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 United States Environmental Protection Agency

INFORMATION COLLECTION REQUEST (ICR)

Part A of the Supporting Statement

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title: Registration of Fuels and Fuel Additives:

Requirements for Manufacturers

EPA ICR Number 0309.13, OMB Control Number 2060-0150

Docket ID Number EPA-HQ-OAR-2006-0894

1(b) Abstract

In accordance with the regulations at 40 CFR part 79, subparts A, B, C, D and F, 

Registration of Fuels and Fuel Additives, manufacturers of (1) motor vehicle gasoline, (2) motor 

vehicle diesel fuel, and (3) additives for those fuels, are required to have their products registered 

by the Environmental Protection Agency (EPA) prior to their introduction into commerce. 

Registration involves providing (1) a chemical description of the fuel or additive, (2) certain 

technical and marketing information, and (3) any health-effects information in company files. 

(The portion of Subpart F requiring the development of health-effects data is covered by a 

separate information collection.) Manufacturers are also required to submit periodic reports on 

production and related information. The program is run by the Transportation and Regional 

Programs Division, Office of Transportation and Air Quality, Office of Air and Radiation. The 

information is used to (1) identify products whose evaporative or exhaust emissions pose a 

particular threat to public health, thus meriting further investigation and/or regulation, (2) ensure 

that EPA compositional requirements for unleaded gasoline are met before a product is 

registered and introduced into commerce, and (3) maintain a comprehensive data base of motor 

vehicle fuel and additive composition. Most of the compositional information is confidential. 

Lists of registered fuels and additives are available at www.epa.gov/otaq/additive.htm. The 

information is collected and stored in hard copy, with most entered into a computer data base. 

There are approximately 500 fuel manufacturers, 1,000 additive manufacturers, 700 registered 

fuels, and 7,200 registered additives. These numbers change daily. The annual cost to industry

is estimated at $2.2 million. The annual cost to the government is estimated at $450,000. 

This program also serves as a vehicle for the administration of the program for the 

certification of deposit control/detergent gasoline additives at 40 CFR part 80. By using this 

existing registration program the EPA avoided having to establish an additional registration 

program for gasoline detergent additives. The reporting and recordkeeping requirements unique 

to this certification program are covered by a separate information collection.

In addition, per 30 CFR 75.1901(c), only registered diesel fuel additives may be used in 

diesel-powered equipment for underground coal mining. Thus the Mine Safety and Health 

Administration of the Department of Labor is able to utilize this program. 

2. NEED FOR AND USE OF THE COLLECTION
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2(a) Need/Authority for the Collection

Motor vehicles comprise the major source of air pollution in most urban areas, and 

account for about half the toxic air emissions in the United States. Congress demonstrated its 

strong concern for the protection of public health by providing broad legislative authority to 

monitor and regulate fuels, fuel additives, and their emissions. This registration program was 

established by the Air Quality Act of 1967, carried forward into the Clean Air Act (Act) of 1970, 

and strengthened in the Act’s 1977 and 1990 reauthorizations.

Section 211(a) of the Act provides EPA with the authority to designate any mobile source 

fuel or additive for registration. Any fuel or additive with the potential for a significant 

emissions impact on the public would be an appropriate candidate. Once designated, it may not 

be introduced into commerce until it has been registered by EPA. Section 211(b) requires, for 

the purpose of registration, that the manufacturer provide certain compositional and related 

information, and available health-effects data. Section 211(b) also provides EPA with the 

authority to require health-effects testing. The original regulations were promulgated by the 

Department of Health, Education, and Welfare in 1970, and transferred to the EPA shortly

thereafter. They ultimately resided at 40 CFR part 79 and were revised in 1975, 1976, and 1978. 

Due to their broad public emissions exposure, motor vehicle gasolines and diesel fuels, and their 

additives, were designated. Section 211(e) (1977 amendments) directs EPA to establish healtheffects testing requirements, and those regulations were promulgated in 1994 as Subpart F of 40 

CFR part 79. (Changes to the regulations have reduced the burdens, particularly for small 

businesses.) They are structured into three tiers of requirements for specific fuel/additive 

categories. Tier 1, due in May 1997, required an emissions characterization and a literature 

search for health-effects information on those emissions. Tier 2, due in May 2000, required 

short-term inhalation exposures of laboratory animals to emissions to screen for adverse health 

effects. The regulations also allow for alternative Tier 2 testing if more appropriate. The major 

gasoline oxygenates and a manganese additive for gasoline have undergone such alternative 

testing. Follow-up studies, if required, would occur under Tier 3. (The reporting and 

recordkeeping requirements of these tiers are covered by a separate information collection.) The 

objective of the program is to determine if there are any fuels and/or additives whose evaporative 

emissions or products of combustion pose a particular danger to public health or welfare. 

Section 211(c) of the Act provides EPA with the authority to regulate such fuels and additives. 

For example, the use of lead additives in gasoline, gasoline volatility, and the sulfur content of 

gasoline and diesel fuel, have been regulated. In order to assist the EPA in assessing the extent 

of public exposure to a given fuel or additive, the regulations require additive manufacturers to 

submit annual reports on production. Fuel manufacturers are required to submit quarterly

production reports. The manufacturers are also required to report annually on any new health 

effects data they may have acquired. Copies of the sections of the Act mentioned above are 

available at www.epa.gov/otaq.

Another objective of the program is the review of an unleaded gasoline additive’s 

composition for compliance with EPA restrictions. In order to protect catalytic converters and 

other emission control devices, there are specific compositional limitations. On a number of 

occasions the EPA has informed a manufacturer that its additive could not be registered until the 

formulation was modified to comply with those requirements.
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An added benefit of the program has been the development of a comprehensive data base 

of gasoline and diesel fuel/additive composition. These data have proven useful in a number of 

fuels issues, such as the identification of additives with a high sulfur content.

2(b) Practical Utility/Users of the Data

The lists of registered fuels and additives are available to the public at 

www.epa.gov/otaq/additive.htm. The fuel, additive, and motor vehicle industries are well aware 

that gasolines, diesel fuels, and their additives, must be registered before they may be introduced 

into commerce for use in motor vehicles. A separate list of registered gasoline detergent 

additives is also available. These lists are frequently requested by consumers and the 

manufacturers in order to maintain an awareness of competing products. In accordance with 

regulations promulgated by the Mine Safety and Health Administration, only registered diesel 

additives may be used in diesel-powered equipment for underground coal mining.

Most of the data have been claimed as business confidential by the manufacturers. Thus 

access is restricted to authorized EPA personnel and contractors. The data have been extremely 

valuable in EPA’s evaluation of certain fuels issues. Most notably, the compositional data 

required since the program’s inception were instrumental in establishing the fuel/additive testing 

categories in the 1994 health-effects testing rules (Subpart F, 40 CFR 79). If these data indicate 

a particular threat to public health from the evaporative or exhaust emissions of a fuel or 

additive, they will be used to support regulatory action under section 211(c) of the Act.

Section 211(f) of the Act prohibits the introduction into commerce of fuels and additives 

which are not “substantially similar” to those used by the vehicle manufacturers in emissions 

certification (unless a waiver is granted). The objective is to protect emission controls from 

potentially damaging fuels and additives. The term “substantially similar” for unleaded gasoline 

has been defined via interpretive rule. Elemental composition is restricted to carbon, hydrogen, 

oxygen, nitrogen, and sulfur. On a number of occasions additive manufacturers have attempted 

to register additives for unleaded gasoline which did not meet these requirements. Thus, the 

registration program has been instrumental in enforcing requirements that were established 

independently of the registration regulations at 40 CFR 79.

The fuel/additive data base has proven extremely useful in the analysis of other fuels 

issues. For example, the data have been used to assess the development and use of gasoline 

detergent additives.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication

To our knowledge, this is the only program which requires additive manufacturers to 

report the composition of their additives, and gasoline and diesel fuel manufacturers to report the 

usage of additives in their fuels. It is the only program under which these manufacturers must 

develop information on the emissions health effects of their products. Production volumes for 
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additives are not reported elsewhere. Nowhere else are the production volumes for gasoline and 

diesel fuels reported in conjunction with additive usage in those fuels. Such data are necessary

in order to gauge the extent of public exposure to the emissions of a fuel, additive, or particular 

fuel/additive combinations.

3(b) Public Notice

A notice was published in the Federal Register (75 FR 5581, February 3, 2010) 

requesting public comment on the draft ICR. No comments were received.

3(c) Consultations

The Agency has routinely consulted with the manufacturers on the effort to comply with 

the reporting requirements. Below are the manufactures consulted with for this renewal and the 

hour estimates they offered.

Innospec Fuel Specialties

Ms. Ann Marie Savini

Regulatory Affairs Administrator

(302) 451-1362

Fuel Additive Manufacturer Notification (EPA Form 3520-13) - 20 minutes

Fuel Additive Manufacturer Annual Report (EPA Form 3520-13A) - 5 minutes

Afton Chemical Corporation

Ms. Mignon P. Robinson

Environmental Engineer

(804) 788-6027

Fuel Additive Manufacturer Notification (EPA Form 3520-13) - 1 hour

Fuel Additive Manufacturer Annual Report (EPA Form 3520-13A) - 5 minutes

Lubrizol Corporation

Dr. Dennis Dishong

Manager, Product Compliance

(440) 347-2307

Fuel Additive Manufacturer Notification (EPA Form 3520-13) - 4 hours

Fuel Additive Manufacturer Annual Report (EPA Form 3520-13A) - 2 minutes

Western Refining Southwest, Inc.

Mr. Ron Weaver

Terminals Supervisor

(505) 632-4185

Fuel Manufacturer Notification for Motor Vehicle Fuel (EPA Form 3520-12) - 30 minutes

Fuel Manufacturer Quarterly Report for Motor Vehicle Gasoline or Diesel Fuel (EPA Form 

3520-12Q) - 3 hours

Fuel Manufacturer Annual Report for Motor Vehicle Gasoline or Diesel Fuel (EPA Form 3520-

12A) - 1.5 hours
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There is a general consensus that updates, such as a change of address, for which there is not a 

form, average 1 hour

The Mine Safety and Health Administration (MSHA), U. S. Department of Labor, views 

this program as beneficial in that it will provide information on the diesel emissions to which 

underground coal miners are exposed. MSHA regulations limit the diesel additives used in 

underground coal mining to those that have been registered by EPA. 

3(d) Effects of Less Frequent Collection

Registration of a designated fuel or additive is required only once, although the 

manufacturer is required to notify EPA if changes occur in the information provided. The 

quarterly and annual reports for fuel manufacturers, and annual reports for additive 

manufacturers, are appropriate in order to monitor patterns of fuel and additive usage in a timely

manner. Should the health-effects data indicate that certain fuel/additive combinations are of 

concern, their history of usage would be necessary in order to assess the extent of public 

exposure. If these fuel/additive combinations were to experience a significant increase in usage, 

it would be important to know that on a quarterly basis. 

With refiners and importers reporting their usage of additives quarterly, the annual 

production report from the additive manufacturers remains adequate. If an additive were to 

experience a dramatic increase in production, it would be important to have that reported on at 

least an annual basis. 

3(e) General Guidelines

All Office of Management and Budget (OMB) guidelines are met. 

3(f) Confidentiality

The availability to the public of information submitted for this program is governed by 

the Freedom of Information Act (FOIA) regulations for EPA at 40 CFR part 2, with the 

exception that all health and safety test data and other information concerning health and welfare 

effects, submitted pursuant to Subpart F, shall be public. Lists of the registered fuels and 

additives are publicly available.

The majority of the manufacturers consider, for competitive reasons, the compositional 

information for their fuels and additives to be confidential. EPA’s Office of General Counsel has 

consistently ruled that confidentiality is justified when such information has been requested 

under the FOIA.

Because most of the information is confidential, this program is housed in a separate 

office protected by a multi-sensor alarm system with 24-hour monitoring. Access is via a keyfob

system for authorized personnel only. Paper files are secured in combination lock, fireproof 

cabinets with each cabinet requiring its own unique sequence to be unlocked. 
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Data processing is performed solely on computers in the secure area. These computers 

have no connections outside the secure area and employ password security measures.

Contractor personnel handle routine administrative tasks, data input, and data analysis.

EPA personnel work closely with contractor personnel and handle the technical review of the 

data and questions involving regulatory interpretation.

3(g) Sensitive Questions

There are no sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION COLLECTED

4(a) Respondents/NAICS Codes

The fuel and fuel additive manufacturers are related to the following major group North 

American Industry Classification System (NAICS) codes:

324110 - Petroleum Refineries

324199 - All Other Petroleum and Coal Products Manufacturing

325110 - Petrochemical Manufacturing

325193 - Ethyl Alcohol Manufacturing

325199 - All Other Basic Organic Chemical Manufacturing

4(b) Information Requested

(i) Data Items

The following definitions at 40 CFR 79.2 are important to the understanding of the 

reporting requirements:

“Fuel manufacturer” means any person who, for sale or introduction into commerce, 

produces, manufacturers, or imports a fuel or causes or directs the alteration of the chemical 

composition of a bulk fuel, or the mixture of chemical compounds in a bulk fuel, by adding to it 

an additive, except:

(1) A party (other than a fuel refiner or importer) who adds a quantity of additive(s) 

amounting to less than 1.0 percent by volume of the resultant additive(s)/fuel mixture is not 

thereby considered a fuel manufacturer.
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(2) A party (other than a fuel refiner or importer) who adds an oxygenate compound to 

fuel in any otherwise allowable amount is not thereby considered a fuel manufacturer.

“Additive” means any substance, other than one composed solely of carbon and/or 

hydrogen, that is intentionally added to a fuel named in the designation (including any added to a 

motor vehicle’s fuel system) and that is not intentionally removed prior to sale or use.

“Additive manufacturer” means any person who produces, manufacturers, or imports an 

additive for use as an additive and/or sells or imports for sale such additive under the person’s 

own name.

Motor vehicle gasolines, motor vehicle diesel fuels, and additives to those fuels, have 

been designated at 40 CFR part 79. For the purpose of registration, the following is required to 

be submitted by each manufacturer of a designated fuel (40 CFR 79.11) (See EPA Form 3520-

12, Fuel Manufacturer Notification for Motor Vehicle Fuel, Attachment 1, and instructions, 

Attachment 2).

1. Brand name(s) of the fuel

2. Company name

3. Company identification number (issued by EPA)

4. Address

5. Type of fuel

6. Fuel properties as specified in the regulations

7. A list of additives the manufacturer intends to use, additive manufacturer names,

purpose-in-use of each additive, and range of additive concentration

8. To the extent known, information on analytical techniques that can be used to detect the 

presence of the additives listed above in the fuel

9. To the extent known to the manufacturer, information on the mechanisms of action of the 

additives listed, reactions between the additives and the fuel, emission products, additive 

effects on emissions, health or welfare effects of additive emission products, and effects 

of additive emission products on emission controls

10. Anticipated sales, in percent, by Petroleum Administration for Defense Districts

11. Yes/no response on if fuel is derived only from conventional petroleum, heavy oil 

deposits, coal, tar sands, and/or oil sands

12. If applying for a small business provision, annual sales revenue for the past three years 

and identification of any parent company

13. If not applicable for a small business provision, identification of membership in a testing 

group

14. Indication of which portions of the form are confidential

15. List of attachments

16. Assurances that the information is correct, EPA will be notified in writing if certain 

information were to change, and that registration will not be used in advertising to imply

government approval

17. Signature, date, printed name, title, phone number, fax number, and e-mail address of 

signer
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Note that in item 16 above, the manufacturer is required to notify EPA in writing if 

certain information, listed in the regulations, were to change. This usually involves updating the 

list of additives being used and is accomplished with a brief letter. This will be referred to later 

in this ICR as a “fuel notification update.”

For the purpose of registration, the following is required to be submitted by each 

manufacturer of a designated fuel additive (40 CFR 79.21) (See EPA Form 3520-13, Fuel 

Additive Manufacturer Notification, Attachment 3, and instructions, Attachment 4).

1. Commercial name(s) of the additive

2. Company name and company identification number (issued by EPA)

3. Address

4. Method of use (bulk and/or aftermarket)

5. Fuels for which the additive is recommended and range of concentration

6. Recommended purpose-in-use of the additive

7. Chemical composition of the additive

8. Chemical structure of the additive

9. To the extent known, impurities at greater 0.1% by weight

10. To the extent known, information on analytical techniques that can be used to detect the 

additive in fuel

11. To the extent known to the manufacturer, information on additive mechanisms of action, 

reactions between the additive and fuel, identification and measurement of additive 

emission products, effects of the additive on emissions, toxicity or any other health 

effects of the additive emission products, and effects on emission controls;

12. Yes/no response on if the additive is a relable of a currently registered additive

13. Estimated annual production during the third year of production

14. Estimated market distribution for the third year of production

15. Yes/no response on if the additive is derived only from conventional petroleum, heavy oil 

deposits, coal, tar sands, and/or oil sands

16. If applying for a small business provision, annual sales revenue for the past three years 

and identification of any parent company

17. Yes/no response on if the additive is an aerosol, and if so, if applying for the aerosol 

provision

18. If not applicable for a small business or aerosol provision, identification of membership 

in a testing group

19. Indication of which portions of the form are confidential

20. List of attachments;

21. Assurances that the information is correct, EPA will be notified in writing if certain 

information were to change, and that registration will not be used in advertising to imply

government approval

22. Signature, date, printed name, title, phone number, fax number, and e-mail address of 

signer

Note that in item 21 above, EPA would be notified in writing if certain information, listed 

in the regulations, were to change. This is accomplished by a brief letter, and involves minor 
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issues such as an additional name under which the additive will be sold. This will be referred to 

later in this ICR as an “additive notification update.”

Additive manufacturers are also required to report annually the following information for 

each registered additive (40 CFR 79.5(b)) (See EPA Form 3520-13A, Fuel Additive 

Manufacturer Annual Report, Attachment 5, and instructions, Attachment 6, and, if reporting for 

more than 16 additives, EPA Form 3520-13B, Supplemental Additive Manufacturer Annual 

Report, Attachment 7).

1. Company name and company identification number

2. Report year

3. Type of report (original or resubmission)

4. Impurities, if greater than 0.1% by weight, to the extent known

5. Any information known to the manufacturer and not previously reported on mechanisms 

of action, reactions with fuels, emission products, or emission effects

6. Production (volume or weight) for the year for the additive(s)

7. Indication of which portions of the form are confidential

8. Signature, date, printed name, title, phone, fax, e-mail

9. Indication if a supplemental report is attached

Additive manufacturers who are merely relabeling a registered additive or blend of 

registered additives are not required to submit an annual report, since the information would be 

covered by the original manufacturer(s).

Fuel manufacturers are also required to report quarterly the following information for 

each registered gasoline and diesel fuel (40 CFR 79.5(a)(1)) (See EPA Form 3520-12Q, Fuel 

Manufacturer Quarterly Report for Motor Vehicle Gasoline or Diesel Fuel, Attachment 8, and 

instructions, Attachment 9).

1. Company name and identification number

2. Address

3. Fuel identification number

4. Report year

5 Quarterly production volume

6. Quarter

7. Brand name of the fuel

8. Range of concentration during the quarter for each additive previously reported for use in 

the fuel

9. Indication of which items are confidential

10. Signature, date, printed name, title, phone, fax, e-mail

Fuel manufacturers are also required to report annually the following information for 

each registered gasoline and diesel fuel (40 CFR 79.5(a)(2)) (See EPA Form 3520-12A, Fuel 

Manufacturer Annual Report for Motor Vehicle Gasoline or Diesel Fuel, Attachment 10, and 

instructions, Attachment 11).
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1. Company name and identification number

2. Address

3. Fuel identification number

4. Report year

5. Brand names(s)

6. Fuel properties, to the extent known by the manufacturer

7. If not previously reported, information known by the manufacturer on mechanisms of 

action, reactions between additives and fuels, emission products, and emission effects

8. Indication of which items are confidential

9. Signature, date, printed name, title, phone, fax, and e-mail

There are no recordkeeping requirements.

(ii) Respondent Activities

The following activities are required.

1. Read or hear the regulations at 40 CFR 79 and the instructions for each of the 

applicable forms

2. Gather information from company files

3. Review the information

4. Enter information onto the forms and sign

5. If indicated on the forms that additional information is attached, copy such information

6. Transmit the information

5. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

The following activities are required:

1. Respond to inquiries on the reporting requirements;

2. Mail copies of the forms/instructions, regulations, list of all registered additives, list of 

registered gasoline detergent additives, list of registered diesel additives, and/or list of 

registered fuels upon request;

3. Review the forms and other submitted data;

4. Contact the manufacturer when the information has not been submitted in accordance 

with the regulations and discuss how the problem can be resolved;

5. Store the information in hard copy;

6. Enter the data submitted on the forms into the database.

7. Issue a letter to the manufacturer for each fuel and additive that is registered;

8. Administer a contract for the day-to-day operation of the registration program;

9. Maintain rigorous security for the protection of confidential business information;

10. Maintain a record of all confidential business information provided to the contractor;
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11. Maintain computer hardware and software;

12. Provide general program oversight.

5(b) Collection Methodology and Management

The manufacturers are completing forms which are very straightforward and whose basic 

structure dates back to 1975. We have not had complaints on the design of the forms. 

Much of the information is maintained in the normal course of business, such as the chemical 

composition of an additive and its annual production. For information which may not normally

be maintained, such as mechanisms of reaction, the manufacturer is not required to search 

beyond its company files. EPA and its contractor review the forms and in some cases the 

manufacturer must be contacted for clarification or additional information. Since most of the 

information is confidential, the data are handled exclusively on a physically and electronically 

isolated IBM/PC-based local area network using Novell NetWare as an operating system and 

running FOXPRO database software as the database platform. Data are input and reports 

generated on workstations located entirely within the locked facility and connected to the 

network through direct connections. EPA personnel routinely compare the data that have been 

entered into the database with hard copy. The network is not connected to the Agency’s LAN 

backbone and has no modem connections. The facility is protected by an advanced security 

system described earlier. 

All of the forms and instructions are available for downloading at: 

http://www.epa.gov/otaq/regs/fuels/ffarsfrms.htm. Manufacturers may also submit the quarterly

and annual reports in the format of their choice, including on diskette, if they prefer not to use 

the forms.

5(c) Small Entity Flexibility

The reporting requirements have been kept as simple as possible to minimize the burden 

on all manufacturers. EPA is not aware of any simpler format to provide the chemical 

descriptions and related information. Changes to the regulations in 1997 removed many small 

businesses from the program, by excluding those who only add oxygenates or small amounts of 

additives to fuels from the definition of a fuel manufacturer. For manufacturers who merely 

relabel additives, which are usually small businesses, the one-time notification is very simple, 

and there are no periodic reporting requirements.

5(d) Collection Schedule

For the manufacturer of a fuel, there is a one-time registration for the fuel and an onoccasion requirement to inform the Agency if the information provided for registration changes. 

There are also quarterly and annual reports that a fuel manufacturer is required to submit for the 

registered fuel.

For the manufacturer of a fuel additive, there is a one-time registration for the additive, 

and an on-occasion requirement to inform the Agency if the information provided for registration 
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were to change. There is also an annual report that the additive manufacturer is required to 

submit for the registered additive.

6. ESTIMATING THE BURDEN AND THE COST OF THE COLLECTION

6(a) and (b) Estimating Respondent Burden and Costs

Estimating the burden is straightforward. For the most part, the manufacturer is 

collecting and reporting information that is available in the normal conduct of business, such as 

product composition and production volume. Other information, such as health effects data, only 

have to be reported if they reside in the company files. No searching beyond company files is 

required. There are no recordkeeping requirements. There are no third party activities. Thus, 

there are no capital/start-up costs. The only operating and maintenance (O&M) cost is for 

copying and postage for each submission. Instead of including this in each burden table, a cost 

of $5.00 per submission will be included in the total burden estimate. 

In discussions with fewer than ten fuel and fuel additive manufacturers, four labor 

categories were identified as having involvement: managerial, legal, professional/technical

(prof/tech), and clerical. According to the Bureau of Labor Statistics, May 2008 National 

Industry-Specific Occupational Employment and Wage Estimates, mean wages were:

Wages

Managerial $60.42 per hour

Legal $84.56 per hour

Prof/Tech $60.05 per hour

Clerical $17.34 per hour

Doubling for company overhead and employing a 2% annual inflation factor to bring the 

rates to the year 2010, and, for convenience, rounding up to the nearest dollar, gives the follow 

rates that will be used in this ICR.

Total Employer Cost

Managerial $126 per hour

Legal $176 per hour

Prof/Tech $125 per hour

Clerical $ 36 per hour

The labor mix for the activities above will be about the same for each. It is assumed that 

for each hour of activity the mix will be about 0.05 hour managerial, 0.05 hour legal, 0.7 hour 

professional/technical, and 0.2 hour clerical. This gives an average labor cost of about $110 per 

hour, which will be used in this ICR. The burden estimates for each activity are the same as for 

the previous ICR. That is, a fuel manufacturer notification will require 8 hours on average to 

complete. Likewise, the fuel additive manufacturer notification will require 8 hours to complete. 

The additive update, fuel update, and additive annual report each require one hour on average to
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complete. The fuel annual and fuel quarterly reports each require 3 hours on average to 

complete.

Cost per Report

Fuel Manufacturer Notification - 8 hours @ $110 = $880

Fuel Notification Update - 1 hour @ $110 = $110

Fuel Additive Manufacturer Notification - 8 hours @ $110 = $880

Additive Notification Update - 1 hour @ $110 = $110

Additive Manufacturer Annual Report - 1 hour @ $110 = $110

Fuel Manufacturer Quarterly Report - 3 hours @ $110 = $330

Fuel Manufacturer Annual Report - 3 hours @ $110 = $330

6(c) Estimating Agency Burden and Cost

The Agency activities listed in section 5(a) are handled primarily by contractor personnel 

for $174,000 per year. A part time Senior Environmental Employee (SEE) is employed at 

$14,000 per year for data entry. Eight hundred twenty square feet of space are leased at $25,000 

per year. Security monitoring is $5,000 per year. Portions of the following EPA personnel are 

involved (with 1.6 overhead factor):

GS -14 Environmental Engineer (EE), $120K x 1.6=$192K

GS-13 Chemical Engineer (CE), $100K x 1.6=$160K

GS-13 Program Analyst (PA), $100K x 1.6=$160K

GS-13 Computer Specialist (CS), $100K x 1.6=$160K

Worksheet 9: Annual Agency Burden in Full Time Equivalents (FTE’s)

activity EE CE PA CS

respond to

inquiries 0.1/$19200 0.1/$16000 0 0

mail info by contractor

review data 0.1/$19200 0.2/$32000 0 0

contact manu. 0 0.1/$16000 0 0

store info by contractor
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enter data by contractor and Senior Environmental Employee

issue letters by contractor

contract ad. 0.1/$19200 0 0.2/$32000 0

security 0 0 0.1/$16000 0

record cbi division clerical support

maintain computer by contractor 0.05/$8000

program oversight 0.2/$38400 0.1/$16000 0 0

totals 0.5/$96000 0.5/$80000 0.3/$48000 0.05/$8000

total 1.35 FTE/$232,000

Total Annual Cost to the Government

Contract $ 174,000

Part time SEE $ 14,000

Lease $ 25,000

Security $ 5,000

FTE’s $232,000

Total $450,000

Thus, the annual estimated cost to the government is $450,000. The total hours are 1.35 

FTE x 2080 hours/FTE=2808.

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

Bottom Line Burden Hours and Costs

The following worksheet is based on an inventory of 700 registered fuels (up from 500 in 

the previous ICR) and 7,200 registered additives (up from 5,800 the previous ICR). Of the 

additives, about 3,000 are relabels, so only 7,200-3,000 = 4,200 additives will require annual 

reports. Data for 2009 indicate that EPA is receiving approximately 75 new fuel notifications 

(down from 100), 200 fuel notification updates (down from 250), 500 new additive notifications 

(unchanged), and 200 additive notification updates (down from 300) annually. 

Worksheet 10: Annual Industry Burden

Form Number Hours/Cost Total Hours/Cost

Additive

Notification 500 8.0/$880 4000/$440,000

Additive Update 200 1.0/$110 200/$22,000
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Additive Annual 4200 1.0/$110 4200/$462,000

Fuel Notification 75 8.0/$880 600/$66,000

Fuel Update 200 1.0/$110 200/$22,000

Fuel Annual 700 3.0/$330 2100/$231,000

Fuel Quarterly 2800 3.0/$330 8400/$924,000

Totals 8,675 19,700/$2,167,000

Thus, the net burden to industry is 19,700 hours and $2,167,000, plus 8,675 submissions 

x $5.00 each for copying and postage, or $43,375+$2,167,000=$2,210,375. (The net burden for 

the previous ICR was $1,411,750.) The burden is gauged per form. Some manufacturers have 

hundreds of products, some have only one or two. Per section 6(c), the annual burden to the 

government is 2808 hours and $450,000. It is recommended that the above costs be increased 

2% annually for inflation.

6(f) Reasons for Change in Burden

The net burden has increased due to an increase in the number of fuels and an increase in 

labor rates. The following worksheet summarizes the changes:

Worksheet 11: Changes in Burden - Hours

Form Previous Requested Change Reason

additive

notification 4000 4000 0

additive 

update 300 200 -100 adjustment

additive 

annual 4300 4200 -100 adjustment

fuel

notification 800 600 -200 adjustment

fuel

annual 1500 2100 +600 adjustment

fuel 

quarterly 6000 8400 +2400 adjustment

fuel 
16

update 250 200 -50 adjustment

totals 17,150 19,700 +2,550

6(g) Burden Statements

Burden Statement: The annual public reporting and recordkeeping burden for this 

collection of information is estimated to average 2 hours per response. Burden means the total 

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

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

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

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

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

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

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

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

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

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

CFR part 9 and 48 CFR chapter 15. 

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

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

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

Docket ID No. EPA-HQ-OAR-2006-0894, which is available for public viewing at the Office of 

Air and Radiation Docket 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 Office of Air 

and radiation Docket is (202) 566-1742. An electronic version of the public docket is available 

through www.regulations.gov. Use the 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. Once in the system, follow the on-line instructions. 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-2006-0894 and OMB control number 

2060-0150 in any correspondence. 

For the additive annual report form, the statement would be identical, with the exception 

that the burden estimate would be one hour. For the quarterly and annual fuel report forms, the 

statement would be identical, with the exception that the burden estimate would be three hours.

Attachments (These are not attached. For access, see the web address in section 5(b).)

Attachment 1 - EPA Form 3520-12
17

Attachment 2 - Instructions for EPA Form 3520-12

Attachment 3 - EPA Form 3520-13

Attachment 4 - Instructions for EPA Form 3520-13

Attachment 5 - EPA Form 3520-13A

Attachment 6 - Instructions for EPA Form 3520-13A

Attachment 7 - EPA Form 3520-13B

Attachment 8 - EPA Form 3520-12Q

Attachment 9 - Instructions for EPA Form 3520-12Q

Attachment 10 - EPA Form 3520-12A

Attachment 11 - Instructions for EPA Form 3520-12A