with this information 

collection include CDs, photocopying, postage and other shipping expenses and phone calls. 

CDs are used by manufacturers to submit data electronically and to keep records.

There are no capital start-up costs associated with this collection.
ICR #0282.15 Supporting Statement

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(iii) Capital/Start Up Operations and Maintenance Costs

There are no capital start-up costs associated with the renewal of this ICR.

(iv) Annualizing capital costs

There are no capital start-up costs associated with this information collection. 

6(c) Estimating Agency Burden 

Please refer to Table 3 in the attachment for detailed calculations.

Table 4 below summarizes EPA's labor costs associated with this information collection. 

These costs are based on hourly wage rates obtained from the Office of Personnel Management

(OPM) and adjusted by a factor of 1.6 to account for benefits and overhead.

Table 4

Agency Labor Costs

Occupation Hourly Rate

1.6 Federal Factor for 

Benefits and Overhead

Engineer (GS-13/10) $55.46 $88.73

Lawyers (GS-13/10) $55.46 $88.73

Contractors (amount spent in FY 2009) –

Defect and Recall Reports Processing $41,330

Due to a shortage of personnel, EPA contracts out the processing of DIRs and VERRs. The 

Contractor answers questions from manufacturers regarding how to prepare and submit reports, 

reviews reports for completeness, uploads them into a database, and identifies those that need 

special follow up. EPA personnel follow up with manufacturers in matters that require 

regulatory interpretation and enforce the requirements, as needed.
ICR #0282.15 Supporting Statement

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

There are approximately 338 engine manufacturers (respondents) who obtain certificates 

of conformity with EPA emission regulations. All of them need to comply with defect and recall 

regulations. Manufacturers need to submit DIRs only when they learn that a significant number 

of properly maintain engines are affected by a particular defect. Therefore, not all manufacturers 

will respond to this collection every year.

Based on previous experience, EPA expects to receive approximately 225 DIRs from 75

different respondents per year during the next three years. This is a significant increase from 

previous response levels. This increase is mainly due to two factors: (1) the pool of possible 

respondents has significantly increased in the last few years; and (2) EPA has noted that not all 

manufacturers are aware of their responsibilities to report and cure defects found in their 

products. To address this issue, EPA plans to step up efforts to verify compliance with defect 

reporting and recall regulations. This should result in a higher number of respondents to this 

information collection.

6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

 Number of Respondents: 75

 Number of Activities: 13

 Total Hours per Year: 26,563

 Total Labor Cost per Year: $2,276,608

 Total Capital Costs per Year: 0

 Total O&M Costs per Year: $17,040

 Total Costs: $2,293,648

(ii) The Agency Tally

 Number of Respondents: 75

 Number of Activities: 12

 Total Hours per Year: 1,858

 Total Labor Cost per Year: $44,126.36

 Total Capital Costs per Year: 0

 Total O&M Costs per Year: $637 in addition to $41,330 in contract 

dollars

 Total Costs: $86,093
ICR #0282.15 Supporting Statement

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6(f) Reasons for change in burden

There is an increase in burden associated with this ICR renewal due to: (1) a significant 

increase in the estimated number of respondents; and (2) an increase in estimated frequency. 

This increases are due adjustments EPA has made to its estimates.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection is estimated to 

average 354 hours per respondent. 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-2006-0895, which is available for online viewing at 

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

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

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

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

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

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

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

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

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

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

Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office 

for EPA. Please include the EPA Docket ID No. EPA-HQ-OAR-2006-0895 and OMB control 

number 2060-0048 in any correspondence.