Technical Support 

Document

Analysis of the Economic Impact and 

Benefits of Proposed Revisions to the 

National Recycling and Emission Reduction 

Program

August 26, 2015

U.S. Environmental Protection Agency

Stratospheric Protection Division

Office of Atmospheric Programs

1200 Pennsylvania Avenue, NW

Washington, DC 20460
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iii August 26, 2015

Contents

Executive Summary..........................................................................................................................vii

1. Introduction ................................................................................................................................1

1.1. Regulatory Context.......................................................................................................................3

1.1.1. Profile of Regulated Community .....................................................................................3

1.1.2. Current Leak Repair Requirements.................................................................................3

1.1.3. Current Recordkeeping and Reporting Requirements....................................................4

1.2. Proposed Regulatory Revisions....................................................................................................6

1.2.1. Proposed Changes to the Leak Repair Requirements.....................................................6

1.2.2. Proposed Changes to the Recordkeeping and Reporting Requirements........................7

1.2.3. Other Proposed Regulatory Revisions.............................................................................8

1.3. Organization of This Report..........................................................................................................8

2. Industry Characterization...........................................................................................................10

2.1. Affected Industry for Leak Inspection and Repair Requirements ..............................................10

2.1.1. Equipment Characterization..........................................................................................10

2.1.2. Industry Characterization ..............................................................................................14

2.2. Affected Industry for Recordkeeping and Reporting Requirements..........................................20

2.3. Affected Industry for Self-sealing Valves on DIY Small Cans......................................................22

3. Methodology .............................................................................................................................23

3.1. Approach for Estimating Aggregate Annual Costs to the U.S. Economy....................................24

3.1.1. Leak Inspection and Repair............................................................................................24

3.1.2. Recordkeeping and Reporting .......................................................................................34

3.1.3. Self-sealing Valves on DIY Small Cans............................................................................39

3.1.4. Extending Other Existing Requirements to HFCs and Other Substitutes: Implications 

for Costs.........................................................................................................................39

3.2. Approach for Estimating the Economic Impact on Small Entities..............................................42

3.2.1. Leak Inspection and Repair Model Facility and Entity Assumptions.............................42

3.2.2. Reporting and Recordkeeping .......................................................................................44

3.2.3. Self-sealing Valves on DIY Small Cans............................................................................45

3.3. Approach for Estimating Benefits...............................................................................................45

3.3.1. Emission Reduction Benefits of Leak Inspection and Repair.........................................45

3.3.2. Emission Reductions Benefits of Installing Self-sealing Valves on Small Cans..............48

3.3.3. Extending Other Existing Requirements to HFCs and Other Substitutes: Implications 

for Benefits....................................................................................................................50

4. Aggregate Economic Impact Analysis..........................................................................................51

4.1. Annual Compliance Costs...........................................................................................................51

4.2. Annual Refrigerant Savings.........................................................................................................52

4.3. Annual Emission Reduction Benefits..........................................................................................53

4.4. Looking Forward: Emission Reduction Benefits in 2020 and 2025 ............................................53

4.5. Other Benefits.............................................................................................................................54

5. Small Entities Impact Analysis....................................................................................................56

5.1. Decision Matrix for Determining Significant Economic Impact on a Substantial 

Number of Small Entities..................................................................................................56

5.2. Aggregate Small Business Impacts of Proposed Regulatory Changes........................................57
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6. Statutory and Executive Order Impact Analyses..........................................................................60

7. Conclusions ...............................................................................................................................61

8. References.................................................................................................................................62

Appendix A. Sensitivity Analyses for Aggregate Economic Analysis.................................................. A-1

Appendix B. Detailed Tables for Recordkeeping and Reporting........................................................ B-1

Appendix C. Detailed Tables for SISNOSE Analysis........................................................................... C-1

Appendix D. Sensitivity Analysis for SBREFA ................................................................................... D-1

Appendix E. NAICS Codes................................................................................................................E-3

Appendix F. Costs Incurred by DIYers for a Sales Restriction...........................................................F-14

Tables

Table 1. Summary of EPA’s Proposed Changes to Section 608 Regulations by Rule 

Component.................................................................................................................................vii

Table 2. Industries Affected by the Proposed Regulatory Changes by Rule Component............................. x

Table 3. Existing Annual Leak Rates by Appliance Type................................................................................ 4

Table 4: Equipment Characterization by Sector, Type, Size, and Refrigerant Type.................................... 12

Table 5: Typical Refrigerants Used by Equipment Type ............................................................................. 13

Table 6: Typical Charge Size Categories by Equipment Type...................................................................... 13

Table 7: Industry Sector, NAICS Code, and Definition ................................................................................ 14

Table 8: Total Businesses and Facilities by Industry Category.................................................................... 17

Table 9: Percentage of Industry Containing Appliances with 50 or More Pounds of ODS 

or HFC Refrigerant, and Average Number of Systems per Facility ........................................... 18

Table 10: Universe of Affected Equipment................................................................................................. 20

Table 11. Total Number of Small Entities Affected by Industry Category and NAICS Code ....................... 21

Table 12: Industry Characterization for Small Can Manufacturers Affected by Proposed 

Rule............................................................................................................................................ 22

Table 13: Leak Repair Outcomes and Proportions ..................................................................................... 27

Table 14: Leak Rate Assumptions by Equipment Sector, Type, and Size.................................................... 28

Table 15: Unit Cost Assumptions................................................................................................................ 31

Table 16. Leak Rate Comparison Based on California’s RMP and EPA’s Vintaging Model ......................... 33

Table 17: Affected Equipment Assumptions by Equipment Sector, Type, Size, and 

Refrigerant Type........................................................................................................................ 33

Table 18. Appliances with Charge Sizes Between 5 and 50 Pounds Disposed in 2015 .............................. 38

Table 19: Regulatory Changes Assumed to Present No Incremental Cost................................................. 40

Table 20. Potentially Affected Industries for Reporting and Recordkeeping Requirements...................... 44

Table 21: Average GWP and ODP Assumptions by Equipment Type, Size, and Refrigerant 

Type........................................................................................................................................... 46

Table 22. Annual Compliance Costs by Rule Component (2014$).............................................................. 51

Table 23. Total Annual Refrigerant Savings (2014$), Compliance Costs, and Combined 

Annual Compliance Costs and Refrigerant Savings................................................................... 52

Table 24. Annual GHG and ODS Emissions Avoided in 2015 ...................................................................... 53

Table 25. Annual GHG Emissions Avoided in 2020 (MTCO2eq.) ................................................................. 53
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Table 26. Annual GHG Emissions Avoided in 2025 (MTCO2eq.) ................................................................. 54

Table 27. Annual ODS Emissions Avoided in 2020 and 2025 (ODP-weighted MT)..................................... 54

Table 28. Decision Matrix for Certifying SISNOSE....................................................................................... 56

Table 29. Summary of the Small Business Impact ...................................................................................... 57

Table 30. Aggregated Economic Impacts on Small Businesses................................................................... 59

Table 31: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

CARB ODS and HFC Equipment Distribution............................................................................A-1

Table 32: . Annual GHG and ODS Emissions Avoided with CARB ODS and HFC Equipment 

Distribution ..............................................................................................................................A-2

Table 33: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

200-pound Annual Leak Inspection Threshold.........................................................................A-3

Table 34: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

Higher Post-Repair Leak Rate...................................................................................................A-4

Table 35: . Annual GHG and ODS Emissions Avoided with Higher Post-Repair Leak Rate ........................A-4

Table 36: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

3% Discount Rate .....................................................................................................................A-5

Table 37: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 2-

week Leak Repair Improvement ..............................................................................................A-6

Table 38: . Annual GHG and ODS Emissions Avoided with 2-week Leak Repair 

Improvement............................................................................................................................A-7

Table 39: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

2-month Leak Repair Improvement.........................................................................................A-8

Table 40: . Annual GHG and ODS Emissions Avoided with 2-month Leak Repair 

Improvement............................................................................................................................A-9

Table 41: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

Lower Threshold Leak Rates ..................................................................................................A-10

Table 42: Annual GHG and ODS Emissions Avoided with Lower Threshold Leak Rates..........................A-11

Table 43: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 

Higher Threshold Leak Rates..................................................................................................A-12

Table 44: Annual GHG and ODS Emissions Avoided with Higher Threshold Leak Rates.........................A-13

Table 45. Annual Compliance Costs for Recordkeeping and Reporting ....................................................B-1

Table 46: Estimated Number of Small Businesses Affected by NAICS Code .............................................C-1

Table 47. Aggregated Economic Impacts on Small Businesses with 3% Discount Rate ........................... D-1

Table 48: NAICS Codes Included in the Leak Repair Regulation Analysis.................................................. E-3

Table 49: NAICS Codes Included in the Small-can Analysis .....................................................................E-13

Table 50: NAICS Codes Included in the Recordkeeping and Reporting Requirements 

Analysis...................................................................................................................................E-13

Table 51. Costs Incurred by DIYers to Take Vehicle to a Professional Service Shop ............................... F-14

Table 52. Costs Incurred by DIYers to Become a 609 Certified Technician ............................................. F-14
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Executive Summary

Under the National Recycling and Emission Reduction Program, found at Section 608 of the Clean Air Act 

(40 CFR part 82, subpart F), EPA has established standards and regulations for the use and disposal of 

ozone-depleting substances (ODS) during the maintenance, service, repair, or disposal of airconditioning and refrigeration appliances. EPA is proposing to extend, as appropriate, the existing 

requirements in subpart F that currently apply to ozone-depleting refrigerants to non-ozone-depleting 

substitute refrigerants, such as hydrofluorocarbons (HFCs). Further, EPA is proposing to revise Section 

608 rule components associated with leak repair; recordkeeping and reporting, and the refrigerant sales 

restriction. EPA’s proposed changes to Section 608 are summarized in Table 1 below by rule component.

Table 1. Summary of EPA’s Proposed Changes to Section 608 Regulations by Rule Component

Rule Component Proposed Change

Leak Inspection and 

Repair

 Extend the existing requirements to comfort cooling (CC), commercial 

refrigeration (CR), and industrial process refrigeration (IPR) equipment containing 

50 or more pounds of HFC and other substitute refrigerant;

 Lower the annual leak rates for CC, CR, and IPR equipment containing 50 or more 

pounds of ODS, HFC, or other substitute refrigerant; 

 Require periodic leak inspections for equipment containing 50 or more pounds of 

ODS, HFC, or other substitute refrigerant;

 Establish a leak limit where an appliance is prohibited from leaking more than 75% 

of its full charge in two consecutive years;

 Require initial and follow-up verification tests for all appliances (i.e., IPR, CR, and 

CC equipment) when the applicable leak rate is exceeded;

 Require a leak inspection to identify leaks upon discovering that the applicable 

leak rate is exceeded;

 Require that all identified leaks are repaired when the applicable leak rate is 

exceeded rather than just bringing the leak rate down below the annual leak rate

threshold;

 Allow leak repair extension requests for all equipment, including non-federal CR 

and CC systems; and

 Explicitly allow (and even encourage) electronic instead of paper records.
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Rule Component Proposed Change

Recordkeeping and 

Reporting

 Extend the current recordkeeping and reporting requirements to appliances 

containing HFCs and other non-exempt substitutes;

 Allow owners/operators of all ODS, HFC, and other substitute refrigerantcontaining appliances with charge sizes of 50 or more pounds to prepare and 

submit requests for extensions to the leak repair and retrofit/retire timeline;

 Require persons servicing ODS, HFC, and other substitute refrigerant-containing 

appliances with charge sizes of 50 or more pounds to provide records of the 

following for each refrigerant addition: the identity and location of the appliance, 

the date and type of service performed, the quantity and type of refrigerant 

added, the full charge of the system, and the leak rate;

 Require owners/operators of ODS, HFC, and other substitute refrigerantcontaining appliances with charge sizes of 50 or more pounds to maintain records 

of the following for each refrigerant addition: the identity and location of the 

appliance, the date and type of service performed, the quantity and type of 

refrigerant added, the full charge of the system, and the leak rate;

 Require owners/operators of ODS, HFC, and other substitute refrigerantcontaining appliances with charge sizes of 50 or more pounds to maintain reports 

on the results of verification tests and leak inspections any time the leak rate 

threshold is exceeded;

 Require owners/operators of ODS, HFC, and other substitute refrigerantcontaining appliances with charge sizes of 50 or more pounds to maintain records 

of quarterly and annual leak inspections;

 Require technicians disposing of field-installed appliances with charge sizes 

between 5 and 50 pounds to maintain records on the quantity and types of 

refrigerant recovered at disposal and the quantity and type of refrigerant 

transferred for reclamation or destruction, as well as the company name and date;

 Require approved technician certifying programs to publish online lists or 

databases documenting who they have certified and what type of certification 

each individual has received;

 Require manufacturers of small cans of automotive refrigerant to keep records of 

test data and log forms that demonstrate compliance with the allowable leakage 

rate; and

 Remove the requirement for persons who maintain, service, repair, or dispose of 

appliances containing ODS refrigerants to submit a signed statement that they 

own certified recovery and recycling equipment.

Refrigerant Sales 

Restriction

 Extend the sales restriction to HFCs and other non-exempt substitutes;

 Exempt small cans of HFC refrigerant that are used for DIY aftermarket servicing of 

MVACs from the sales restriction; and

 Require self-sealing valves on small cans of substitute refrigerant.
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Rule Component Proposed Change

Other  Extend all other the regulatory requirements found at 40 CFR part 82, subpart F, 

including technician certification, appliance disposal, reclamation, service 

practices, and the requirement to recover refrigerant to HFCs and other nonexempt substitutes; and

 Require substitute-containing recycling/recovery equipment to be certified. 

The purpose of this report is to present the results of a costs and benefits assessment to assist EPA in 

evaluating the impacts of the proposed changes to Section 608 regulations and satisfying its obligations 

under relevant statutes and Executive Orders (EOs), including EO 12866: Regulatory Planning and 

Review, the Regulatory Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement 

Fairness Act (SBREFA), and the Unfunded Mandates Reform Act (UMRA) of 1995. This report was 

developed with support from ICF International.

General Approach

Below is a summary of the general approach used to estimate the impact of the proposed regulatory 

changes associated with each major rule component. A list of potentially affected industry sectors by 

major rule component is presented in Table 2. 

 Leak inspection and repair. To estimate the impact of the proposed regulatory changes associated 

with leak inspection and repair to the U.S. economy as a whole and individual small businesses, this 

analysis uses a model entity approach. The model entity approach is built up from a model facility 

analysis, which was developed based on assumptions about model equipment. First, the impacts 

were estimated for each type of affected equipment. Then, impacts were estimated for a model 

facility in each of the industry categories presented in Table 2. Assumptions about the number and

type of equipment used per model facility varied based on the industry category. Lastly, impacts per 

model facility were scaled to a model entity based on the average number of facilities an entity is 

estimated to have in each industry category. 

 Reporting and recordkeeping. To estimate the impact of the proposed regulatory changes 

associated with recordkeeping and reporting, the estimated burden (hours) was multiplied by the 

assumed average hourly administrative cost of labor plus overhead for a private firm (hourly wage 

rate). Additional details regarding the estimated recordkeeping and reporting burden are found in 

the supporting statement for the Information Collection Request accompanying this proposed rule.

 Refrigerant sales restriction. To estimate the impact of requiring self-sealing valves on small cans of 

automotive refrigerant for MVAC servicing, the total number of small cans sold annually in the 

United States was multiplied by the cost per self-sealing valve.

To estimate impacts on small businesses, industries potentially affected by these regulatory options 

were primarily identified by North American Industry Classification System (NAICS) codes. Small 

businesses in each affected industry were classified as such based on size definitions established by the 
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Small Business Administration. Economic impacts on affected small businesses were calculated using a 

direct compliance cost method. The “sales test” was applied by estimating annualized compliance costs 

for affected small businesses as a percentage of those businesses’ annual sales.

Table 2. Industries Affected by the Proposed Regulatory Changes by Rule Component

Rule 

Component Industry Category NAICS Codes NAICS Code Definition

Leak 

Inspection and 

Repair; 

Reporting and 

Recordkeeping

Agriculture and Crop Support 

Services

115 Support Activities for Agriculture and Forestry

Arts, Entertainment, and Recreation 71 Arts, Entertainment, and Recreation

Beverage and Ice Manufacturing 312 Beverage Manufacturing

Durable Goods Wholesalers and 

Dealers

423 Merchant Wholesalers - Durable Goods

441 Motor Vehicle and Parts Dealers

Educational Services 611 Educational Services

Food manufacturing 311 Food manufacturing

General Merchandise Stores 452 General Merchandise Stores

453998 All Other Miscellaneous Store Retailers (except 

Tobacco Stores) 

Grocery and Specialty Food Stores 4451 Grocery Stores

4452 Specialty Food Stores

72231 Food Service Contractors

Hospitals 622 Hospitals

Non-durable Goods Wholesalers and 

Dealers

424 Merchant Wholesalers – Non-durable Goods

Non-food Manufacturing 322 Paper Manufacturing

323 Printing and Related Support Activities

324 Petroleum Manufacturing

325 Chemical Manufacturing

3254 Pharmaceutical Manufacturing

326 Plastics and Rubber Manufacturing

332 Metals Manufacturing

333 Machinery Manufacturing
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Rule 

Component Industry Category NAICS Codes NAICS Code Definition

334 Computer and Electronic Product Manufacturing

336 Transportation Equipment Manufacturing

3391 Medical Equipment and Supplies Manufacturing

339999 Miscellaneous Manufacturing 

Office Buildings 511 Publishing Industries (except Internet)

512 Motion Picture and Video Industries

515 Broadcasting

517 Telecommunications

518 Data Processing, Hosting, and Related Services

519 Libraries and Archives

522 Credit Intermediation and Related Activities

524 Insurance Carriers

531 Real Estate

541 Professional, Scientific, and Technical Services

551 Management of Companies and Enterprises

561 Administrative and Support Services

712 Museums, Historical Sites, and Similar Institutions

721 Accommodation

813 Religious, Grantmaking, Civic, Professional, and Similar 

Organizations

Other Warehousing, Storage, and 

Transportation

48 Transportation and Warehousing

4931 Warehousing and Storage

Refrigerated Warehousing and 

Storage

49312 Refrigerated Warehousing and Storage

Research and Development 5417 Research and Development

Utilities 211 Oil and Gas Extraction

221 Utilities

Warehouse Clubs and Supercenters 452910 Warehouse Clubs and Supercenters 

Recordkeeping Reclaimers 325120 Industrial Gas Manufacturing
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Rule 

Component Industry Category NAICS Codes NAICS Code Definition

and Reporting 423930 Recyclable Material Merchant Wholesalers

562920 Materials Recovery Facilities

562212 Solid Waste Landfill

424690 Other Chemical and Allied Products Merchant 

Wholesalers

Refrigerant Wholesalers 325120 Industrial Gas Manufacturing

424690 Other Chemical and Allied Products Merchant 

Wholesalers

42 Wholesale Trade

Service Technicians 238220 Plumbing, Heating, and Air-conditioning Contractors

Disposal Establishments 562920 Materials Recovery Facilities

562212 Solid Waste Landfill

423990 Other Miscellaneous Durable Goods Merchant 

Wholesalers

Service Establishments 811310 Commercial Industrial Machinery and Equipment (not 

Automotive and Electronic) Repair and Maintenance

811412 Appliance Repair and Maintenance

Refrigerant 

Sales 

Restriction; 

Recordkeeping 

and Reporting

Small Can Manufacturers 441310 Automotive Parts and Accessories Stores

325120 Industrial Gas Manufacturing

Summary of Results: Costs and Benefits

Total annual compliance costs for EPA’s proposed rulemaking are estimated to be $62–66 million, with a 

best estimate of $63 million.

1

This estimate includes annual compliance costs associated with the 

proposed rulemaking, as well as avoided compliance costs associated with the proposed removal of 

some existing regulatory requirements and the provision of additional flexibility that are expected to 

reduce regulatory burden. The proposed rulemaking is also expected to result in approximately $52

million in savings associated with reduced use of ODS and HFC refrigerant. 

 

1

2014$, using a 7% discount rate. Compliance costs using a 3% discount rate are estimated at $83 million.
xiii August 26, 2015

Total annual greenhouse gas (GHG) emissions avoided associated with the proposed regulatory changes 

has a best estimate of 7.5 MMTCO2eq. Total ODS emissions avoided are estimated at 116 ODP-weighted 

MT.

This screening analysis finds that the proposed rulemaking can be presumed not to have a significant 

economic impact on a substantial number of small entities (SISNOSE). In total, an estimated 950,500 

small businesses may be subject to the proposed regulatory actions. About 944,000 small businesses 

(99%) are expected to incur compliance costs as a result of this rulemaking that are less than 1% of 

annual sales. Approximately 150 affected small businesses—or less than 0.02%—could incur costs in 

excess of 1% of annual sales, and fewer than 80 small businesses—or less than 0.01%—could incur costs 

in excess of 3% of annual sales. These estimates are below the thresholds for a substantial number 

determination under the RFA.
1 August 26, 2015

1. Introduction

Section 608 of the Clean Air Act (CAA) Amendments of 1990, also known as the National Recycling and 

Emission Reduction Program (the Program), provides authority for the U.S. Environmental Protection 

Agency’s (EPA) regulations governing the use of ozone-depleting substances (ODS), including 

chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), during the maintenance, service, 

repair, or disposal of air-conditioning and refrigeration equipment. The purpose of the Program is to: (1) 

prohibit any person from intentionally venting ODS refrigerants and their substitutes, such as HFCs, into 

the environment; (2) reduce the use and emissions of refrigerants; (3) maximize the recapture and 

recycling of refrigerants; and (4) ensure safe disposal of refrigerants. To this end, regulations established 

under 40 CFR part 82, subpart F:

 Prohibit knowingly venting or otherwise releasing into the environment any refrigerant, including 

substitutes for ODS, while maintaining, servicing, repairing, or disposing of appliances.

 Require service practices that maximize recovery and recycling of ODS (both CFCs and HCFCs and 

their blends) during the servicing and disposal of air-conditioning and refrigeration equipment.

 Set certification requirements for refrigerant recycling and recovery equipment, technicians, and 

refrigerant reclaimers.

 Generally restrict the sale of ODS refrigerant to certified technicians. 

 Require used ODS refrigerant to be reclaimed to certain purity standards before being resold.

 Require persons servicing or disposing of air-conditioning and refrigeration equipment containing an 

ODS to certify to EPA that they have acquired refrigerant recovery and/or recycling equipment and 

are complying with the requirements of the rule. 

 Require the repair of significant leaks in air-conditioning and refrigeration equipment containing 

more than 50 pounds of an ODS refrigerant. 

 Establish safe disposal requirements to ensure removal of ODS refrigerants from goods that enter 

the waste stream with the charge intact (e.g., motor vehicle air conditioners, home refrigerators, 

and room air conditioners). 

 Require reporting and recordkeeping for technicians; technician certification programs; equipment 

testing organizations; refrigerant wholesalers and purchasers; refrigerant reclaimers; refrigeration 

and air-conditioning equipment owners/operators; and other establishments that perform 

refrigerant removal, service, or disposal.

 Take enforcement actions against any violation of these regulations.

While these regulations significantly reduce emissions of refrigerants, the current requirements do not 

include specific requirements for substitute refrigerants other than prohibiting venting. To help 

minimize the harm that both ODS and substitute refrigerants have on the environment and to fully 

implement the prohibition on venting, EPA is considering extending the existing requirements under the 

Program to cover substitutes, and revising the rule components associated with leak repair, as well as
2 August 26, 2015

recordkeeping and reporting, to reduce refrigerant emissions. Further, EPA is considering a new 

requirement to reduce emissions associated with Do-It-Yourself (DIY) motor vehicle air-conditioning 

(MVAC) re-charging where manufacturers must install a self-sealing valve on all small containers to 

prevent the release of refrigerant to the atmosphere. 

The purpose of this report is to document the results of a costs and benefits assessment that was 

conducted to help EPA evaluate the impact of the proposed revisions to Section 608 regulations. 

Further, this report provides information to assist EPA in satisfying its obligations under relevant 

statutes and Executive Orders (EOs), including: EO 12866 Regulatory Planning and Review; the 

Regulatory Flexibility Act (RFA); and the Unfunded Mandates Reform Act (UMRA). 

EO 12866: Regulatory Planning and Review. EO 12866 requires agencies to prepare a Regulatory Impact 

Analysis (RIA) for any “significant regulatory action,” which includes any regulatory action that is likely to 

result in a rule that may:

 Have an annual effect on the economy of $100 million or more or adversely affect in a material way 

the economy, a sector of the economy, productivity, competition, jobs, the environment, public 

health or safety, or State, local, or tribal governments or communities;

 Create a serious inconsistency or otherwise interfere with an action taken or planned by another 

agency;

 Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the 

rights and obligations of recipients thereof; or

 Raise novel legal or policy issues arising out of legal mandates, the President’s priorities, or the 

principles set forth in EO 12866.

UMRA. Under Title II, section 202 of the UMRA, each agency is generally required to prepare a written 

statement for any proposed rulemaking that may result in the expenditure by State, local, and tribal 

governments (SLTG), in the aggregate, or by the private sector, of $100 million or more in any one year. 

The written statement must include an assessment of the anticipated costs and benefits of the Federal 

mandate, a description of the macro-economic effects, and a summary of SLTG concerns and how they 

were addressed. 

RFA. The RFA, as amended by the Small Business Regulatory Enforcement Fairness Act (SBREFA), 

requires federal agencies to consider the effects its regulations may have on small entities, and ensure 

that small entities have a voice in the regulatory development process. Under the RFA, small entities 

include:

 Small businesses, which are defined by size standards established by under the North American 

Industry Classification System (NAICS) and are based on the number of employees or annual 

receipts;

 Small governments, which are defined as the government of a city, county, town, township, village, 

school district, or special district with a population of less than 50,000; and
3 August 26, 2015

 Small organizations, which are defined as any “not-for-profit enterprise which is independently 

owned and operated and is not dominant in its field.”

If it is found that the rule may impose a significant economic impact on a substantial number of small 

entities (SISNOSE), the agency will generally be required to prepare a formal analysis of the potential 

adverse economic impacts on small entities, participate in a Small Business Advocacy Review Panel in 

the proposed rule stage, and prepare a Small Entity Compliance Guide in the final rule stage.

As required by abovementioned EOs and statutory requirements, this report provides a screening 

analysis to assess the potential impacts of the proposed changes to the U.S. economy as a whole, SLTGs, 

children, minority and low-income populations, and small entities. This analysis finds that the proposed 

rulemaking will result in total annual compliance costs of approximately $63 million, and therefore, is 

not considered an economically significant regulatory action as defined in EO 12866. Further, this 

analysis finds that the proposed rulemaking can be presumed to have no SISNOSE.

1.1. Regulatory Context

The following sections provide an overview of the affected industries, current regulations, and proposed 

changes to the current regulations.

1.1.1. Profile of Regulated Community

The proposed updates to the Section 608 regulations apply to a wide variety of industries across the U.S. 

economy. The new leak inspection and updated repair requirements regulate equipment used for 

commercial refrigeration (CR), industrial process refrigeration (IPR), and comfort cooling (CC) containing 

50 or more pounds of refrigerant. This regulated equipment is owned by many industries and business 

sectors, including grocery and specialty food stores, warehouse clubs and supercenters, agricultural and 

crop support services, utilities, food and non-food manufacturing, beverage and ice manufacturing, 

office buildings, hospitals, and others. The reporting and recordkeeping requirements affect these 

business sectors as well as: refrigerant reclaimers; disposal establishments; plumbing, heating, and airconditioning contractors; service establishments; and refrigerant wholesalers. Lastly, the requirements 

for DIY small containers affect manufacturers of those containers, including automotive parts and 

accessories stores and industrial gas manufacturers.

1.1.2. Current Leak Repair Requirements

The current leak repair regulations require that when an owner or operator of a regulated appliance 

discovers that ODS refrigerant is leaking at a rate that would exceed the applicable annual leak rate 

during a 12-month period, the owner or operator must take corrective action to repair the leak. Table 3

below shows the current annual leak rates for each appliance type.
4 August 26, 2015

Table 3. Existing Annual Leak Rates by Appliance Type

Appliance Type Annual Leak Rate

CR 35%

IPR 35%

CC 15%

All other appliances 15%

Appliances classified as CR or IPR with a charge size greater than 50 pounds of ODS refrigerant must be 

repaired within 30 days of discovering a leak that would result in the release of 35% or more of the 

charge over a 12-month period. All other appliances with a charge size greater than 50 pounds of ODS 

refrigerant must be repaired within 30 days of discovering a leak that would result in the release of 15%

or more of the charge over a 12-month period. Alternatively, owners or operators of appliances that 

exceed the annual leak rate may opt to develop a retrofit/retirement plan within 30 days of leak 

discovery and complete actions under that plan within 12 months. The deadlines for repair and 

retrofit/retirement may be extended in some cases such as when the necessary repair parts are 

unavailable, other applicable regulations make a repair within the required timeframe impossible, or an 

industrial process shutdown is required to make necessary repairs. 

IPR equipment owners or operators are also required to verify the success of repairs. Specifically, an 

initial verification test must be completed after any repairs and before the replacement of the 

refrigerant in the system. A follow-up verification test must be conducted within 30 days after the initial 

verification test or of bringing the system back to normal operation. If the initial or follow-up verification 

indicates that the repair was unsuccessful, the owner or operator is required to notify EPA and develop 

a retrofit or retirement plan within 30 days of the failed test. The requirement to retire or retrofit the 

leaking equipment may be avoided if the leak is successfully repaired within the allotted time period, as 

demonstrated by an initial and follow-up verification tests. If the repair requires an industrial process 

shutdown, a 120-day repair period is allowed.

1.1.3. Current Recordkeeping and Reporting Requirements

To facilitate compliance with and enforcement of Section 608 regulations, EPA requires reporting and 

recordkeeping of relevant entities such as owners/operators of regulated equipment and service 

technicians. The recordkeeping requirements and periodic submission of reports occur on an annual, 

biannual, one-time, or occasional basis depending on the nature of the reporting entity and the length 

of time that the entity has been in service. Specific recordkeeping requirements for affected entities 

only cover appliances with ODS refrigerants and include the following: 

 Programs certifying technicians must maintain records on each technician certified through their 

programs and display a copy of EPA’s approval letter at their place of business.
5 August 26, 2015

 Anyone selling or distributing or offering to sell or distribute previously-used or virgin refrigerant 

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

the purchaser is a certified technician (as applicable).

 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 technician certifying programs must maintain records that include, but are not limited to, 

the names and addresses of all individuals taking the tests, the scores of all certification tests 

administered, and the dates and locations of all testing administered.

 Technicians must maintain proof that they are certified.

 Refrigerant reclaimers must maintain records on the quantity of material sent to them for 

reclamation, the amount reclaimed, waste products from the reclamation process, and customer 

and sales records.

 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.

 Anyone servicing appliances normally containing 50 or more pounds of refrigerant must provide 

service invoices to the owner or operator.

 Owners or operators of appliances normally containing 50 or more pounds of refrigerant must keep 

records of the amounts of refrigerant purchased and added to their appliances, as well as service 

records provided by technicians and other reports related to the leak repair requirements (e.g., 

retrofit/retirement plans, full charge calculation).

 Owners or operators of appliances normally containing 50 or more pounds of refrigerant must 

maintain information on purged and destroyed refrigerant. 

 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 equipment testing organizations must submit to EPA within 30 days of the certification of 

a new model line of recycling or recovery equipment the name of the manufacturer and the name 

and/or serial number of the model line.

 Approved technician certification programs that stop providing the certification test must forward 

all records to another program currently approved by EPA, who then must inform EPA of the 

transferred records.
6 August 26, 2015

 Approved technician certification programs that have had their certification revoked must forward 

all records to EPA.

 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 three-year 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 IPR equipment whose appliances fail a verification test and owners of IPR appliances and 

federally-owned CR and CC appliances who wish to receive an extension or exclusion under the leak 

repair requirement are subject to additional reporting and recordkeeping requirements.

1.2. Proposed Regulatory Revisions

EPA is proposing to revise select components of the current regulatory requirements under Section 608, 

including leak repair and recordkeeping and reporting. These changes are further described in the subsections below.

1.2.1. Proposed Changes to the Leak Repair Requirements

EPA is proposing to change the leak repair requirements for CC, CR, and IPR appliances normally 

containing 50 or more pounds of ODS refrigerant. Specifically, EPA is proposing to:

 Extend the existing requirements to CC, CR, and IPR appliances containing 50 or more pounds of HFC 

and other substitute refrigerant, excluding those that are exempt from the venting prohibition (e.g., 

CO2, ammonia)2.

 Lower the annual leak rates from 35% to 20% for IPR and CR appliances containing 50 or more

pounds of ODS, HFC, or other non-exempt substitute refrigerant.

 Lower the annual leak rates from 15% to 10% for CC appliances containing 50 or more pounds of 

ODS, HFC, or other non-exempt substitute refrigerant.

 Require quarterly leak inspections for CR and IPR appliances containing 500 or more pounds of ODS,

HFC, or other non-exempt substitute refrigerant (unless automatic leak detection equipment is 

installed and certified every year).

 Require annual leak inspections for all CC appliances, plus CR and IPR appliances containing between 

50-500 pounds of ODS, HFC, or other substitute refrigerant (unless automatic leak detection 

equipment is installed and certified every year).

 

2

 EPA is using the term “non-exempt substitute” to refer to substitute refrigerants that have not been exempted from the 

venting prohibition under CAA section 608(c)(2) and 40 CFR 82.154(a).
7 August 26, 2015

 Establish a leak limit where an appliance is prohibited from leaking more than 75% of its full charge 

in two consecutive years (e.g., a facility leaks 80% in one year, and 76% the following year).

 Require initial and follow-up verification tests for all appliances (i.e., IPR, CR, and CC equipment) 

when the applicable leak rate is exceeded.

 Require a leak inspection to identify leaks upon discovering that the applicable leak rate is 

exceeded;

 Require that all identified leaks are repaired when the applicable leak rate is exceeded rather than 

just bringing the leak rate down below the annual leak rate threshold.

 Allow leak repair extension requests for all appliances, including non-federal CR and CC systems.

 Explicitly allowing (and even encouraging) electronic instead of paper records.

1.2.2. Proposed Changes to the Recordkeeping and Reporting Requirements

EPA is proposing to change the recordkeeping and reporting requirements for 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. Specifically, 

EPA is proposing to: 

 Extend the current recordkeeping and reporting requirements to appliances containing HFCs and 

other non-exempt substitutes.

 Allow owners/operators of all CC and CR appliances containing 50 or more pounds of ODS 

refrigerant to prepare and submit requests for extensions to the leak repair and retrofit/retire 

timeline (currently limited to IPR and federally-owned CC and CR appliances).

 Allow owners/operators of all CC, CR, and IPR appliances containing 50 or more pounds of HFC or 

other substitute equipment to prepare and submit requests for extensions to the leak repair and 

retrofit/retire timeline.

 Require persons servicing ODS, HFC, and other non-exempt substitute refrigerant-containing

appliances with charge sizes of 50 or more pounds to provide records of the following for each 

refrigerant addition: the identity and location of the appliance, the date and type of service 

performed, the quantity and type of refrigerant added, the full charge of the system, and the leak 

rate.

 Require owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing

appliances with charge sizes of 50 or more pounds to maintain records of the following for each 

refrigerant addition: the identity and location of the appliance, the date and type of service 

performed, the quantity and type of refrigerant added, the full charge of the system, and the leak 

rate.
8 August 26, 2015

 Require owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing

appliances with charge sizes of 50 or more pounds to maintain reports on the results of verification 

tests and leak inspections any time the leak rate threshold is exceeded.

 Require owners/operators of ODS, HFC, and other non-exempt substitute refrigerant-containing

appliances with charge sizes of 50 or more pounds to maintain records of quarterly and annual 

inspections.

 Require technicians disposing of field-installed appliances with charge sizes between 5 and 50 

pounds of ODS, HFC, and other non-exempt substitute refrigerant to maintain records on the 

quantity and type of refrigerant recovered at disposal and the quantity and type of refrigerant 

transferred for reclamation or destruction, as well as the company name and date.

 Require approved technician certifying programs to publish online lists or databases documenting 

who they have certified and what type of certification each individual has received. The regulation 

would only require prospective lists of who is certified, not a compilation of everyone who was 

certified previously.

 Require manufacturers of small cans of automotive refrigerant to keep records of test data and log 

forms that demonstrate compliance with the allowable leakage rate.

EPA is also proposing to remove the requirement for persons who maintain, service, repair, or dispose 

of appliances containing ODS refrigerants to submit a signed statement that they own certified recovery 

and recycling equipment.

1.2.3. Other Proposed Regulatory Revisions

EPA is also proposing to change other regulatory requirements. Specifically, EPA is proposing to: 

 Extend the sales restriction to HFCs and other non-exempt substitutes to ensure proper handling of 

ODS substitutes.

 Exempt small cans of HFC refrigerant that are typically used for DIY aftermarket servicing of MVACs 

from the sales restriction.

 Require self-sealing valves on small cans of substitute (currently HFC-134a) refrigerant to minimize 

emissions from DIY servicing.

 Extend all other the regulatory requirements found at 40 CFR part 82, subpart F, including technician 

certification, appliance disposal, refrigerant reclamation, service practices, and the requirement to 

recover refrigerant to HFCs and other non-exempt substitutes.

 Require substitute-containing recycling/recovery equipment to be certified. 

1.3. Organization of This Report

The remainder of this report is organized as follows: 
9 August 26, 2015

 Section 2 characterizes the equipment regulated under Section 608 and identifies affected 

businesses within each sector.

 Section 3 presents the general approach and assumptions used to estimate aggregate annual costs 

to the U.S. economy, economic impacts on small entities, and benefits associated with the proposed 

changes.

 Section 4 summarizes the results of the aggregate economic impact analysis.

 Section 5 summarizes the economic impact on small entities, including the SISNOSE determination.

 Section 6 discusses the relevant statutes and EOs that EPA must satisfy.

 Section 7 summarizes the results of the analysis.
10 August 26, 2015

2. Industry Characterization

The Agency’s proposed changes to the Section 608 regulations—including requirements for leak 

inspection and repair, recordkeeping and reporting, and self-sealing valves for small cans—will affect a 

range of businesses and industries. This section identifies the industries that may be affected using 

North American Industry Classification System (NAICS) codes. NAICS codes are industry classifications 

that the U.S. Census Bureau uses to track the number of businesses and relevant information about 

those businesses, including their distribution by employment size and sales receipts. 

2.1. Affected Industry for Leak Inspection and Repair Requirements

2.1.1. Equipment Characterization

The proposed changes to the requirements for leak inspection and repair will generally affect owners 

and operators of CR, IPR, and CC appliances with a full charge size of 50 pounds or more of ODS or HFC 

refrigerant.3These equipment types include:

 Commercial refrigeration systems are the refrigeration appliances used in the retail food and cold 

storage warehouse sectors. Retail food includes the refrigeration equipment found in supermarkets, 

convenience stores, restaurants, and other food service establishments. All cold storage systems 

generally have charge sizes over 50 pounds and include the equipment used to store meat, produce, 

dairy products, and other perishable goods. 

 Industrial Process Refrigeration systems are complex, customized systems used in the chemical, 

pharmaceutical, petrochemical, and manufacturing industries. These systems are directly linked to 

the industrial process. This sector also includes industrial ice machines, appliances used directly in 

the generation of electricity, and ice rinks.

 Comfort Cooling includes stationary refrigeration equipment that provides cooling in order to 

control heat and/or humidity in facilities, such as office buildings and light commercial buildings. 

Comfort cooling appliances include building chillers and roof-top self-contained units. They may be 

used for the comfort of occupants or for climate control to protect equipment within a facility, such 

as in computer rooms. 

Table 4 presents the characterization of equipment by sector, type, size, and refrigerant used (ODS or 

HFC). Assumptions are derived from data and analysis based on EPA’s Vintaging Model (see Box 2; EPA 

2014) and on facility-level reporting from California’s High-Global Warming Potential Stationary Source 

Refrigerant Management Program (RMP) (see Box 1), as described below. 

 

3

Full charge size is defined as the quantity of refrigerant needed for normal equipment operation.
11 August 26, 2015

Box 2: California’s Refrigerant Management Program (RMP)

CARB adopted the RMP in 2009 as a part of the state’s Global Warming 

Solutions Act of 2006 (AB 32). The purpose of the RMP is to reduce 

emissions of high-GWP refrigerants from stationary, non-residential 

refrigeration equipment and from the installation and servicing of 

stationary refrigeration and air-conditioning appliances using highGWP refrigerants. Effective January 1, 2011, facilities with refrigeration 

systems containing more than 50 pounds of refrigerant must conduct 

periodic leak inspections, promptly repair leaks, and keep onsite 

records. Beginning January 1, 2012, facilities with systems containing 

more than or equal to 200 pounds must report annually through 

CARB’s online reporting tool on leak inspections, repairs, and 

purchases of high-GWP refrigerants (CARB 2010a).

This analysis uses data reported to CARB under the RMP for the 2013 

calendar year. The data include annual reports for facilities with 

refrigeration systems containing a full charge greater than or equal to 

200 pounds. Although reporting is not required for refrigeration 

systems containing a full charge between 50 and 200 pounds, some 

facilities have chosen to track leak inspections and maintenance 

records for these systems through CARB’s online reporting tool as well. 

For the 2013 calendar year, approximately 600, 42,000, and 4,600 leak 

event records were reported for small, medium, and large 

refrigeration systems, respectively (CARB 2014). 

While this analysis largely relies on 2013 RMP data, these data have 

been reviewed against other sources, including information from 

California’s South Coast Air Quality Management District (SCAQMD) 

Rule 1415 and EPA’s Vintaging Model, to ensure that assumptions 

made are representative of the United States as a whole. 

Box 1: EPA’s Vintaging Model

EPA’s Vintaging Model estimates the annual chemical emissions from 

industry sectors that have historically used ODS, including AC, 

refrigeration, foams, solvents, aerosols, and fire protection. Within 

these industry sectors, there are over 60 independently modeled enduses. The model uses information on the market size and growth for 

each end-use, as well as a history and projections of the market 

transition from ODS to alternatives. As ODS are phased out, a 

percentage of the market share originally filled by the ODS is allocated 

to each of its substitutes, including HFCs. The model tracks emissions 

of annual “vintages” of new equipment that enter into operation by 

incorporating information on estimates of the quantity of equipment 

or products sold, serviced, and retired or retrofitted each year, and 

the quantity of the compound required to manufacture, charge, 

and/or maintain the equipment. EPA’s Vintaging Model uses this 

market information to build an annual inventory of in-use stocks of 

equipment and the ODS and non-ODS substitutes in each end-use. The 

model is updated on a regular basis to reflect changes in the market 

and new industry information.

Equipment type and size. This analysis 

classifies equipment into four size 

categories based on refrigerant charges: 

small (containing between 50 and 199 

pounds of refrigerant), medium <500 

pounds (containing between 200 and 499 

pounds of refrigerant), medium ≥500 

pounds (containing between 500 and 

2,000 pounds of refrigerant), and large 

(containing greater than 2,000 pounds of 

refrigerant). These size categories are 

similar to those used by the California Air 

Resources Board (CARB) in their 2009 

analysis of the RMP (CARB 2009a; see also 

Box 1) but adjusted to correspond with 

distinctions in the Agency’s proposed 

regulatory changes. For example, 

quarterly reporting is proposed for CR and 

IPR equipment with refrigerant charges of 

≥500 pounds, thus, a distinction is made 

between medium-sized equipment with 

charge sizes above and below the 500 

pounds threshold. Assumptions about the 

average charge size by equipment sector 

and type and the percentage of systems 

by type and sector were developed based 

on analysis of facility-level reporting under 

California’s RMP.

4

Equipment type is not a reporting 

requirement of California’s RMP. 

Therefore, although this analysis relies on 

facility-level data reported under the 

California RMP, additional analysis and 

assumptions were applied to these data 

regarding refrigerant use, size, and 

industry characterizations (outlined in 

Section 2.1.2). The additional analysis was 

 

4

EPA’s Vintaging Model does not disaggregate all equipment types by size. Thus, facility-level reporting under California’s RMP 

informed assumptions about charge sizes and equipment distributions by size and type.
12 August 26, 2015

used to group reported equipment into the equipment sectors, types, and industries affected by the 

proposed regulatory changes and to determine the universe of affected equipment by the proposed 

regulatory changes. Box 3 in Section 2.1.2 farther below illustrates this approach.

Refrigerant distribution. EPA’s Vintaging Model is the basis for assumptions on the distribution of 

refrigerant (i.e., ODS and HFC) by equipment sector and type.5

Table 4: Equipment Characterization by Sector, Type, Size, and Refrigerant Type

Equipment 

Sector

Equipment 

Type

Equipment 

Size

Refrigerant 

Type

Typical Charge 

Sizes (lbs)

Percentage of 

Systems in Sector

Distribution of 

Refrigerants by Typea

CC Unitary AC Small ODS 114 28% 59%

HFC 115 2% 41%

Chiller Medium ODS 780 60% 62%

HFC 651 8% 38%

Chiller Large ODS 7,659 1% 62%

HFC 5,118 2% 38%

CR Condensing 

Unit

Small ODS 110 1% 41%

HFC 97 9% 59%

Rack Medium 

<500 lbs

ODS 335 8% 51%

HFC 370 19% 49%

Rack Medium 

≥500 lbs

ODS 961 20% 51%

HFC 930 33% 49%

Rack Large ODS 2,501 1% 51%

HFC 2,486 1% 49%

Cold Storage Medium 

<500 lbs

ODS 320 2% 57%

HFC 315 1% 43%

Cold Storage Medium 

≥500 lbs

ODS 1,110 2% 57%

HFC 1,061 1% 43%

Cold Storage Large ODS 7,368 2% 57%

HFC 5,882 0% 43%

IPR IPR Small ODS 70 5% 47%

HFC 86 22% 53%

Medium 

<500 lbs

ODS 322 16% 47%

HFC 306 8% 53%

 

5

To explore the sensitivity of the results to the ODS/HFC refrigerant distribution used, Appendix A.1 shows the results of this 

analysis using a distribution based on data reported under California’s RMP.
13 August 26, 2015

Equipment 

Sector

Equipment 

Type

Equipment 

Size

Refrigerant 

Type

Typical Charge 

Sizes (lbs)

Percentage of 

Systems in Sector

Distribution of 

Refrigerants by Typea

Medium 

≥500 lbs

ODS 1,049 25% 47%

HFC 1,038 3% 53%

Large ODS 5,592 13% 47%

HFC 5,062 8% 53%

Totals may not sum due to independent rounding.

Source: EPA 2014; CARB 2009a

a

EPA’s Vintaging Model does not disaggregate all equipment types by size. Therefore, the same ODS/HFC distributions are 

applied across all size categories for some equipment types.

Table 5 and Table 6 below present the specific ODS and HFC refrigerants and charge size categories, 

respectively, that are most commonly used in the equipment types and sectors affected by this 

proposed rulemaking. Typical refrigerants used by each equipment type were identified using CARB 

(2009) and EPA’s Vintaging Model.6

Table 5: Typical Refrigerants Used by Equipment Type

Equipment Sector Equipment Type

ODS HFC

123 22 402A 408A 134a 404A 407A 507

CC Centrifugal Chillers X X X

Packaged Chillers X X X

Unitary AC X

CR Centralized Systems 

(DX, parallel rack)

X X X X X X

Condensing Units X X X

Cold Storage X X X X X X

IPR Process Cooling X X X

Source: EPA 2014; CARB 2009a

Table 6: Typical Charge Size Categories by Equipment Type

Sector CARB Equipment 

Characterization

Small

(50-200 lbs)

Medium

(200-2,000 lbs)

Large

(2,000 lbs and above)

CC Chillers X X

Unitary AC X

CR Condensing Units X

 

6

This analysis considers eight of the 32 refrigerants self-reported under California’s RMP (i.e., ODS refrigerants and blends: R123, R-22, R-402A, and R-408A and HFC refrigerants and blends: R-134a, R-404A, R-407A, and R-507). These eight refrigerants 

account for 97% of the equipment reported under the RMP in 2013. Although Table 5 indicates the most commonly used 

refrigerants by equipment type, there are instances where systems reported using less common refrigerants. 
14 August 26, 2015

Rack X X

Cold Storage X X

IPR Process Cooling X X X

Source: EPA 2014; CARB 2009a

Only equipment that experience leaks that exceed the proposed leak thresholds will be subject to repair 

requirements; however, all equipment containing 50 or more pounds of ODS or non-exempt substitute 

refrigerant will be subject to the leak inspection requirements and thus incur compliance costs. These 

assumptions are further elaborated in Section 3.1.1. 

2.1.2. Industry Characterization

The affected businesses (by NAICS code) were identified from an analysis conducted by CARB (2009) on 

California’s RMP, a similar analysis of proposed leak repair requirements (Stratus 2009), an earlier RIA 

on this issue (ICF 1997), an analysis of data reported under California’s RMP for 2013 (which includes 

self-assigned NAICS codes from 3,565 facilities), the Program’s 2015 supporting ICR (EPA ICR Number: 

1626.13, OMB Control Number: 2060-0256) (EPA 2015b), and expert judgment. 

The affected businesses were grouped into 17 broader industry categories based on industry similarities 

(e.g., different types of non-food manufacturing, or different types of businesses that may have office 

buildings), as well as expert judgment on grouping the affected businesses by the types of equipment 

they are likely to use per facility. Table 7 below presents the list of affected industry sectors, NAICS 

codes, and NAICS code definitions. 

Table 7: Industry Sector, NAICS Code, and Definition

Industry Sector Category NAICS Codesa,bNAICS Code Definition

Agriculture and Crop Support Services 115 Support Activities for Agriculture and Forestry

Arts, Entertainment, and Recreation 71 Arts, Entertainment, and Recreation

Beverage and Ice Manufacturing 312 Beverage Manufacturing

Durable Goods Wholesalers and 

Dealers

423 Merchant Wholesalers - Durable Goods

441 Motor Vehicle and Parts Dealers

Educational Services 611 Educational Services

Food Manufacturing 311 Food Manufacturing

General Merchandise Stores 452 General Merchandise Stores

453998 All Other Miscellaneous Store Retailers (except 

Tobacco Stores) 

Grocery and Specialty Food Stores 4451 Grocery Stores
15 August 26, 2015

Industry Sector Category NAICS Codesa,bNAICS Code Definition

4452 Specialty Food Stores

72231 Food Service Contractors

Hospitals 622 Hospitals

Non-durable Goods Wholesalers and 

Dealers

424 Merchant Wholesalers – Non-durable Goods

Non-food Manufacturing 322 Paper Manufacturing

323 Printing and Related Support Activities

324 Petroleum Manufacturing

325 Chemical Manufacturing

3254 Pharmaceutical Manufacturing

326 Plastics and Rubber Manufacturing

332 Metals Manufacturing

333 Machinery Manufacturing

334 Computer and Electronic Product Manufacturing

336 Transportation Equipment Manufacturing

3391 Medical Equipment and Supplies Manufacturing

339999 Miscellaneous Manufacturing 

Office Buildings 511 Publishing Industries (except Internet)

512 Motion Picture and Video Industries

515 Broadcasting

517 Telecommunications

518 Data Processing, Hosting, and Related Services

519 Libraries and Archives

522 Credit Intermediation and Related Activities

524 Insurance Carriers

531 Real Estate

541 Professional, Scientific, and Technical Services

551 Management of Companies and Enterprises

561 Administrative and Support Services
16 August 26, 2015

Industry Sector Category NAICS Codesa,bNAICS Code Definition

712 Museums, Historical Sites, and Similar Institutions

721 Accommodation

813 Religious, Grantmaking, Civic, Professional, and Similar 

Organizations

Other Warehousing, Storage, and 

Transportation

48 Transportation and Warehousing

4931 Warehousing and Storage

Refrigerated Warehousing and Storage 49312 Refrigerated Warehousing and Storage

Research and Development 5417 Research and Development

Utilities 211 Oil and Gas Extraction

221 Utilities

Warehouse Clubs and Supercenters 452910 Warehouse Clubs and Supercenters 

Source: U.S. Census Bureau 2012

a

The NAICS codes range from the broadest classification, the two digit NAICS code, to the most narrow, six digit level NAICS code,

with each progressive digit specifying a further level of detail. The first two digits distinguish the economic sector, the third digit 

distinguishes the subsector, the fourth digit distinguishes the industry group, the fifth digit distinguishes the NAICS industry, and 

the sixth digit distinguishes the national industry (U.S. Census Bureau 2015). 

b

In several cases where a broader NAICS designation is listed (e.g., two digit code), not all national industries (i.e., six digit codes) 

were considered applicable to this analysis. A full list of NAICS codes, disaggregated to the degree of detail used in the analysis is 

available in Appendix E.1.

Economic data for each affected industry—including number of firms and establishments7by 

employment or receipts size—was obtained from the U.S. Census Bureau’s Industry Statistics Portal 

(http://www.census.gov/econ/isp/) and includes the latest employment and receipt data from the U.S. 

Census Bureau 2012 County Business Patterns and the 2007 Economic Census, respectively (U.S. Census 

Bureau 2012; U.S. Census Bureau 2007). The economic census profiles U.S. national and local 

economies every five years, and the 2007 data is the latest available at the time of this writing.

Table 8 below presents the total number of establishments (facilities) and firms (businesses), as well as 

small businesses and associated facilities, by industry category. Small businesses were identified using 

the U.S. Small Business Administration’s table of small business size standards matched to affected 

NAICS codes. The version employed for this analysis became effective July 14, 2014 (U.S. Small Business 

Administration 2014).

 

7

The U.S. Census Bureau defines an establishment as a single physical location where business is conducted or where services 

or industrial operations are performed; a firm is a business organization consisting of one or more domestic establishments in 

the same state and industry that were specified under common ownership or control. The firm and the establishment are the 

same for single-establishment firms. For each multi-establishment firm, establishments in the same industry within a state are 

counted as one firm, and the firm employment and annual payroll are summed from the associated establishments.
17 August 26, 2015

Table 8: Total Businesses and Facilities by Industry Category

Industry Category

All Businesses Small Businesses

Facilities Businesses Facilities Businesses

Agriculture & Crop Support Services 3,588 3,296 3,189 3,151 

Arts, Entertainment, and Recreation 32,288 27,322 28,897 26,891

Beverage & Ice Manufacturing 4,712 4,135 4,134 4,052

Durable Goods 128,858 92,362 99,926 90,802

Educational Services 26,641 21,691 21,315 19,888

Food Manufacturing 25,798 22,293 22,533 21,319

General Merchandise Stores 55,428 20,412 24,839 20,044

Grocery & Specialty Food Stores 105,342 56,740 60,013 55,807

Hospitals 5,281 2,904 1,533 1,363

Non-durable Goods 52,363 40,256 39,061 37,576

Non-food Manufacturing 58,313 51,923 54,713 50,815

Office Buildings 2,258,830 1,910,880 1,998,350 1,874,025

Other Warehousing, Storage, and 

Transportation 67,627 53,145 53,582 50,312

Refrigerated Warehousing & Storage 1,158 628 638 503

Research and Development 15,501 12,359 12,426 11,660

Utilities 25,553 12,781 21,036 12,433

Warehouse Clubs & Supercenters 5,164 32 84 26

Total 2,872,445 2,333,159 2,446,270 2,280,667 

Sources: U.S. Small Business Administration 2014; U.S. Census Bureau 2012; U.S. Census Bureau 2007

CR and IPR appliances in facilities located in California are already subject to similar leak inspection and 

repair requirements under the California RMP. Thus, California facilities using those equipment types 

were removed from the total facilities and businesses considered when model facility assumptions were 

scaled up to determine total affected equipment for this analysis. California facilities using CC appliances 

with refrigerant charges of 50 or more pounds were still included, as those systems are not already 

subject to similar requirements. 

To estimate aggregate costs and benefits across the entire U.S. economy, as well as costs per small 

business for the RFA/SBREFA screening analysis, assumptions were needed about the percentage of 

each industry category affected by the proposed regulatory changes (i.e., the proportion of facilities that 

would have appliances with refrigerant charges 50 or more pounds) and the type and number of 

equipment per affected facility and business.
18 August 26, 2015

Table 9 summarizes the assumptions made regarding the average number of systems in each sector per 

facility, for each industry category. These assumptions were based on analysis of 2013 data reported 

under California’s RMP, cross-walked with assumptions made by similar analyses (CARB 2009a; Stratus 

2009) about equipment use by industry, and reconciled with expert judgment. Table 9 also presents 

assumptions about the percentage of each industry that is assumed to use equipment containing 50 or 

more pounds of ODS or HFC refrigerant, and thus be affected by leak inspection and repair provisions of 

the proposed rulemaking.

 Comfort Cooling—approximately 6% of commercial buildings (including offices, hospitals, and 

schools) are estimated to contain AC systems with a charge size of 50 or more pounds, based on 

data reported under the Commercial Building Energy Consumption Survey (as reviewed in Stratus 

2009).

 Commercial Refrigeration—all industries assumed to use commercial refrigeration equipment use 

equipment that contains 50 or more pounds of refrigerant. Industries that only use smaller 

commercial refrigeration equipment (e.g., stand-alone systems, beverage coolers, vending 

machines) are not considered in the commercial refrigeration equipment categorization. 

 Industrial Process Refrigeration—IPR are very large systems that contain 50 or more pounds of 

refrigerant. 

Table 9: Percentage of Industry Containing Appliances with 50 or More Pounds of ODS or HFC 

Refrigerant, and Average Number of Systems per Facility

Industry Category Percentage of 

Industry Affected

Average Systems per 

Facility

CC CR IPR

Agriculture and Crop Support Services 100% 1 2 -

Arts, Entertainment, and Recreation 1 - -

Non-ice Rinks 6% 1 - -

Ice Rinks 2% 1 - 2

Beverage and Ice Manufacturing 100% 1 - 1

Durable Goods Wholesalers and Dealers 100% 2 - -

Educational Services 6% 4 1 -

Food Manufacturing 100% 1 2 -

General Merchandise Stores

Department Stores, Etc. 6% 1 - -

Stores with Grocery Departments 10% 1 2 -

Grocery and Specialty Food Stores 100% 1 2 -

Hospitals 6% 2 - -

Non-durable Goods Wholesalers and Dealers 100% 1 2 -
19 August 26, 2015

Box 3: Industry and Equipment Characterization Approach for the Agricultural and Crop Support Services Industry

Information regarding refrigerant use (Table 5), typical sizes per equipment type (Table 6), and equipment sectors used per 

industry (Table 9) were triangulated to define model equipment and facilities for the purposes of this analysis. For example, 

the Agriculture and Crop Support Services industry is assumed to use both CC and CR appliances. Facility reports under the 

RMP show equipment in this industry containing R-123, R-22, R-134a, R-404A, R-407A, and R-507. It can be reasonably 

assumed that all systems using R-404A, R-407A, and R-507 are commercial refrigeration systems, as these refrigerants are 

typically used only in the commercial refrigeration sector, regardless of equipment size. The Agriculture and Crop industry is 

also assumed to use cold storage equipment in the commercial refrigeration sector, which falls in the medium and large size 

categories and typically uses R-22, but not R-123 or R-134a. Therefore the reported medium and large R-22 systems are 

assumed to be commercial refrigeration systems, and the remaining R-123, R-134a, and small R-22 systems are assumed to 

be for comfort cooling, with small systems likely being unitary AC and medium and large systems likely being chillers. This 

type of reasoning process was applied for each of the broad industry categories to define the distribution of equipment 

types per industry, as shown in the table below.

Industry

Average Systems and Equipment Types per Facility

CC Unitary 

AC

Chiller 

(M)

Chiller 

(L) CR Cond. Unit

Rack 

(M)

Rack 

(L)

Cold 

Storage 

(M)

Cold 

Storage 

(M)

IPR

Ag. and Crop 

Support Services 1 74% 22% 4% 2 5% 0% 0% 78% 17% -

Industry Category Percentage of 

Industry Affected

Average Systems per 

Facility

Non-food Manufacturing 100% 2 - 3

Office Buildings 6% 3 - -

Other Warehousing, Storage, and Transportation 6% 4 - -

Refrigerated Warehousing and Storage 100% 1 2 -

Research and Development 6% 2 - -

Utilities 6% 2 - -

Warehouse Clubs and Supercenters 100% 1 3 -

In Box 3 below, the Agricultural and Crop Support Services industry is used to illustrate how the 

assumptions described in Sections 2.1.1 and 2.1.2 were applied to characterize the industries and 

equipment affected by the proposed leak inspection and repair regulatory changes. 

To estimate the universe of potentially affected equipment by sector, the number of facilities per 

industry in the United States (shown in Table 8) was multiplied by the percentage of affected industries 

and the assumed pieces of equipment per facilities (as shown in Table 9). Total equipment per sector 

was then disaggregated by equipment type, size, and refrigerant based on the assumptions shown in 

Table 4 (Section 2.1.1).

As shown in Table 10, there are approximately 1.5 million CC, CR, and IPR systems potentially affected 

by the proposed regulatory changes. 53% of these appliances contain ODS refrigerants, and 47% contain 
20 August 26, 2015

HFCs. These systems contain over 900 million pounds of refrigerant, with a GWP-weighted value of over 

850 MMTCO2eq.

Table 10: Universe of Affected Equipment

Refrigerant Type

Affected Equipment

CC CR IPR Total

ODS 578,181 156,981 79,961 815,123

HFC 440,511 211,584 75,276 727,371

Total 1,018,692 368,565 155,237 1,542,494

2.2. Affected Industry for Recordkeeping and Reporting Requirements

In addition to owners and operators of CC, CR, and IPR equipment (described in the previous section), 

there are six main industries expected to be affected by the changes to the recordkeeping and reporting 

requirements: (1) refrigerant reclaimers; (2) refrigerant wholesalers; (3) service technicians; (4) small 

can manufacturers; (5) disposal establishments; and (6) service establishments.

8

The NAICS codes for 

these industry categories were identified using the Program’s 2015 supporting ICR (EPA ICR Number: 

1626.13, OMB Control Number: 2060-0256), as well as company research and expert judgment. Sales 

and employment data for all affected industries was collected from U.S. Census Bureau’s Economic 

Census and ReferenceUSA Online Database (U.S. Census Bureau 2007; U.S. Census Bureau 2012;

Infogroup Inc n.d.). The small business thresholds for the NAICS codes were used in determining the 

number of small businesses affected by the proposed recordkeeping and reporting requirements.

The number of affected businesses in the following industry categories was assumed to be equivalent to 

those in the Program’s 2015 ICR Supporting Statement: reclaimers, refrigerant wholesalers, service 

technicians, disposal establishments, and service establishments (EPA 2015b). The total number of 

affected businesses in each of these industries was proportioned across: 1) the affected NAICS codes 

within that industry and 2) business size category (based on either enterprise receipt or employment 

size, depending on the specific SBA threshold for each NAICS code). This proportioning yielded the 

estimated number of affected small businesses, by NAICS code and business size.9,10

 

8

Disposal and service establishments are expected to experience compliance cost relief due to EPA’s proposal to remove the 

requirement for persons who maintain, service, repair, or dispose of appliances containing ODS refrigerants to submit a 

signed statement that they own certified recovery and recycling equipment.

9

This approach was modified for EPA certified reclaimers since four reclaimer entities are known to be in the Industrial Gas 

Manufacturing (NAICS code 325120) industry category, including Arkema, Dow Chemical Company, Honeywell, and National 

Refrigerants. Instead of proportioning these four entities across business size category, data from ReferenceUSA Online 

Database on number of employees and annual sales was used to determine economic impacts to small businesses. The 

proportioning method described above was applied to the remaining 57 certified reclaimer entities.
21 August 26, 2015

Table 11 below shows the total number of entities and small entities affected by industry category and 

NAICS code. 

Table 11. Total Number of Small Entities Affected by Industry Category and NAICS Code

Industry Category NAICS 

Code NAICS Code Definition

Total 

Entities 

(Affected)a

Small 

Entities 

(Affected)

Industries Experiencing Annual Compliance Costs

Reclaimers 325120 Industrial Gas Manufacturing 4 1

423930 Recyclable Material Merchant Wholesalers 27 26

562920 Materials Recovery Facilities 4 3

562212 Solid Waste Landfill 3 2

424690 Other Chemical and Allied Products Merchant Wholesalers 23 22

Refrigerant 

Wholesalers

325120 Industrial Gas Manufacturing 52 52 

424690 Other Chemical and Allied Products Merchant Wholesalers 3,930 3,700 

42 Wholesale Trade 196,018 189,364 

Service Technicians 238220 Plumbing, Heating, and Air-conditioning Contractors 300,000 295,592 

Small Can 

Manufacturers

441310 Automotive Parts and Accessories Stores 5 2

325120 Industrial Gas Manufacturing 5 3

Sub-Total 500,071 488,767

Industries Experiencing Avoided Compliance Costs

Disposal 

Establishments

562920 Materials Recovery Facilities 35 32

562212 Solid Waste Landfill 25 24

423990 Other Miscellaneous Durable Goods Merchant 

Wholesalers

315 289

Service 

Establishments

811310 Commercial Industrial Machinery and Equipment (not 

Automotive and Electronic) Repair and Maintenance

1,872 1,800 

811412 Appliance Repair and Maintenance 378 376

Sub-Total 2,625 2,521 

Total 502,696 491,288

 

10 This approach was similarly modified for small can manufacturers. Instead of proportioning these five entities across business 

size category, data from ReferenceUSA Online Database on number of employees and annual sales was used to determine 

economic impacts to small businesses.
22 August 26, 2015

a

The estimated number of firms in each industry category (i.e., reclaimers, refrigerant wholesalers, and service technicians) 

were distributed on a weighted basis across the affected NAICS codes, where the weighting was based on the number of 

firms in each NAICS code. This approach was slightly modified for EPA certified reclaimers and small can manufacturers, 

since the NAICs codes of some specific entities were known.

2.3. Affected Industry for Self-sealing Valves on DIY Small Cans

To identify small can manufacturers potentially affected by the DIY self-sealing valve requirements, an 

internet search was combined with industry input from the Auto Care Association and the Automotive 

Refrigerant Products Institute (ARPI). Ten manufacturers were identified. This analysis assumes that all 

small can manufacturers can be categorized into the following NAICS codes: 441310 Automotive Parts 

and Accessories Stores and 325120 Industrial Gas Manufacturing. 

Information on number of employees and annual sales volume was collected for each of the affected

entities from ReferenceUSA Online Database (Infogroup Inc n.d.). Then, based on company research and 

expert judgement, each entity was assigned a NAICS code (i.e., either 441310 or 325120). Small business 

standards established by the SBA were then used to assess whether an entity is considered small. For 

NAICS code 441310, small entities are determined based on annual sales volume, where entities with an 

annual sales volume of less than $15 million are categorized as small (SBA 2014). For NAICS code 

325120, small entities are determined based on total number of employees, where entities with less 

than 1,000 employees are categorized as small (SBA 2014). Using the SBA size standards, it was 

estimated that five of the affected entities are small businesses.

Table 12 below outlines the number of entities and small businesses by industry category. 

Table 12: Industry Characterization for Small Can Manufacturers Affected by Proposed Rule

Industry Category NAICS 

Code NAICS Code Definition Total Entities Affected

Total Small 

Entities

Small Can Manufacturers 441310 Automotive Parts and Accessories Stores 5 2

325120 Industrial Gas Manufacturing 5 3
23 August 26, 2015

3. Methodology

This section presents the methodology used to estimate the incremental impact of the proposed 

regulatory changes on the U.S. economy as a whole and on small businesses individually (for the 

RFA/SBREFA screening analysis). The impact of EPA’s proposed changes includes compliance costs

(including avoided compliance costs because of the proposed removal of regulatory requirements and 

provision of additional flexibility measures), refrigerant savings (associated with reduced refrigerant 

use), and emission reduction benefits.

The analysis uses a model entity approach to estimate these impacts. The model entity approach is built 

up from a model facility analysis, which was developed based on assumptions about model equipment.

 Model equipment. First, the compliance costs, avoided compliance costs (i.e., compliance costs no 

longer incurred), refrigerant savings, and benefits associated with the proposed regulatory 

requirements (i.e., leak inspection and repair, and recordkeeping and reporting) were estimated for 

each type of affected equipment.

 Model facility. Next, based on the compliance costs and benefits per affected equipment, costs and 

benefits were estimated for a model facility in each of the industry categories described in Section 2. 

Assumptions about the number and type of equipment used per model facility varied based on the 

industry category. Assumptions about the proportion of equipment affected per industry were 

incorporated, based on equipment type and size, refrigerant type, and leak rate distributions.

For the analysis of the aggregate impact on the U.S. economy, the model entity step was bypassed 

by multiplying the costs and benefits per model facility by the number of affected facilities. These 

scaling assumptions varied based on the industry category. Because CR and IPR equipment in 

facilities located in California are already subject to requirements that are generally more stringent 

than those in the proposed rule, costs and benefits were not included for these equipment/facilities. 

 Model entity. For the RFA/SBREFA screening analysis, costs per model facility were scaled to a 

model entity on both an industry-specific and size-specific basis. Therefore, each model entity 

reflected information about the average number of facilities an entity has in a given industry 

category and size (i.e., smaller entities typically have fewer facilities per entity than larger 

businesses).

All costs and benefits were estimated on an annual basis, based on assumptions about the current 

distribution of affected ODS- and substitute-containing equipment. An analysis of future benefits in 

2020 and 2025 was also conducted, as described in 3.3.1.2. All costs are shown in 2014 dollars.

As noted previously, the proposed rule updates and extends the existing requirements to non-ozonedepleting substitute refrigerants. The main class of refrigerant affected by this proposed extension is 

HFCs since many other refrigerants currently in use are exempted from the venting prohibition. As such, 

this analysis estimates the incremental costs and benefits associated with the application of the 

proposed regulatory changes to ODS and HFC equipment.
24 August 26, 2015

The remainder of this chapter is organized as follows:

 Section 3.1 describes the approach for estimating the aggregate cost to the U.S. economy.

 Section 3.2 presents the methodology for estimating the impact on small businesses.

 Section 3.3 provides the benefits estimation approach.

3.1. Approach for Estimating Aggregate Annual Costs to the U.S. 

Economy

The sections below describe the method and assumptions used to estimate aggregate incremental costs 

associated with the Agency’s proposed regulatory changes related to: leak inspection and repair, 

reporting and recordkeeping, and self-sealing valves on DIY small cans. The final section provides 

rationale for assuming no incremental compliance costs associated with other proposed regulatory 

changes.

3.1.1. Leak Inspection and Repair

Proposed regulatory changes associated with leak inspection and repair are expected to result in:

 Compliance costs associated with conducting leak inspections and repairs.

 Avoided compliance costs associated with changes in the leak repair requirements that relieve 

regulatory burden. Specifically, EPA proposes to grant the same flexibility to owners or operators of 

ODS CC and CR appliances as is currently offered to owners or operators of ODS IPR appliances to 

request additional time to make repairs due to the unavailability of components. This additional 

flexibility is expected to result in fewer ODS appliances being retired prematurely.

 Refrigerant savings associated with repairing leaks earlier.

As noted above, costs and savings were estimated using a model equipment, facility, and entity 

approach. Costs were then scaled up industry-wide based on the proportion of businesses that could be 

affected by the regulation in order to determine the full impact of each of the proposed changes.

3.1.1.1. Leak Inspection

The proposed regulatory changes result in compliance costs to equipment owners and operators in 

order to meet new requirements to conduct annual leak inspections for CC, CR, and IPR systems with 

charge sizes between 50 and 500 pounds and quarterly leak inspections for CR and IPR systems with 

charge sizes of 500 or more pounds. As a baseline, the analysis conservatively assumes that neither 

annual nor quarterly leak inspections are currently performed.11 This assumption may overestimate 

compliance costs since, in practice, some owners and operators have indicated they conduct regular 

 

11 Similarly, no appliances were assumed to have regularly-certified automatic leak detection equipment. 
25 August 26, 2015

leak inspections to ensure that systems continue to function properly and to avoid recurring refrigerant 

top-off costs. Automatic leak monitoring equipment is also becoming more common, which would 

further reduce actual compliance costs.

3.1.1.2. Leak Repair

The proposed regulatory changes result in compliance costs to owners and operators when leaks are 

identified in equipment containing 50 or more pounds of ODS or HFC refrigerant that exceeds the leak 

rate of 10% for CC or 20% for CR and IPR equipment. Equipment owners and operators must repair all 

identified leaks within 30 days, or, under certain circumstances, request an extension to conduct the 

repair; if leaks cannot be repaired, the appliance must be retrofitted or retired.12 These proposed 

requirements are incremental for owners and operators of equipment containing 50 or more pounds of:

 HFC refrigerant that exceeds the leak rate of 10% for CC or 20% for CR and IPR; and

 ODS refrigerant that exceeds the leak rate of 10% for CC or 20% for CR and IPR.

13

When leaks are repaired, all appliances must also conduct initial and follow-up verification tests; this 

requirement currently only applies to federally-owned and IPR appliances.

Leak repair outcomes. Lower applicable leak rates, in combination with the proposed regulatory 

requirement for leak inspections for all eligible equipment, should lead to leaks being identified and 

repaired sooner than under the current approach. As such, this analysis assumes that leaks will be 

detected and repaired earlier across all CC, CR, and IPR equipment containing 50 pounds or more of ODS 

or HFC refrigerant. Specifically, the analysis assumed that ODS and HFC equipment that experiences a 

leak event requiring repair realizes one of three outcomes:

 The standard repair outcome conservatively assumes that repairs are conducted three weeks earlier 

as a result of the proposed leak repair and leak inspection requirements (see Box 4).

 

12 The proposed regulatory changes also prohibit an appliance from leaking more than 75% of its full charge in two consecutive 

years. Because the economic analysis presented in this document assumes full compliance with the regulatory changes, it is 

assumed that qualifying leak events are identified and repaired within a one-year period, such that equipment would not be 

able to leak more than 75% of its total charge within a two year period. 

13 Although under the current Section 608 requirements, owners and operators of equipment containing more than 50 lbs. of 

ODS refrigerant are already required to repair leaks if the leak rate is above 15% CC and 35% for CR and IPR, it was assumed 

that the proposed leak inspection requirements would still accelerate the detection and repair of leaks of ODS equipment 

leaking above the previous threshold leak rates of 15% for CC and 35% for CR and IPR in addition to CC equipment with a leak 

rate between 10 and 15% and CR and IPR equipment with a leak rate between 25 and 35%.
26 August 26, 2015

Box 4: Assuming Three-week Earlier Repair

The assumption that repairs are conducted three weeks 

earlier as a result of the proposed rulemaking was based on 

analysis of facility-level reporting on leak repair under 

California’s RMP. Individual system-level leak rates were 

estimated using the amount of refrigerant reported as added 

during each leak event and the number of days between the 

refrigerant addition and the previous record for each system. 

This data set (i.e., individual system leak rates) was then 

grouped into leak rate bins (e.g., 0-10%, 10-20%, 20-30%, 

and so on). 

The average leak rate for each bin was used to calculate the 

number of weeks before the system would lose 40% of its 

charge. It was assumed that systems below 60% of their full 

charge would require servicing—regardless of the proposed 

requirements for mandatory inspection and repair (Kim and 

Braun 2010).

Leak events were assumed to be spread evenly over a 13 

week period to simulate the time between proposed 

quarterly inspections. The average number of weeks early 

that a leak would be detected for each bin was calculated 

based on this spread. For example, if a system is leaking at a 

rate that would cause it to lose 40% of its charge in eight 

weeks, and the leak inspection occurs in week four, the leak 

is assumed to be caught four weeks early. 

The average number of weeks early for each bin was then 

weighted based on (a) the number of systems in each bin 

and (b) the emissions value of catching a leak early in each 

bin. The emissions weighting accounts for the fact that 

catastrophic leaks would likely be found very quickly due to 

performance degradation, regardless of mandatory leak 

inspections, whereas slower, smaller leaks would benefit 

proportionately more from early detection through leak 

inspection.

This approach yielded a weighted average of approximately 

three weeks early that a leak would be detected. More and 

less conservative assumptions were also modeled, assuming 

repairs are conducted two weeks earlier and two months

earlier as a result of the proposed leak repair and leak 

inspection requirements. These alternate results are shown 

in Appendices 0 and 0, respectively.

 Under the extension repair outcome, 

owners/operators request an extension for 

conducting the repair. The analysis 

conservatively assumes that repairs are also 

conducted three weeks earlier as a result of 

the proposed leak repair and leak 

inspection requirements. As mentioned 

above, the proposed extension would allow 

owners/operators of non-federally-owned 

CC and CR appliances additional time to 

repair an appliance if components cannot 

be delivered within the necessary time. As a 

result, some ODS CC and CR systems that 

would have been prematurely retired under 

the current approach are now expected to 

request extensions. 14 

 The retrofit/retirement outcome assumes 

that systems that require retrofitting/

retirement are retrofitted/retired 5 years 

earlier than they would have been in the 

absence of the proposed regulatory 

changes (i.e., 5 years were assumed to be 

remaining before normal end-of-life). ODS 

systems were assumed to be retired as they 

are generally older systems, and HFC 

systems were assumed to be retrofitted. As 

previously noted, some owners or 

operators would have prematurely retired 

their ODS CC and CR equipment if a 

component could not be delivered in time, 

but now would apply for an extension. 

These avoided system retirements will 

result in avoided compliance costs for these 

equipment owners.

Table 13 below shows the proportion of affected equipment assumed to experience each outcome. The 

percentage of ODS systems reaching the retrofit/retirement outcome is shown as zero because no ODS 

 

14 Specifically, the analysis assumes that 50% of the ODS CC and CR systems that would have been prematurely retired under 

the current requirements instead apply for an extension. The baseline number of ODS system retirements was taken from EPA 

(2015b). 
27 August 26, 2015

systems are assumed to experience incremental incidence of retrofit or retirement. However, 

approximately 2,300 premature retirements of ODS CC and CR appliances are expected to be avoided as 

a result of the proposed consistent set of extensions for all appliance types.15 These avoided retirements 

result in reduced regulatory burden and avoided compliance costs.

Table 13: Leak Repair Outcomes and Proportions

Outcome HFC Systems ODS Systems

Standard Repair 97% 98%

Extension Repair 2% 2%*

Retrofit/Retirement 1% 0%

* Only includes CC and CR appliances.

Frequency of repair. Data reported under California’s RMP was reviewed to determine an appropriate 

assumption for the annual frequency of repair for systems that use advanced leak detection monitoring 

systems or are inspected annually or quarterly and are leaking above the proposed leak rates. These 

data suggest that most systems are repaired once per year, with the exception of larger (>500 lbs.) cold 

storage systems, which are repaired about twice per year on average.16 This analysis assumes that there 

would be a similar relationship between quarterly or annual leak inspections and leak detection and 

subsequent repair for equipment that is subject to Section 608 as there is for the equipment subject to 

California’s RMP.

Repair effectiveness and baseline leak rates. For all equipment types and sizes, post-repair leak rates 

reflect CARB (2009) estimates, which were based on EPA’s Vintaging Model and Intergovernmental 

Panel on Climate Change (IPCC)/Technology and Economic Assessment Panel (TEAP) (2005) 

recommendations. While EPA is requiring repair of all identified leaks if the applicable leak rate is 

exceeded, EPA recognizes that a post-repair leak rate of zero is not always the case. Therefore, the 

modeled post-repair rates may be more conservative than what may be achieved if this rule is finalized 

as proposed. To explore the sensitivity of costs and benefits to higher post-repair leak rates, the analysis 

was also run using post-repair rates set at 90% of the threshold leak rate (i.e., if the threshold rate is 

20%, it is assumed that the system is repaired and has a resulting leak rate of 18%). Appendix A.3 shows 

the results of this sensitivity analysis.

To develop assumptions for the baseline leak rates, multiple sources of leak rate information were 

reviewed and compared. First, average annual leak rates for equipment reported under California’s RMP 

 

15 As noted previously, this is based on an assumption that 50% of the ODS CC and CR systems that would have been 

prematurely retired under the current requirements instead apply for an extension. The baseline number of ODS system 

retirements was taken from EPA (2015b).

16 Cold storage systems that are repaired twice are assumed to follow a modified standard repair outcome. After the first leak is 

repaired, the system is assumed to leak for one week at the post-repair leak rate. At that point, the system is assumed to 

experience a failure such that two weeks after the original repair the system has leaked a qualifying amount of refrigerant to 

require a second repair.
28 August 26, 2015

were determined,17 and leak rates and number of affected equipment within and outside of the leak 

rate thresholds were examined at different levels of aggregation (e.g., sector, type, size, and 

refrigerant). This examination suggested that the economic analysis should develop separate leak rates 

for different equipment types and sizes. 

To ensure that this analysis used leak rates that were representative of equipment throughout the 

United States, average annual leak rates reported under the RMP that were above the leak rate 

thresholds for each sector were averaged and compared with equipment leak rates modeled in EPA’s 

nationwide Vintaging Model. This comparison of leak rates suggested that the RMP data set is likely a 

strong indicator of average leak rates for equipment above the leak rate thresholds throughout the 

United States and is discussed further in Section 3.1.1.4.

Table 14 below presents the final leak rate assumptions by equipment sector, type, and size for 

equipment that is affected by the leak repair requirements (i.e., is expected to leak above the leak rate 

thresholds).18 The percentage of each equipment type that is experiencing a qualifying leak is discussed 

in Table 17. For example, although only 23% of condensing unit systems have an annual average leak 

rate exceeding 20%, the average annual leak rate of those systems is 66% according to the RMP data. 

Table 14: Leak Rate Assumptions by Equipment Sector, Type, and Size

Leak Rate

Threshold Equipment Sector Equipment Type Equipment Size

Baseline Annual 

Leak Rate (for 

Equipment 

Requiring Repair)

Annual Postrepair Leak 

Rate

10% CC Unitary AC Small 60% 5%

Chiller Medium 49% 2%

Chiller Large 47% 2%

20% CR Condensing Unit Small 66% 5%

Rack Medium ≥500 lbs. 49% 10%

Rack Medium <500 lbs. 70% 10%

Rack Large 47% 10%

Cold Storage Medium ≥500 lbs. 55% 10%

Cold Storage Medium <500 lbs. 79% 10%

Cold Storage Large 62% 10%

 

17 Annual leak rates were calculated as the total amount of refrigerant added to a piece of equipment minus any refrigerant 

removed from the equipment (e.g., due to seasonal adjustment) throughout the year, divided by the charge size of the 

equipment.

18 The average baseline annual leak rates shown in Table 14 are based on actual leak rate data reported to the CARB RMP. 

Although leak repair requirements are currently in place for ODS CC, CR, and IPR equipment when their average annual leak 

rate exceeds the threshold leak rates of 15% and 35%, respectively, annual leak rates can still exceed these threshold leak rates 

prior to the repair. 
29 August 26, 2015

Leak Rate

Threshold Equipment Sector Equipment Type Equipment Size

Baseline Annual 

Leak Rate (for 

Equipment 

Requiring Repair)

Annual Postrepair Leak 

Rate

IPR IPR Small 97% 7%

IPR Medium ≥500 lbs. 59% 7%

IPR Medium <500 lbs 76% 7%

IPR Large 58% 7%

Assumptions about equipment charge sizes were made by equipment type and size category, as well as 

by refrigerant type (HFC and ODS), based on data reported under the California RMP. These 

disaggregated assumptions are shown in Section 2.1.1.

3.1.1.3. Unit Cost and Savings Assumptions

Leak inspection. Leak inspections were assumed to require one hour per system per inspection for 

commercial refrigeration and IPR, and 30 minutes for comfort cooling systems.

An hourly labor rate of $45.07 was assumed for leak inspection and repair, based on the median hourly 

earnings of $21.46 for heating, air-conditioning, and refrigeration mechanics and installers from the 

Bureau of Labor Statistics, plus 110% to account for overhead ($23.61).

Leak repair. Repair costs are calculated as the base cost of making the repair or retrofit, including labor, 

parts, refrigerant recovery, and verification tests.

19 These costs are assumed to vary by system size, 

where leak repairs on a smaller system are assumed to be relatively simpler and less costly than repairs 

on medium and large systems. The base costs associated with each outcome were estimated as 

described below. All costs were adjusted to 2014 dollars.

 Standard repair. Leak repair costs for a “standard repair” are based on assumptions in CARB (2009). 

CARB (2009) surveyed refrigeration and AC service contractors and technicians to validate these cost 

assumptions. 

 Extension repair. An “extension repair” is assumed to involve the repair of a major component such 

as a compressor, and is based on costs presented in Stratus (2009).20

 Retrofit. Retrofit costs were also based on Stratus (2009); this analysis assumed that the cost to 

retrofit an entire piece of equipment was between two to three times the cost of the compressor. 

 

19 Industry input suggested that verification tests are already conducted as standard practice during servicing events. Moreover, 

because initial and follow-up verification tests can both be conducted during the same service appointment, this requirement 

is not expected to result in a longer servicing event (and thus not expected to result in incremental labor costs).

20 Stratus (2009) obtained estimates of retail prices for typical replacement compressors from a supplier (ThermaCom Ltd.).
30 August 26, 2015

As noted above, HFC systems were assumed to be retrofitted, while ODS systems were assumed to 

be retired as they are generally older systems.

 Retirement. The base cost of retirement is assumed to be the installed cost of new, replacement 

equipment. The installed cost of CC, CR, and IPR equipment varies significantly across and within 

equipment types and capacities. For the purposes of this analysis, a reasonable average cost by 

equipment size was estimated through review of available literature (Stanford University 2011; Tait 

Consulting Ltd 2012; ACEEE 2013), including economic analyses conducted for other federal 

agencies (DOE 2009; DOE 2013), and industry calls. 

As noted above, lower leak rate thresholds, combined with new requirements for leak inspections, will 

result in leaks being repaired sooner than under the current approach. The analysis assumes that repairs 

are conducted three weeks earlier as a result of these proposed requirements. Thus, the repair costs 

attributable to the rule are based on the time cost of conducting those repairs three weeks earlier. The 

interest cost (at 7% per year)21 of the base repair cost is attributed to the rule; this cost is referred to 

below as the “effective cost of repair.” CARB used a similar approach—i.e., estimating the effective cost 

of repair—in developing its economic impact estimates for its High-Global Warming Potential Stationary 

Source Refrigerant Management Program (CARB 2009a). A sensitivity analysis exploring the impact of 

assuming repairs are conducted two months earlier—which results in higher effective costs of repair—is 

shown in Appendix A.4.

An “effective cost” approach was also taken for the cost of retrofitting and retirement. Systems that are 

retrofitted as a result of the proposed regulatory changes are assumed to be retrofitted five years 

earlier than they would have been under current practices. Thus, the effective cost of retrofitting 

attributable to the rule is the cost of borrowing the funds for retrofitting for five years at 7% per year.

Similarly, the avoided effective cost for premature retirement of ODS CC and CR appliances is the cost of 

borrowing the funds for purchasing a new system for five years at 7% per year. 

Table 15 below presents the base and effective cost assumptions by repair and system size. For retrofit 

and retirement outcomes, the costs presented do not include the additional cost of replacing the entire 

refrigerant charge with virgin refrigerant or charging a new system. With charge sizes exceeding 7,000 

pounds in some very large systems, these costs can be sizeable. For the standard and extension repair 

outcomes, the cost of refrigerant recharge is not included, since it is assumed that the owner or 

operator would have topped off the system in the absence of the proposed requirements.

 

21 A sensitivity analysis using an interest cost of 3% per year of the base unit cost is shown in Appendix A.4.
31 August 26, 2015

Table 15: Unit Cost Assumptions

System Size Labor 

Hours Parts Refrigerant Recovery

Total Base Cost for Labor, 

Parts, and Recovery

Effective Cost of 

Early Repair / 

Retrofit

Standard Repair

Small 8 $109 $218 $682 $3

Medium 12 $327 $382 $1,241 $5

Large 16 $655 $709 $2,073 $9

Extension Repair

Small 20.25 $2,836 $218 $3,967 $17

Medium 20.25 $10,345 $382 $11,639 $51

Large 20.25 $10,345 $709 $11,966 $52

Retrofit (HFC Equipment)

Small 20.25 $8,343 $218 $9,473 Varies based on 

charge size of 

equipment retrofitted Medium 20.25 $22,247 $382 $23,541 

Large 20.25 $22,247 $709 $23,869 

Retirement (ODS Equipment)

Small $20,000 Varies based on 

charge size of 

equipment replaced Medium $100,000

Large $250,000

Sources: for Standard Repair Labor Hours, Parts, and Recovery Costs: CARB 2009a; for Extension Repair and Retrofit: Status 

2009; for Retirement: Stanford University 2011; Tait Consulting Ltd 2012; ACEEE 2013; DOE 2009; DOE 2013.

Refrigerant savings. By causing leaks to be repaired earlier, the proposed regulatory changes would 

result in refrigerant cost savings for system operators. Refrigerant cost savings are calculated based on 

the difference between the baseline and post-repair leak rates, multiplied by the charge size, over the 

three weeks earlier that each repair was conducted. An average price of $6 per pound was assumed for 

all refrigerants. 

On a per system basis, effective refrigerant savings range from $20 for small systems up to $1,300 for 

large cold storage and IPR systems.

Leak repair expected costs and savings. Expected costs and savings per model equipment were 

estimated on a weighted basis, taking into account the proportion of equipment assumed to reach each 

leak repair outcome and the unit costs and savings associated with each outcome. Expected costs and 

savings were estimated in the model in a disaggregated manner, distinguishing between equipment 

sectors, types, sizes, and refrigerant type.
32 August 26, 2015

3.1.1.4. Model Facility Assumptions

The following calculation steps yielded aggregate costs/savings for the U.S. economy as a whole.

1. Leak repair expected costs/savings per model equipment type (as described above) were multiplied 

by the number of each type of equipment per facility (see below) and the percentage of each type 

of equipment assumed to experience leaks above the proposed rule’s threshold rates (see below).

2. Leak inspection costs per model equipment type were multiplied by the number of each type of 

equipment per facility (see below), taking into account equipment size to determine required 

frequency of inspection.

3. The sum of expected leak repair costs/savings and leak inspection costs per model facility was then 

multiplied by the total number of facilities in each industry category (see below) and the percentage 

of each industry assumed to be affected (see Section 2.1.2). Because CR and IPR appliances in 

facilities located in California are already subject to similar leak inspection and repair requirements 

under the California RMP, these appliances are removed from the analysis of costs and benefits.

The assumptions made are summarized below. In the model developed for this analysis, calculations 

were performed in a disaggregated manner, distinguishing between industry sectors, equipment 

sectors, types, sizes, and refrigerant type. Many of these assumptions were based on confidential 

business information reported under California’s RMP. To preserve the confidentiality of those data, 

assumptions are summarized on an industry- or equipment type-specific basis.

Section 2.1 summarizes the assumptions made regarding the average number of systems in each sector 

per model facility, for each industry category and the assumptions about the percentage of each 

industry that is assumed to use equipment containing 50 or more pounds of ODS or HFC refrigerant, and 

thus be affected by the proposed rulemaking.

Only equipment that experiences leaks that exceed the proposed leak threshold will be subject to repair 

requirements and thus incur compliance costs to repair those leaks. To determine this proportion of 

equipment, data submitted for CR and IPR under California’s RMP was reviewed. For CC, although 

facilities are not required to report data on CC systems under California’s RMP, some do, so while RMP 

data was reviewed to establish preliminary assumptions for CC systems, additional sources, such as data 

reported under California’s South Coast Air Quality Management District (as analyzed in Stratus 2009), 

EPA’s Vintaging Model, and expert judgement were also used to estimate the proportion of affected 

systems. 

Table 16 below presents a comparison of leak rate distributions by equipment sector and refrigerant 

type, based on analysis of California’s RMP and EPA’s Vintaging Model.
33 August 26, 2015

Table 16. Leak Rate Comparison Based on California’s RMP and EPA’s Vintaging Model

Equipment 

Sector Ref. Type Leak Rate Distribution

Percent of Equipment within 

Leak Rate Distribution

CARB RMP VM

CC ODS >10% 23% 4%

HFC >10% 20% <1%

CR ODS >20% 19% 100%

HFC >20% 17% 63%

IPR ODS >20% 15% 0%

HFC >20% 14% 0%

Note: The Vintaging Model assumes that 100% of ODS and HFC IPR systems 

have a leak rate below 20%.

Within each sector, the CARB RMP data suggest that the leak rate distributions for ODS and HFC systems 

are similar. Differences between the leak rate distributions from California’s RMP and those from the 

Vintaging Model can be attributed to how annual leak rates are developed (i.e., reported leak rate data 

and average leak rates across equipment types, respectively). Section 2.1.1 discusses these differences 

further. 

Based on the information above, ODS and HFC equipment were assumed to have the same leak rate 

distributions, disaggregated by equipment type and size. Table 17 presents the assumptions made for 

this analysis regarding the proportion of affected equipment experiencing leaks above the threshold.

Table 17: Affected Equipment Assumptions by Equipment Sector, Type, Size, and Refrigerant Type

Equipment Sector Equipment Type Equipment Size

Percentage of Equipment 

Experiencing Leaks Above 

the Proposed Threshold 

Rate

CC Unitary AC Small 20%

Chiller Medium 23%

Large 16%

CR Condensing Unit Small 23%

Rack Medium <500 6%

Medium ≥500 13%

Large 26%

Cold Storage Medium <500 13%

Medium ≥500 17%

Large 33%

IPR IPR Small 6%
34 August 26, 2015

Equipment Sector Equipment Type Equipment Size

Percentage of Equipment 

Experiencing Leaks Above 

the Proposed Threshold 

Rate

Medium <500 12%

Medium ≥500 10%

Large 10%

3.1.2. Recordkeeping and Reporting

Proposed regulatory changes associated with recordkeeping and reporting are expected to result in:

 Compliance costs associated with incremental requirements for recordkeeping and reporting for 

ODS-containing appliances, extending the requirements for recordkeeping and reporting to 

appliances containing substitute refrigerants, and adding new recordkeeping and reporting

requirements.

 Avoided compliance costs associated with the removal of some recordkeeping and reporting 

requirements.

The sections below describe the assumptions and methodology used to estimate recordkeeping and 

reporting costs and avoided costs associated with the proposed regulatory changes. All recordkeeping 

and reporting costs are calculated by multiplying the estimated burden (hours) times the average annual 

respondent hourly cost (labor plus overhead). For all recordkeeping and reporting requirements, except 

the new recordkeeping requirement for small can manufacturers,22 the analysis uses the median hourly 

earnings of $21.46 for heating, air-conditioning, and refrigeration mechanics and installers from the 

Bureau of Labor Statistics (BLS 2014a). This number was multiplied by 110% for overhead (i.e., $21.46 x 

1.10 = $23.61). The resulting cost of $45.07 ($21.46 + $23.61) is the average hourly administrative cost 

of labor plus overhead for a private firm.

3.1.2.1. Recordkeeping and Reporting Associated with Leak Inspection and Repair

The sections below describe how the incremental annual burden time was estimated for each 

recordkeeping and reporting requirement associated with leak inspection and repair. To generate costs, 

the annual burden time was multiplied by the hourly wage rate.

Requests for extensions to the leak repair and retrofit/retire timelines. Owners or operators of IPR

appliances and federally-owned CR and CC appliances normally containing 50 or more pounds of ODS 

refrigerant may apply to EPA for an extension to the leak repair and appliance retrofit/retire timeframe.

 

22 The median hourly earnings of $13.74 for Weighers, Measurers, Checkers, and Samplers, Recordkeeping occupational 

workers from the Bureau of Labor Statistics was assumed for small can manufacturers (BLS 2014b). This number was 

multiplied by 110% for overhead (i.e., $13.74 x 1.10 = $15.11). The resulting cost of $28.85 ($13.74 + $15.11) is the average 

hourly administrative cost of labor plus overhead for a private firm.
35 August 26, 2015

EPA is proposing to extend this requirement to: 1) all equipment types, including CC and CR appliances 

that are not federally-owned; and 2) appliances normally containing 50 or more pounds of HFC 

refrigerant. 

First, the incremental burden associated with submitting extension requests for CC and CR equipment 

containing ODS refrigerants was estimated. The total number of extension requests for IPR equipment 

under the current requirements was identified using the Program’s supporting ICR (EPA ICR Number: 

1626.13, OMB Control Number: 2060-0256), and this number was then scaled based on the expanded 

pool of affected equipment (i.e., CC and CR) using the model facility assumptions described in Section 

3.1.1.4 above. In addition, some ODS-containing CC and CR equipment that would have been 

prematurely retired under the current approach are now expected to request extensions, as described 

in Section 3.1.1.2.

23 As a result, the number of extension requests for ODS-containing CC and CR is 

expected to increase, while the number of plans developed to retire/replace or retrofit ODS-containing 

CC and CR equipment is expected to decrease. Because the burden time per response is greater for 

developing retirement/retrofit plans than for preparing and submitting an extension request (8 hours 

versus 30 minutes), some owners and operators of ODS-containing CC and CR equipment24 are expected 

to experience avoided reporting and recordkeeping costs.

To estimate the incremental burden associated with submitting extension requests for IPR, CC, and CR 

equipment containing HFC refrigerants, the number of requests was estimated by scaling based on the 

ratio of affected ODS equipment to HFC equipment. 

Invoices provided by service technicians. Under current regulations, persons servicing appliances 

normally containing 50 or more pounds of ODS refrigerant are required to provide invoices to appliance 

owners or operators indicating the amount of refrigerant added to the appliance. EPA is proposing to: 1) 

extend this requirement to appliances normally containing 50 or more pounds of HFC refrigerant, and 2) 

add new recordkeeping requirements associated with each refrigerant addition (see Section 1.2.2 for 

details). 

The analysis assumed that service technicians would need to provide invoices to appliance 

owners/operators four times per year for IPR and CR equipment with charge sizes 500 pounds or greater

and one time per year for all CC equipment and IPR and CR equipment with charge sizes between 50 and 

500 pounds. Multiplying this invoice frequency by the number of affected equipment yields an annual 

estimate of approximately 1.3 million invoices for affected ODS equipment and approximately 1.1

million invoices for affected HFC equipment. Since technicians are already required to provide invoices 

when servicing ODS equipment, the only incremental burden for ODS equipment was assumed to be the 

time associated with providing documentation for the new recordkeeping requirements (i.e., 0.5 

minutes). For servicing HFC equipment, the same burden time per invoice as the ICR was assumed (i.e., 

 

23 Specifically, the analysis assumes that 50% of the ODS CC and CR systems that would have been prematurely retired under 

the current requirements instead apply for an extension. The baseline number of ODS system retirements was taken from EPA 

(2015b). 

24 Approximately 2,300 owners/operators.
36 August 26, 2015

1.5 minutes), plus 0.5 minutes to account for the new recordkeeping requirements associated with 

refrigerant additions. 

Purchase and service records. Under current regulations, owners or operators of IPR, CC, and CR 

appliances normally containing 50 or more pounds of ODS refrigerant must maintain purchase and 

service records. EPA is proposing to: 1) extend this requirement to equipment containing HFCs and 

other non-exempt substitutes; and 2) require equipment owners to maintain records of the information 

provided by service technicians associated with each refrigerant addition (see Section 1.2.2 for further 

details). 

This analysis assumes that there is no incremental burden on owners of affected equipment to maintain 

the new information from service technicians associated with each refrigerant addition. However,

owners or operators of affected HFC equipment are assumed to incur costs associated with the time 

burden for maintaining purchase and service records. Consistent with the ICR, 1.5 minutes of burden 

time is assumed each time an HFC appliance is serviced. The total number of servicing events is assumed 

to be equal to the number of times that service technicians provide invoices (i.e., four times per year for 

IPR and CR equipment with charge sizes 500 pounds or greater and one time per year for all CC 

equipment and IPR and CR equipment with charge sizes between 50 and 500 pounds).

Plans to retire/replace or retrofit equipment. Under current regulations, owners or operators of IPR, 

CC, and CR appliances normally containing 50 or more pounds of ODS refrigerant must develop and 

maintain a plan to retire/replace or retrofit equipment after a failed follow-up verification test. EPA is 

proposing to extend this requirement to IPR, CC, and CR appliances normally containing 50 or more

pounds of HFC refrigerant. To calculate the incremental recordkeeping costs associated with developing 

a plan to retire/replace or retrofit HFC equipment, the assumptions in the ICR for ODS equipment were 

scaled proportionately based on the ratio of affected ODS and HFC equipment.

Results of verification tests. Section 608 regulations currently require initial and follow-up verification 

tests each time the leak rate threshold is breached for both IPR appliances and federally-owned CC and 

CR appliances normally containing 50 or more pounds of ODS refrigerant. EPA is proposing to extend 

this requirement to: 1) all equipment types, including CC and CR appliances that are not federallyowned; and 2) appliances normally containing 50 or more pounds of HFC refrigerant. The model facility 

assumptions described in Section 3.1.1.4 were used to identify the pool of newly affected equipment 

(i.e., CC and CR ODS equipment and all HFC equipment) and the expected number of times that the 

newly affected equipment would exceed the leak rate threshold on an annual basis. For every 

occurrence of an appliance exceeding the leak rate threshold, 1.5 minutes of burden time was assumed 

to maintain reports on the results of verification tests. 

Leak inspections. Leak inspections are currently not required under the Section 608 regulations. EPA is 

proposing to require: 1) quarterly inspections for all IPR and CR equipment containing a refrigerant 

charge of 500 or more pounds; and 2) annual inspections for all IPR and CR equipment with a refrigerant 

charge between 50 and 500 pounds, plus all CC equipment with a refrigerant charge greater than 50 

pounds. This analysis assumes that the recordkeeping time associated with quarterly and annual 
37 August 26, 2015

inspections is one minute. The model facility assumptions (see section 3.1.1.4) were used to identify the 

affected pool of equipment. 

3.1.2.2. Other Recordkeeping and Reporting Requirements

As also described in Section 1.2.2, EPA is proposing to extend the following recordkeeping and reporting 

requirements to HFC refrigerants and other substitutes: 

 Reclaimer annual activity reports. Refrigerant reclaimers must submit annual reports noting the 

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

 Reclaimer recordkeeping. Reclaimers must maintain records of refrigerant sales transactions, 

including the quantity of material sent to them for reclamation.

 Disposal establishments’ refrigerant recovery recordkeeping. Persons disposing of air-conditioning 

or refrigeration equipment must maintain a copy of a signed statement for each piece of disposed 

equipment that demonstrates all remaining refrigerant was recovered from the equipment before 

final disposal.

 Refrigerant wholesalers’ recordkeeping. Wholesalers of refrigerants must maintain sales records 

and technician certification cards from purchasers showing that they employ at least one certified 

technician.

 Purged refrigerant recordkeeping. Owners/operators of appliances with charge sizes greater than 

50 pounds must maintain information on purged/destroyed refrigerant.

To estimate the incremental costs for an extension to HFCs and other non-exempt substitutes for each 

of the abovementioned requirements, the burden estimates from the Program’s supporting ICR (EPA ICR 

Number: 1626.13, OMB Control Number: 2060-0256) were scaled based on the ratio of ODS to HFC 

equipment stock. For recordkeeping and reporting requirements that pertain to reclamation, it was 

conservatively assumed that HFC reclamation would occur at the same rate as ODS reclamation.

Other proposed recordkeeping and reporting provisions also include: 

Certified technician database. EPA is proposing to require certification programs to create and maintain 

a publicly-available database or list of currently certified technicians. This analysis assumes negligible 

cost associated with this requirement, since it is anticipated to be fulfilled by maintaining and publishing 

a PDF list of certified technicians online.25

Small can self-sealing valve recordkeeping. EPA is proposing to add a new recordkeeping requirement 

for manufacturers of small cans of automotive refrigerant to keep records of test data and log forms 

that demonstrate compliance with the allowable leakage rate. To estimate the costs for the new small 

 

25 A total annual labor cost of approximately $660 was estimated for technician certification programs to maintain a list of 

currently certified technicians. Specifically, it was assumed that each of the 88 technician certification programs would spend 

approximately 5 minutes updating their list of certified technicians twice a year, resulting in 15 total annual burden hours. 
38 August 26, 2015

can recordkeeping requirement, it was assumed that filing test data and log forms would take 

approximately 1.5 minutes per test batch. Since the test procedure takes on average 30 days per batch, 

filing test data and log forms is assumed to occur on a monthly basis. 

Recovery and recycling equipment certification of ownership. EPA is proposing to remove the 

requirement for persons who maintain, service, repair, or dispose of appliances containing ODS 

refrigerants to submit a signed statement that they own certified recovery and recycling equipment. The 

removal of this requirement would result in a burden reduction for more than 2,600 affected service 

and disposal establishments.

Disposal of appliances with charge sizes between 5 and 50 pounds. EPA is proposing to require a new 

recordkeeping requirement where technicians disposing of appliances with charge sizes between 5 and 

50 pounds must document how much refrigerant was recovered from the appliance at disposal and how 

much refrigerant is transferred for reclamation or destruction. To estimate the incremental burden 

associated with this new requirement, the total number of ODS and HFC appliances disposed of annually 

with charge sizes between 5 and 50 pounds from EPA’s Vintaging Model was multiplied by the perappliance burden time associated with maintaining these records (assumed to be two minutes). Table 

18 below shows the total number of ODS and HFC appliances containing between 5 and 50 pounds of 

refrigerant that are estimated to be disposed of annually.

Table 18. Appliances with Charge Sizes Between 5 and 50 Pounds Disposed in 2015

Equipment Type

Estimated Units Disposed in 2015

HCFC HFC Total

Water and ground source heat pumps 68,240 0 68,240

Ice Makers 0 142,240 142,240

Small condensing units 72,970 7,790 80,760

Refrigerated transport 3,160 315,280 318,440

Residential unitary AC 6,302,760 99,080 6,401,840

Small commercial unitary AC 260,150 8,050 268,200

Large commercial unitary AC 15,440 0 15,440

Total 6,722,720 572,440 7,295,160

Source: EPA 2014.

The following recordkeeping and reporting requirements were assumed to have no incremental burden 

costs associated with an extension to HFCs and other substitutes: 

 Maintenance of copies of signed statements of previous refrigerant recovery by disposal 

establishments.

26

 

26 It is assumed that time required to file these statements daily remains the same.
39 August 26, 2015

 Refrigerant recovery and recycling equipment testing organizations submitting reports on approved 

equipment and maintaining records of equipment tested.

 Certification by refrigerant reclaimers that change ownership or enter the market.

 Technician certification programs applying for approval.

 Recordkeeping and biannual reporting by existing technician certification programs.

 Technicians acquiring and maintaining certification cards.

3.1.3. Self-sealing Valves on DIY Small Cans

Consistent with CARB’s Staff Analysis on Emissions and Economic Impact of Proposed Regulation for 

Small Containers of Automotive Refrigerant, this analysis assumes that the extra cost to install a selfsealing valve on DIY small cans would be approximately $0.25 per can (CARB 2009b). Using data from 

the NPD Automotive Aftermarket Industry Monitor, the total number of small cans sold annually in the 

United States was multiplied by the cost per valve to arrive at the total annual incremental cost 

estimated to be incurred by small can manufacturers (NPD 2008; CARB 2009b).

27 Small cans that are sold 

in the state of California were excluded from this analysis due to CARB’s existing requirement for all 

small can manufacturers to install self-sealing valves, which became effective October 1, 2009.

EPA also considered what the costs would be of extending the sales restriction to HFCs and other 

substitutes without an exemption for small cans of refrigerant for MVAC servicing. If EPA had extended 

the sales restriction without the exemption, DIYers would be required to either seek certification under 

section 609 or take their car to a technician to be serviced. As shown in Appendix F, extending the sales 

restriction to small cans would be significantly more burdensome than the requirement to equip all 

small cans with a self-sealing valve.

3.1.4. Extending Other Existing Requirements to HFCs and Other Substitutes: 

Implications for Costs

While EPA is requiring specific practices to prevent release of refrigerant, including but not limited to 

requiring refrigerant be recovered from small appliances, MVACs, and MVAC-like appliances before 

disposal, evacuation of refrigerant before opening an appliance for servicing, and reclamation of used 

refrigerant to industry standards before sale, EPA has not assumed any additional cost to industry for 

this extension other than those discussed in Section 3.1. Likewise, EPA has not calculated any of the 

benefits that would accrue if compliance were to increase as a result of this rulemaking (see Section 

3.3). 

 

27 The NPD data was provided by nine companies, including Advance, AutoZone, CSK/Murrays, Pep Boys, O'Reilly’s, CARQUEST, 

NAPA, Strauss Auto, and Parts Alliance. It represents an average of the total HFC-134a small cans sold in the United States in 

2006 and 2007. 
40 August 26, 2015

This assumption is reasonable and appropriate because anyone handling HFC and other substitute 

refrigerants already must comply with the venting prohibition, which effectively necessitates similar 

practices to ensure refrigerant is not released into the environment. This assumption is supported by 

feedback from numerous regulated entities both in the public and private sector that most in industry 

treat HFCs and ODS refrigerants the same way to comply with the venting prohibition.

Thus, some of the regulatory changes that EPA is proposing are not expected to result in compliance 

costs. Table 19 summarizes these regulatory changes and the rationales for assuming no incremental 

costs.

Table 19: Regulatory Changes Assumed to Present No Incremental Cost

Recommended Regulatory Changes Rationale for Assuming No Incremental Costs

Leak Repair and Prevention

 Require all appliances to 

conduct initial and follow-up 

verification tests (currently 

only applies to federal and IPR 

appliances)

Industry input suggested that verification tests are already 

conducted as standard practice during servicing events. 

Moreover, because initial and follow-up verification tests can 

both be conducted during the same service appointment, this 

requirement is not expected to result in a longer servicing event 

(and thus not expected to result in incremental labor costs).

 Require a leak inspection to 

identify leaks upon 

discovering that the 

applicable leak rate is 

exceeded

This analysis assumes that equipment owners or operators are 

currently inspecting their equipment as part of a service call to 

identify what must be repaired upon discovering that the 

appliance exceeds the applicable leak rate. 

 Create an annual leak limit of 

75% for 2 consecutive years

This regulatory change is expected to improve compliance and 

enforcement. However, because the economic analysis 

presented in this document already assumes full compliance 

with the regulatory changes, it is assumed that qualifying leak 

events are identified and repaired within a one-year period, such 

that equipment would not leak more than 75% of its total charge 

within two consecutive 12-month periods.

Preventing

Emissions During

Servicing

 Extend the sales restriction to 

non-exempt substitutes, 

thereby requiring technician 

certification and proper 

handling for HFCs

This analysis assumes that all technicians currently servicing ODS 

equipment also service HFC equipment, and therefore, 

extending the sales restriction to HFCs would not result in any 

technicians needing to become newly certified.

Venting Prohibition

 Extend the de minimis

exemption to HFCs and other 

substitute refrigerants

This analysis assumes no costs associated with this extension 

because most stakeholders are already properly recovering 

substitute refrigerants during maintenance, servicing, repair, or 

disposal of appliances as required under the venting prohibition.

This requirement would likely mean minimal, if any, change in 

business practices other than the recordkeeping provisions 

discussed previously.
41 August 26, 2015

Recommended Regulatory Changes Rationale for Assuming No Incremental Costs

Evacuation

Requirements

 Extend evacuation 

requirements to HFCs and 

other substitute refrigerants

This analysis assumes no costs associated with this extension 

because most technicians are already properly evacuating 

substitute refrigerants during maintenance, servicing, repair, or 

disposal of appliances as required under the venting prohibition. 

This requirement would likely mean minimal, if any, change in 

business practices.

Reco

very Equipment

Certification

 Extend the requirement to 

use certified recovery 

equipment during the 

maintenance, service, repair, 

or disposal of appliances, 

other than MVACs and MVAClike appliances, that contain 

HFCs or other substitute 

refrigerants

This analysis assumes no costs associated with this extension

since the existing pool of recycling and recovery equipment are 

already expected to meet certification requirements and can be 

used to recover both ODS refrigerants and fluorocarbon 

substitutes. Additionally, EPA assumes full compliance with the 

venting prohibition, which would necessitate recovery of all nonexempt refrigerants.

Safe Disposal

 Extend requirements for the 

safe disposal of appliances to 

HFCs or other substitute 

refrigerants

This analysis assumes no costs associated with this extension 

because most technicians are already properly evacuating 

substitute refrigerants during maintenance, servicing, repair, or 

disposal of appliances as required under the venting prohibition. 

This requirement would likely mean minimal, if any, change in 

business practices other than the recordkeeping provisions 

discussed previously.

Reclamation

 Extend reclamation standards 

in Appendix A (currently 

based on ARI Standard 700-

1995, Specification for 

Fluorocarbons and Other 

Refrigerants) to HFCs and 

other substitutes

This analysis assumes no costs associated with this extension 

because refrigerant recovered and reclaimed from disposed 

appliances must be of a certain purity to effectively be used in 

the appliance service sectors. Additionally, feedback from 

industry indicates that reclaimers use the same processes and 

practices when they reclaim HFCs as they do for ODS.

Technician Certification

 Extend certification 

requirements to technicians 

who work with HFCs and 

other substitute refrigerants

This analysis assumes no costs associated with this extension 

because the pool of currently certified technicians is assumed to 

work with both ODS and substitute refrigerants. Many 

companies already require certification of their technicians 

regardless of the type of refrigerant being used. Further, EPA is 

not requiring currently certified technicians to recertify under 

this provision.

 Require technician 

certification programs to offer 

tests to technicians who work 

with HFCs and other 

substitute refrigerants 

This analysis assumes no costs associated with this extension 

because certification programs will not need to change current 

practices to offer tests for these technicians. Further, EPA is not 

proposing to require certification programs to recertify.

Grandfathering

Pro

visions

 Remove provisions related to 

voluntary certification 

programs

This analysis assumes no costs associated with removing 

provisions related to voluntary certification programs since the 

provisions are deemed no longer necessary.
42 August 26, 2015

Recommended Regulatory Changes Rationale for Assuming No Incremental Costs

Certification

Cards

 Change the required text that 

is printed on certification 

cards

This analysis assumes the costs associated with this change are 

negligible and may actually ease burden on refrigerant 

wholesalers who must inspect the cards to verify the 

certification of technicians.

3.2. Approach for Estimating the Economic Impact on Small Entities

The sections below describe the method and assumptions used to estimate the economic impact on 

small entities associated with proposed regulatory changes related to: leak inspection and repair, 

reporting and recordkeeping, and self-sealing valves on DIY small cans.

3.2.1. Leak Inspection and Repair Model Facility and Entity Assumptions

The RFA/SBREFA screening analysis uses most of the assumptions and methodological steps presented 

above for the aggregate economic analysis, in Section 3.1.1.

Different model facility scenarios were developed, however, to more accurately reflect the range of 

compliance costs that a given small business owner or operator could experience. For each facility, there 

are many potential configurations of equipment types, refrigerant, leak rates, and repair outcomes. For 

example, a food manufacturer with one comfort cooling system and two commercial refrigeration 

systems could have the comfort cooling system exceed the leak rate threshold and conduct a standard 

repair, while the two commercial refrigeration systems do not exceed the leak rate threshold. Or, the 

comfort cooling system could exceed the leak rate threshold and require a retrofit, while the 

commercial refrigeration systems are maintained below the threshold. Or, alternatively, the two 

commercial refrigeration systems could exceed the leak rate threshold and require an extension repair, 

while the comfort cooling system does not exceed the threshold. Multiple other configurations are 

possible within this single example and across all of the other industry categories.

Considering these multiple possibilities, “worst case” model facility assumptions were adopted. The 

“worst case” reflects the possibility that equipment with leak rates above the proposed threshold are 

clustered in individual facilities, such that all of the eligible equipment in a single model facility might 

trigger repair requirements. Within each facility, it is assumed that multiple units of the same 

equipment type are maintained in the same way (e.g., if a facility has two commercial refrigeration 

systems, both pieces of equipment are assumed to have similar leak rates), and thus experience the 

same leak repair outcomes. Model facility scenarios were developed for each industry category based 

on how many different types of equipment the industry is assumed to use and the expected number of 

extension requests and retrofits. Each scenario features a different combination of equipment and leak 

repair outcomes.

In Box 5 below, the Agricultural and Crop Support Services industry (Ag/Crop) is used to illustrate how 

this method was applied. 
43 August 26, 2015

Box 5: Model Facility Approach for the Agricultural and Crop Support Services Industry

In the Ag/Crop industry, a total of about 1,140 commercial refrigeration systems and 728 comfort cooling systems are 

estimated to be affected by the proposed rule. Each Ag/Crop facility is assumed to have two commercial refrigeration 

systems and one comfort cooling system. Therefore, 570 facilities (1,1,40 ÷ 2) are assumed to have two commercial

refrigeration systems and one comfort cooling system with leak rates above the proposed threshold. The remaining 158 

facilities (728 – 570) have one comfort cooling system with leak rates that exceed the proposed threshold. 

The 570 facilities with all three pieces of affected equipment were further broken down by the potential repair outcomes 

for the affected equipment. Because the extension requests and retrofits result in the highest compliance costs incurred, 

these leak repair outcomes drove the model facility scenarios. The number of extension requests and retrofit requests were 

apportioned to each industry by multiplying the percentage of affected equipment (by sector and industry) by the total 

number of extension requests and retrofits expected across all industries.

For the Ag/Crop industry, 8 pieces of commercial refrigeration equipment are estimated to undergo retrofit in a given year. 

Assuming that both pieces of commercial refrigeration equipment at a facility will experience the same leak repair outcome, 

4 facilities are assumed to have two pieces of commercial refrigeration equipment retrofitted. The comfort cooling systems 

at those 4 facilities are assumed to undergo a standard repair. Similarly, 18 pieces of commercial refrigeration equipment 

are assumed to request an extension repair, so 9 facilities are assumed to have two commercial refrigeration units with 

extension repairs and one comfort cooling system with a standard repair. This matrix approach is applied until all equipment 

outcomes are distributed among facilities, as shown in the table below.

Number of Facilities

Comfort Cooling Units Commercial Refrigeration Units

Standard Extension Retrofit Standard Extension Retrofit

Facilities with only 1 CC Affected

158 1

Facilities with 1 CC and 2 CR Affected

4 1 2

9 1 2

5 1 2

12 1 2

540 1 2

Expected compliance costs per model facility were estimated by multiplying the unit cost assumptions 

described in Section 3.1.1.3 plus the expected reporting and recordkeeping costs per facility, by the 

model facility configurations for each industry sector. Costs to small businesses were then scaled based 

on the proportion of facilities-to-entities for small businesses in each NAICS code in each industry 

category.

To be conservative, this analysis does not include the avoided compliance costs associated with the 

proposed flexibility for owners or operators of ODS CC and CR appliances to request additional time to 

make repairs due to the unavailability of components. While this flexibility is expected to result in fewer 

ODS appliances being retired prematurely, these avoided costs are not reflected in the small business 

impacts analysis. 
44 August 26, 2015

3.2.2. Reporting and Recordkeeping 

The compliance costs associated with reporting and recordkeeping that are incurred by affected 

equipment owners and operators are included in the model facility calculations described above. This 

section addresses the costs to other small entities subject to reporting and recordkeeping requirements, 

including reclaimers, disposal establishments, service establishments, refrigerant wholesalers, small can 

manufacturers, and service technicians.

28

Table 20 below shows potentially affected industries by reporting and recordkeeping requirement (see 

also Section 2.2).

Table 20. Potentially Affected Industries for Reporting and Recordkeeping Requirements

Reporting and Recordkeeping 

Requirement Industry NAICS Code and Definition

Reclaimer annual activity reports 

and recordkeeping

Reclaimers 325120 Industrial Gas Manufacturing

423930 Recyclable Material Merchant Wholesalers

562920 Materials Recovery Facilities

562212 Solid Waste Landfill

424690 Other Chemical and Allied Products Merchant 

Wholesalers

Refrigerant wholesalers 

recordkeeping for refrigerant sales, 

including maintenance of technician 

certification cards from purchasers 

employing at least one certified 

technician

Refrigerant 

Wholesalers

325120 Industrial Gas Manufacturing

424690 Other Chemical and Allied Products Merchant 

Wholesalers

42 Wholesale Trade

New recordkeeping requirement to 

document how much refrigerant was 

recovered from 5-50 lb. appliances 

at disposal and the fate of that 

refrigerant

Service 

Technicians

238220 Plumbing, Heating, and Air-conditioning 

Contractors

New recordkeeping requirement to 

keep records of self-sealing valve 

test data and log forms

Small Can 

Manufacturers

441310 Automotive Parts and Accessories Stores

325120 Industrial Gas Manufacturing

Removal of certification requirement 

for disposal establishments that 

change ownership or enter the 

market

Disposal 

Establishments

562920 Materials Recovery Facilities

562212 Solid Waste Landfill

423990 Other Miscellaneous Durable Goods Merchant 

Wholesalers

 

28 As noted in Section 2.2, disposal and service establishments are expected to experience cost relief due to EPA’s proposal to 

remove the requirement to submit a signed statement to show ownership of certified recovery and recycling equipment.
45 August 26, 2015

Reporting and Recordkeeping 

Requirement Industry NAICS Code and Definition

Removal of certification requirement 

for owners of refrigerant recovery/ 

recycling equipment that change 

ownership or enter the market 

Service 

Establishments

811310 Commercial Industrial Machinery and 

Equipment (not Automotive and Electronic) 

Repair and Maintenance

811412 Appliance Repair and Maintenance

To determine the incremental cost per firm to comply with the proposed changes to recordkeeping and 

reporting requirements, the total aggregate incremental costs were divided by the total number of 

affected businesses in each industry. For example, the aggregate incremental costs for reclaimers

represents the sum of the incremental costs associated with: 1) reclaimer annual activity reports; and 2) 

reclaimer recordkeeping (i.e., $12,011 + $15,014= $27,025). This number was then divided by 61, 

representing the number of certified refrigerant reclaimers affected by the proposed changes (i.e., 

$27,025/61 = $443/per certified refrigerant reclaimer). This conservative approach likely overestimates 

costs for small businesses by assuming equal burden regardless of business size. 

3.2.3. Self-sealing Valves on DIY Small Cans

To estimate the cost per entity to install self-sealing valves, total annual sales of DIY small cans were 

distributed across the manufacturers using a weighted average of total small can Stock Keeping Units 

(SKUs) and share of total sales volume. For small businesses, this number was then multiplied by the 

cost to install a self-sealing valve, which is assumed to be $0.25 per can.

29

3.3. Approach for Estimating Benefits

The sections below describe the method and assumptions used to estimate aggregate benefits 

associated with proposed regulatory changes related to leak inspection and repair and self-sealing 

valves on DIY small cans. In addition, the methodology for estimating future benefits in 2020 and 2025 

of the leak inspection and repair proposed regulatory changes is presented. The environmental benefits 

are the annual GHG emissions avoided (MTCO2eq) and annual ODS emissions avoided (ODP-weighted 

MT) as a result of the proposed regulatory changes. 

3.3.1. Emission Reduction Benefits of Leak Inspection and Repair

3.3.1.1. Annual Benefits of Leak Inspection and Repair

Similar to the methodology for estimating costs and savings, benefits were estimated using a model 

equipment, facility, and entity approach. Benefits were then scaled up industry-wide based on the 

 

29 Annual sales of DIY small cans sold in California were excluded from this analysis. Cans sold in California are already required 

to have a self-sealing valve per CARB regulations. 
46 August 26, 2015

proportion of businesses that could be affected by the regulation in order to determine the full impact 

of each of the proposed changes.

Benefits are calculated as the refrigerant emissions prevented by repairing or retrofitting a leaking 

system earlier. Avoided refrigerant emissions are calculated based on the difference between the 

baseline and post-repair leak rates (shown in Section 3.1.1.2 above), multiplied by the charge size, over 

the three weeks earlier that each repair was conducted. The amount of avoided refrigerant emissions is 

weighted by an average ODP (for ODS systems) and GWP (for ODS and HFC systems). ODP and GWP 

values were estimated as a weighted average of the refrigerant GWP or ODP (using IPCC AR4 values) and 

charge size for each equipment type and size, based on 2013 data reported under California’s RMP.30

Table 21: Average GWP and ODP Assumptions by Equipment Type, Size, and Refrigerant Type

Sector Equipment Type Equipment Size Refrigerant Type Weighted-Average 

ODP

Weighted-Average 

GWP

CC Unitary AC Small ODS 0.05 1,816

HFC - 2,349

Chiller Medium ODS 0.05 1,716

HFC - 2,044

Chiller Large ODS 0.05 1,414

HFC - 1,544

CR Condensing Unit Small ODS 0.03 3,140

HFC - 3,792

Rack Medium ODS 0.05 2,191

HFC - 3,644

Rack Large ODS 0.05 1,861

HFC - 3,860

Cold Storage Medium ODS 0.05 1,839

HFC - 3,726

Cold Storage Large ODS 0.06 1,810

HFC - 3,984

IPR IPR Small ODS 0.02 2,788

HFC - 3,957

IPR Medium ODS 0.04 1,076

HFC - 3,234

 

30 The ODP and GWP values used in this analysis are based on weighted refrigerant use by each equipment type. Refrigerants 

included in the analysis can be found in Table 5.
47 August 26, 2015

Sector Equipment Type Equipment Size Refrigerant Type Weighted-Average 

ODP

Weighted-Average 

GWP

IPR Large ODS 0.05 1,556

HFC - 1,860

The benefits for the extension repair are assumed to be equivalent to the benefits of a standard repair, 

as this analysis does not take into account the additional 30 days that the system is leaking between 

filing the extension and when the actual repair takes place, which could result in overestimating the 

avoided emissions as a result of the extension request. However, because systems requiring an 

extension repair have typically more complicated or catastrophic leaks, an extension repair as a result of 

the proposed regulatory changes would still be taking place earlier than it would under the baseline 

scenario, and emissions would still be avoided. 

No emission benefits associated with retrofit and replacement are assumed, as the proposed rule does 

not require equipment that is repaired or retrofitted to be initially repaired. Furthermore, because this 

analysis only considers a one-year period, it does not include benefits from preventing a chronically 

leaking system from continued operation over a longer time period than one year, nor does it include 

the benefits of an accelerated transition to alternative refrigerants that may have lower GWPs. 

On a per system basis, effective benefits range from 3 MTCO2eq for small comfort cooling HFC systems 

up to more than 200 MTCO2eq for very large IPR systems.

Model Equipment Expected Benefits. Expected benefits per model equipment were estimated on a 

weighted basis, taking into account the proportion of equipment assumed to reach each leak repair 

outcome (see Table 13 above) and the avoided refrigerant emissions associated with each outcome. 

Expected benefits were estimated in the model in a disaggregated manner, distinguishing between 

equipment sectors, types, sizes, and refrigerant type.

Model Facility Assumptions. To estimate expected benefits per model facility, the expected avoided

refrigerant emissions per model equipment type (as described above) were multiplied by the number of 

each type of equipment per facility and the percentage of each type of equipment assumed to 

experience leaks above the proposed rule’s threshold rate (see Table 17 above). In the final step, the 

expected avoided refrigerant emissions per model facility were multiplied by the total number of 

facilities in each industry category and the percentage of each industry assumed to be affected. These 

calculations yield aggregate benefits for the U.S. as a whole. More detailed assumptions about model 

facilities are summarized above in Section 3.1.1.4.

3.3.1.2. Future Annual Benefits of Leak Inspection and Repair

The analysis described above estimates one-year benefits based on the current distribution of ODS and 

HFC equipment in use. However, because the use of HFCs and ODS will change over the next decade due 

to multiple factors, including the continued phase-out of ODS systems and EPA’s rulemaking, Protection 

of Stratospheric Ozone: Change of Listing Status for Certain Substitutes under the Significant New 
48 August 26, 2015

Alternatives Policy Program (Status Change Rule) (80 FR 42869), benefits for the proposed regulatory 

changes to the Program will also change. Future benefits were estimated using a model equipment, 

facility, and entity approach. Benefits were then scaled up industry-wide based on the total number of 

affected equipment anticipated for two points in the future: 2020 and 2025. 

In order to simplify the process of determining the number of affected equipment and the benefits of 

leak repair in 2020 and 2025, several assumptions were made:

 Equipment used in 2020 and 2025 is assumed to have the same leak rates and charge sizes as 

equipment today.

 The same proportion of standard repairs, extension requests, and retrofit/retirements are assumed

for 2020 and 2025.

 The affected ODS and HFC equipment in 2013 is assumed to grow according to the growth rate, 

lifetime, and transitions in EPA’s Vintaging Model—with the adjustments described below. 

Growth in stock of HFC equipment was slightly adjusted to ensure that the analysis accurately reflects 

other rulemakings that affect the same equipment sectors. EPA’s Status Change Rule makes certain 

HFCs unacceptable for use in some of the equipment affected by the Program, specifically commercial 

refrigeration equipment (i.e., rack systems and condensing units). Benefits from the transition away 

from HFCs were quantified and presented in EPA’s analysis Climate Benefits of the SNAP Program Status 

Change Rule (Docket No. EPA-HQ-OAR-2014-0198-0239). In order to avoid double-counting benefits, 

this analysis assumes that HFC commercial refrigeration equipment begins transitioning away from HFCs 

in accordance with the “most likely” transition scenario presented in the Benefits Analysis for the Status 

Change Rule. 

Equipment-specific average ODP and GWP values were also updated to reflect the specific mix of ODS 

and HFC refrigerants assumed in 2020 and 2025. Benefits on a per-equipment basis were then 

calculated in the same manner outlined in Section 3.3.1.1 and were multiplied by the estimated affected 

equipment in 2020 and 2025 described above. 

3.3.2. Emission Reductions Benefits of Installing Self-sealing Valves on Small 

Cans

3.3.2.1. Annual Benefits of Installing Self-sealing Valves on Small Cans

The following equation was used to calculate annual emissions avoided from the installation of selfsealing valves on DIY small cans:

( − ) ×  ×  × 0.00045359 ×  = 

Where: 
49 August 26, 2015

 = Annual sales of R-134a small cans to DIY market in United States; assumed to be 

approximately 14 million

 = Annual sales of R-134a small cans to DIY market in California; assumed to be 

approximately 1.8 million

 = Charge size per small can (0.75 lbs.)

 = Percent of initial mass contained in the can that is directly emitted during the 

charging procedure (i.e., servicing loss rate); assumed to be 11%

0.00045359 = Factor used to convert from lbs. to MT

 = Global warming potential of R-134a; assumed to be 1,430

 = Annual avoided emissions (MTCO2eq.)

As a first step in the calculation, the number of R-134a small cans that are sold annually to the DIY 

market in the United States and California were estimated based on data from NPD Automotive 

Aftermarket Industry Monitor (NPD 2008; CARB 2009b). Small cans sold to the DIY market in California 

were excluded from this analysis since they already have self-sealing valves per CARB regulations. Then, 

the amount of refrigerant sold annually to the DIY market (excluding sales in California) was calculated 

assuming that each small can contains 12 ounces of refrigerant (0.75 lbs.). 

To estimate the total mass of refrigerant that would have been directly emitted during the DIY charging 

procedure without a self-sealing valve, it was assumed that 11% of the total initial mass is directly 

emitted to the environment during the DIY charging procedure (CEP-Armines 2008). The inclusion of a 

self-sealing valve is expected to reduce release during service to negligible levels, and thus, for the 

purposes of this analysis, it was assumed that 100% of the refrigerant emitted during servicing is 

prevented by the valve. Emissions from the can heel are conservatively assumed to remain the same as 

cans without a self-sealing valve, and therefore are excluded from the benefits analysis. The heel that 

remains in the can may be emitted to the environment during extended storage periods or when 

landfilled (Zhan et al. 2014). As a last step, the total mass of refrigerant loss prevented by the selfsealing valve was converted to metric tons of carbon dioxide equivalent (MTCO2eq.) assuming a GWP of 

1,430 from IPCC’s fourth assessment report (AR4). 

Although this analysis conservatively assumes that self-sealing valves will only negate emissions from 

servicing losses, there also may be emission benefits associated with the can heel. Having a self-sealing 

valve would likely change the percentage and number of cans used per recharge, but no data are 

available to quantify this effect at this time.

3.3.2.2. Future Annual Benefits of Self-sealing Valves

The analysis described above estimates one-year benefits based on the current number of R-134a small 

cans that are sold annually to the DIY market. However, due to recent rulemakings, including 1) the joint 

rulemaking issued by EPA and the National Highway Traffic Safety Administration (NHTSA) to establish 

light-duty vehicle (LDV) GHG emission standards and Corporate Average Fuel Economy (CAFE) Standards 

and 2) EPA’s Status Change Rule (80 FR 42869), the amount of R-134a refrigerant sold to the DIY market 
50 August 26, 2015

is expected to decline over the next decade. As a result, the estimated benefits for this proposed 

regulatory requirement are also expected to decline. 

To estimate the future benefits, current benefits were scaled down based on the Vintaging Model’s 

projected stock of R-134a MVAC units in years 2020 and 2025. The Vintaging Model’s projected stock of 

R-134a MVAC units incorporates assumptions from the Technical Support Document for EPA/NHTSA’s 

final rule, which assumes that in 2017 20% of the U.S. market will adopt alternative MVAC systems, and 

that in each subsequent year the market penetration will increase an additional 20%, reaching 100% by 

2021 (EPA/NHTSA 2012). This analysis assumes that as the market transitions to alternative MVAC 

systems, DIYers are more likely to have their vehicles serviced by a certified technician.

31

3.3.3. Extending Other Existing Requirements to HFCs and Other Substitutes: 

Implications for Benefits

While EPA is proposing specific practices to prevent release of HFCs and other substitute refrigerant, 

including but not limited to requiring refrigerant be recovered from small appliances, MVACs, and 

MVAC-like appliances before disposal, evacuation of refrigerant before opening an appliance for 

servicing, and reclamation of refrigerant to industry standards before sale for use, EPA has not 

calculated any of the benefits that would accrue if compliance were to increase as a result of this 

rulemaking.

As noted above in Section 3.1.4, this assumption seems reasonable because anyone handling HFC and 

other substitute refrigerants already must comply with the venting prohibition, which effectively 

necessitates similar practices to ensure refrigerant is not released into the environment. This 

assumption is supported by feedback from numerous regulated entities both in the public and private 

sector that most in industry treat HFCs and ODS refrigerants the same way to comply with the venting 

prohibition. Assuming no additional benefits also results in a conservative assessment of the benefits of 

this rule.

 

31 The analysis does not estimate changes in benefits that might be associated with DIY servicing of MVAC systems containing 

R-1234yf. DIY small cans containing this substitute are currently not available due in part to the need for unique fittings. If

such technology is developed in future, emissions are assumed to be negligible due to the low GWP of R-1234yf (i.e., 4).
51 August 26, 2015

4. Aggregate Economic Impact Analysis

This section summarizes the estimated impacts on the entire U.S. economy associated with the Agency’s 

proposed regulatory changes to Section 608 of the CAA. These results were generated for the industries 

and equipment types characterized in Section 2, using the modeling approach and methodology 

described in Section 3. All costs and savings are provided in 2014 dollars.

To provide a full range of costs, savings, and benefits estimates, Appendix A presents the results of 

several sensitivity analyses across different assumption dimensions:

 Appendix A.1: CARB distribution of ODS and HFC refrigerants by equipment type, rather than 

Vintaging Model.

 Appendix A.2: 200 pound threshold for annual and quarterly leak inspection for CR and IPR 

equipment, rather than 500 pounds.

 Appendix A.3: Higher post-repair leak rates set at 90% of the threshold leak rate (e.g., if the 

threshold rate is 20%, it is assumed that the system is repaired and has a resulting leak rate of 18%), 

rather than the rates in Table 14.

 Appendix A.4: 3% discount rate, rather than 7%.

 Appendix A.5: Leak repairs are conducted two weeks earlier, rather than three weeks.

 Appendix A.6: Leak repairs are conducted two months earlier, rather than three weeks.

 Appendix A.7: Lower threshold leak rates of 5% for CC and 15% for CR and IPR, rather than 10% for 

CC and 20% for CR and IPR.

 Appendix A.8: Higher IPR threshold leak rates of 15% for CC, 25% for CR, and 30% for IPR, rather 

than 10% for CC and 20% for CR and IPR.

4.1. Annual Compliance Costs

EPA’s proposed changes to the Section 608 regulations are expected to result in annual compliance 

costs of approximately $63 million, as shown in Table 22. This amount includes new compliance costs of 

approximately $113 million associated with the proposed rulemaking, as well as avoided compliance 

costs of approximately $50 million associated with the proposed removal of some existing regulatory 

requirements and provision of additional flexibility that are expected to reduce regulatory burden. 

Table 22. Annual Compliance Costs by Rule Component (2014$)

Rule Component

Compliance Costs

HFC ODS TOTAL
52 August 26, 2015

Rule Component Compliance Costs

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000

Leak Repair

CC $5,046,000 -$38,191,000 -$33,145,000

CR $1,709,000 -$10,137,000 -$8,428,000

IPR $494,000 $39,000 $533,000

Reporting & Recordkeeping $11,304,000 $5,789,000 $17,093,000

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000

Total $60,809,000 $1,858,000 $62,668,000

Totals may not sum due to independent rounding.

More detailed results tables for reporting and recordkeeping can be found in Appendix B.

4.2. Annual Refrigerant Savings

Total annual operating savings associated with reduced refrigerant use are estimated to be $52 million. 

Table 23 below shows the annual savings by rule component. As noted in Section 3.1.1, the combination 

of proposed leak repair and inspection requirements is expected to result in refrigerant savings for 

system owners or operators due to earlier leak repair action. 

Table 23. Total Annual Refrigerant Savings (2014$), Compliance Costs, and Combined Annual Compliance

Costs and Refrigerant Savings

Rule Component

Annual Refrigerant Savings Compliance 

Costs

Combined Annual 

Refrigerant Savings and 

HFC ODS Compliance Costs Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. - - - $34,231,000 $34,231,000

CR and IPR ≥500 lbs. - - - $49,314,000 $49,314,000

Leak Repair

CC -$15,977,000 -$20,221,000 -$36,198,000 -$33,145,000 -$69,343,000

CR -$4,130,000 -$7,514,000 -$11,644,000 -$8,428,000 -$20,072,000

IPR -$2,074,000 -$2,240,000 -$4,314,000 $533,000 -$3,781,000

Reporting & Recordkeeping - - - $17,093,000 $17,093,000

Self-sealing Valves on Small Cans - - - $3,070,000 $3,070,000

Total -$22,181,000 -$29,975,000 -$52,156,000 $62,668,000 $10,512,000

Totals may not sum due to independent rounding.
53 August 26, 2015

4.3. Annual Emission Reduction Benefits

The Agency’s proposed regulatory changes to Section 608 of the CAA are expected to reduce both GHG 

and ODS emissions. Total annual GHG emissions avoided in 2015 from the proposed regulatory changes 

are expected to be approximately 7.5 MMTCO2eq. Total ODS emissions avoided from the proposed 

regulatory changes are expected to be 116 ODP-weighted MT.

Table 24 below shows the annual GHG and ODS emissions avoided from HFC and ODS refrigerants by 

rule component. 

Table 24. Annual GHG and ODS Emissions Avoided in 2015

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 1,425,000 2,487,000 3,912,000 78 

CR 1,246,000 1,077,000 2,323,000 30 

IPR 381,000 250,000 630,000 8 

Reporting & Recordkeeping - - - -

Self-sealing Valves on Small Cans 657,000 - 657,000 -

Total 3,709,000 3,814,000 7,522,000 116 

Totals may not sum due to independent rounding.

4.4. Looking Forward: Emission Reduction Benefits in 2020 and 2025

Leak inspection and repair. The distribution of ODS and HFC equipment in use is anticipated to change 

significantly over the next decade, resulting in different leak inspection and repair benefits for 2020 and 

2025. 

Self-sealing valves on small cans. The number of R-134a small cans sold annually to the DIY market is 

also expected to change over the next decade, resulting in different benefits for 2020 and 2025. 

Table 25 and Table 26 below show the annual GHG emissions avoided from HFC and ODS refrigerants by 

rule component.

Table 25. Annual GHG Emissions Avoided in 2020 (MTCO2eq.)

Rule Component

2020

HFC ODS Total

Leak Inspection and Repair

CC 2,382,000 1,316,000 3,698,000 
54 August 26, 2015

Rule Component 2020

CR 1,902,000 769,000 2,671,000 

IPR 723,000 255,000 978,000 

Self-Sealing Valves on DIY Small Cans 537,000 0 537,000 

Total 5,544,000 2,340,000 7,884,000 

Totals may not sum due to independent rounding.

Table 26. Annual GHG Emissions Avoided in 2025 (MTCO2eq.)

Rule Component

2025

HFC ODS Total

Leak Inspection and Repair

CC 3,367,000 526,000 3,893,000 

CR 2,286,000 440,000 2,726,000 

IPR 927,000 224,000 1,151,000 

Self-Sealing Valves on DIY Small Cans 339,000 0 339,000 

Total 6,919,000 1,190,000 8,109,000 

Totals may not sum due to independent rounding.

Total ODS emissions avoided from the proposed leak repair regulatory changes in 2020 are expected to 

be 80 ODP-weighted MT and in 2025 are expected to be 44 ODP-weighted MT. Table 27 below shows 

the range of annual ODS emissions avoided by rule component.

Table 27. Annual ODS Emissions Avoided in 2020 and 2025 (ODP-weighted MT)

Rule Component

2020 2025

ODS ODS

Leak Inspection and Repair

CC 48 23

CR 23 13

IPR 8 8

Total 80 44

Totals may not sum due to independent rounding.

4.5. Other Benefits

The Agency’s proposed changes to Section 608 of the CAA may result in other economic, health, and 

environmental benefits that are not quantified or monetized in this conservative analysis. Some of these 

potential benefits include the following:
55 August 26, 2015

Energy savings from leak repair. In addition to the financial impacts associated with replacing 

refrigerant from leaking systems, refrigeration and air-conditioning equipment may operate poorly 

when the charge is too low, resulting in higher energy costs. System performance is dependent on the 

charge level in the system and an undercharged system can use significantly more energy than an 

optimally charged one (Cowan, et al. 2010). Energy savings would also take place when leaking, 

inefficient systems are replaced with new, more energy-efficient systems. This analysis does not 

quantify the benefits of improved equipment performance from leak repair and 

retirement/replacement, although these benefits could be significant.

Reporting and recordkeeping. Emissions benefits associated with proposed changes to reporting and 

recordkeeping were not estimated. However, these requirements are anticipated to result in improved 

compliance with the Section 608 requirements, particularly for leak inspection, leak repair, and proper 

refrigerant recovery upon disposal of appliances. In addition, reporting and recordkeeping may 

encourage better equipment management practices, which could lead to faster repairs and better 

maintenance, and consequently reduced expense to system owners and increased environmental 

benefits.

Benefits associated with the proposed recordkeeping requirement for disposing of field-installed 

appliances with charge sizes between 5 and 50 pounds were also not estimated. However, it is assumed 

that this new requirement will address a significant portion of potential emissions during equipment 

disposal. Based on estimates from EPA’s Vintaging Model, the stock of refrigerant contained in fieldinstalled appliances with charge sizes between 5 and 50 pounds that are disposed of annually contain a 

total of 27,300 MT of refrigerant (49.5 million MTCO2eq., 960 ODP-weighted MT), representing 45% of 

the total amount of HCFC and HFC refrigerants charged into all appliances being disposed annually (EPA 

2014).

Extending servicing practice disposal requirements to substitutes. This analysis assumes servicing and 

disposal practices for HFCs and other substitutes are similar to those required for ODS refrigerants in 

order to comply with the venting prohibition. Extending these explicit requirements to HFCs and other 

substitutes could result in better compliance with the existing regulations for ODS appliances. 

Additionally, consistent standards for all refrigerants (except those that are exempt from the venting 

prohibition) should increase compliance, resulting in more benefits than are estimated in this analysis.

Human health benefits. Ozone depletion, caused by the release of CFCs and HCFCs, is associated with 

many adverse health effects, including melanoma skin cancer, non-melanoma skin cancers (e.g., basal 

cell carcinoma and squamous cell carcinoma), and cataracts. Reducing ODS emissions through the 

proposed regulatory changes to the Program will reduce the damages associated with ozone 

depletion.32

 

32 Human health benefits from reducing ODS emissions have historically been estimated using EPA’s Atmospheric Health Effects 

Framework (AHEF) model. 
56 August 26, 2015

Materials and crop damage and ecological benefits. Some materials, such as polymers, are susceptible 

to photodegradation when exposed to ultraviolet (UV)B radiation. UVB radiation has also been shown to 

reduce crop yields. Other ecological effects of UV radiation can include impacts on recreational fishing, 

forests, overall marine ecosystems, and some plant types (EPA 1999). A reduction in UV radiation would 

extend the life of these materials and resources and result in physical and economic benefits (EPA 2011). 

5. Small Entities Impact Analysis

This screening analysis finds that the proposed rulemaking can be presumed not to have a significant 

economic impact on a substantial number of small entities (SISNOSE), as described below. This section

describes the decision matrix used to make this determination and the aggregated small business 

impacts.

5.1. Decision Matrix for Determining Significant Economic Impact on a 

Substantial Number of Small Entities

This analysis uses the matrix shown in Table 28 to determine whether this rulemaking would impose a 

SISNOSE. The economic threshold levels are set conservatively at 1% and 3% of sales, consistent with 

similar analyses of other Clean Air Act Title VI rules. These thresholds are set conservatively because the 

proposed rulemaking affects small businesses in a range of different industries, which may have 

significantly different profit margins and abilities to pass compliance costs along to customers. Based on 

this decision matrix, this screening analysis finds that the proposed rulemaking can be presumed to have 

no SISNOSE.

Table 28. Decision Matrix for Certifying SISNOSE

Economic Impact

Number of Small Entities 

Subject to the Rule and 

Experiencing Given 

Economic Impact

Percent of All Small 

Entities Subject to the Rule 

That Are Experiencing 

Given Economic Impact

Certification Category

Less than 1% for all 

affected small entities Any number Any percent Presumed No SISNOSE 

1% or more for one or 

more affected small 

entities

Fewer than 100 Less than 20 percent Presumed No SISNOSE 

Fewer than 100 20% or more Uncertain – No 

Presumption

Between 100 and 999 Less than 20% Presumed No SISNOSE

Between 100 and 999 20% or more Uncertain – No 

Presumption

1000 or more Any percent Uncertain – No 

Presumption 

Greater than 3% for one 

or more affected small 

entities

Fewer than 100 Less than 20% Presumed No SISNOSE

Fewer than 100 20% or more Uncertain – No 

Presumption
57 August 26, 2015

Economic Impact

Number of Small Entities 

Subject to the Rule and 

Experiencing Given 

Economic Impact

Percent of All Small 

Entities Subject to the Rule 

That Are Experiencing 

Given Economic Impact

Certification Category

Between 100 and 999 Less than 20% Uncertain – No 

Presumption

Between 100 and 999 20% or more Presumed Ineligible for 

Certification

1000 or more Any percent Presumed Ineligible for 

Certification

5.2. Aggregate Small Business Impacts of Proposed Regulatory 

Changes

As shown in Table 29, an estimated 950,500 small businesses may be subject to the proposed regulatory 

actions. Appendix C shows small businesses potentially affected at the NAICS code level.

Table 29. Summary of the Small Business Impact

Industry Estimated Number of Small 

Businesses Affected by the Rule

Grocery and Specialty Food Stores 64,220 

Warehouse Clubs and Supercenters 30 

Agriculture and Crop Support Services 3,780 

Utilities 580 

Food manufacturing 38,230 

Beverage and Ice Manufacturing 4,530 

Non-food Manufacturing 58,120 

General Merchandise Stores 2,960 

Refrigerated Warehousing and Storage 580 

Other Warehousing, Storage, and Transportation 3,680 

Non-durable Goods Wholesalers and Dealers 43,140 

Durable Goods Wholesalers and Dealers 105,770 

Educational Services 1,420 

Hospitals 90 

Research and Development 820 

Office Buildings 128,980 

Arts, Entertainment, and Recreation 2,250 
58 August 26, 2015

Industry Estimated Number of Small 

Businesses Affected by the Rule

Reclaimers 50 

Disposal Establishments 340 

Service Establishments 2,180 

Refrigerant Wholesalers 193,120 

Service Technicians 295,590 

Small Can Manufacturers 5 

Total 950,490 

Totals may not sum due to independent rounding.

To analyze the economic impacts on small businesses against the SISNOSE decision matrix, a “sales test” 

was applied, which calculates annualized compliance costs33 as a percentage of annual sales for 

businesses in each NAICS code by size category. For industries for which annual sales data were not 

available through the Economic Census, annual receipts or annual value of shipments34 was used as a

proxy.

Table 30 aggregates the estimated economic impacts on small businesses, according to the categories 

set out in the SISNOSE decision matrix and using a 7% discount rate.

35 Using the decision criteria 

established in Table 28, this screening analysis suggests that this rulemaking can be presumed to have 

no SISNOSE for the following reasons:

 About 944,000 small businesses (99%) are estimated to incur compliance costs that will be less than 

1% of annual sales.

 Approximately 150 of the approximately 950,500 affected small businesses—or less than 0.02%—

could incur costs in excess of 1% of annual sales and that fewer than 80 small businesses—or less 

than 0.01%—could incur costs in excess of 3% of annual sales. These estimates are below the 

thresholds for a substantial number determination (i.e., between 100 and 999 entities and less than 

20% of affected entities).

 

33 Total economic impact includes incremental compliance costs for leak repair and inspection, as well as compliance costs for 

reporting and recordkeeping and self-sealing valves on small cans. Avoided compliance costs associated with ODS equipment

retirements avoided and refrigerant savings were not included.

34 Total value of shipments includes the received or receivable net selling values of all products shipped (excluding freight and 

taxes).

35 A sensitivity analysis showing the aggregated economic impacts on small entities using a 3% discount rate can be found in 

Appendix D.
59 August 26, 2015

Table 30. Aggregated Economic Impacts on Small Businesses

Economic Impact Industry

Number of Small Entities 

Subject to the Rule and 

Experiencing Given Economic 

Impact

Percent of All Small 

Entities Subject to the 

Rule That are Experiencing 

Given Economic Impact

Less than 1% for 

all affected small 

entities a

Agriculture and Crop Support Services 3,780

Grocery & Specialty Food Stores 64,160

Warehouse Clubs & Supercenters 10

Utilities 560

Food Manufacturing 37,840

Beverage & Ice Manufacturing 4,530

Non-food Manufacturing 57,800

General Merchandise Stores <5

Refrigerated Warehousing and Storage 520

Other Warehousing, Storage, and 

Transportation 3,670

Non-durable Goods Wholesalers and 

Dealers 43,140

Durable Goods Wholesalers and 

Dealers 105,730

Educational Services 1,420

Hospitals 90

Research and Development 820

Office Buildings 128,510

Arts, Entertainment, and Recreation 2,250

Reclaimers 50

Refrigerant Wholesalers 193,120

Service Technicians 295,590

Small Can Manufacturers <5

Total 943,610 99%

1% or more for 

one or more 

affected small 

entities b

Agriculture and Crop Support Services <5

Grocery & Specialty Food Stores 40

Warehouse Clubs & Supercenters 20

Food Manufacturing 10

Beverage & Ice Manufacturing <5

Non-food Manufacturing 10

Other Warehousing, Stor, Trans. <5
60 August 26, 2015

Economic Impact Industry

Number of Small Entities 

Subject to the Rule and 

Experiencing Given Economic 

Impact

Percent of All Small 

Entities Subject to the 

Rule That are Experiencing 

Given Economic Impact

Non-durable Goods Wholesalers <5

Durable Goods Wholesalers 30

Research and Development <5

Office Buildings 20

Small Can Manufacturers <5

Total 150 0.02%

Greater than 3% 

for one or more 

affected small 

entities

Agriculture and Crop Support Services <5

Grocery & Specialty Food Stores 10

Warehouse Clubs & Supercenters 20

Food Manufacturing <5

Non-food Manufacturing <5

Other Warehousing, Stor, Trans. <5

Durable Goods Wholesalers 20

Office Buildings 20

Total 80 0.01%

Totals may not sum due to independent rounding.

a

Represents small entities affected with an economic impact equal to or lesser than 1% but greater than 0%. 

b This category aggregates the number of small entities that would be expected to experience an impact of 1% to 3% with the 

number of small entities that would be expected to experience an impact of 3% or greater.

6. Statutory and Executive Order Impact Analyses

This section summarizes the screening analyses that were conducted to meet the relevant statutory and 

administrative requirements imposed by Congress and the Executive Office, including EOs 12866, 13132, 

13045, and 12898; the RFA; and the UMRA.

EO 12866: Regulatory Planning and Review. The total annual economic impact of the proposed 

regulatory changes is expected to be approximately $63 million, which is below the $100 million 

threshold for an economically “significant regulatory action.” 

UMRA. The proposed rulemaking is not expected to result in expenditures

36 by State, local, and tribal 

governments, in the aggregate, or by the private sector, of $100 million or more in any one year. The 

 

36 Section 421(3)(D)(ii) of UMRA specifies that direct costs should not include “expenditures to the extent that such 

expenditures will be offset by any direct savings to the State, local, and tribal governments or by the private sector as a result 

of—(I) compliance with the Federal mandate; or (II) other changes in Federal law or regulation that are enacted or adopted in 

the same bill or joint resolution or proposed or final Federal regulation and that govern the same activity as is affected by the

Federal mandate.”
61 August 26, 2015

estimated aggregate expenditures associated with the proposed rulemaking are approximately $63 

million.

RFA. This screening analysis finds that the proposed rulemaking can be presumed to have no significant 

economic impact on a substantial number of small entities (SISNOSE) for the following reasons:

 About 944,000 small businesses (99%) are estimated to incur compliance costs that will be less than 

1% of annual sales.

 Approximately 150 of the approximately 950,500 affected small businesses—or less than 0.02%—

could incur costs in excess of 1% of annual sales, and that fewer than 80 small businesses—or less 

than 0.01%—could incur costs in excess of 3% of annual sales. These estimates are below the 

thresholds for a substantial number determination (i.e., between 100 and 999 entities, and less than 

20% of affected entities).

7. Conclusions

This screening analysis found the total annual compliance costs of EPA’s proposed regulatory changes to 

Section 608 to be approximately $63 million. These costs are below the $100 million adverse impact 

threshold set by EO 12866. Emission reduction benefits of the proposed rulemaking are approximately 

7.5 MMTCO2eq (from both ODS and HFC refrigerants), and 116 ODP-weighted MT. 

The RFA screening analysis found that the Agency’s proposed changes will impact an estimated 950,000 

small businesses, with only 0.01% of the small businesses subject to the rulemaking experiencing net 

costs of 1% or more of annual sales.
62 August 26, 2015

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A-1 August 26, 2015

Appendix A. Sensitivity Analyses for Aggregate Economic Analysis

A.1. Aggregate Economic Analysis with CARB ODS and HFC Equipment Distribution

The following tables show the impact on the results of using the CARB distribution for ODS versus HFC equipment rather than the Vintaging 

Model.

Table 31: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with CARB ODS and HFC Equipment Distribution 

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $6,067,000 -$36,180,000 -$30,113,000 -$12,091,000 -$17,337,000 -$29,427,000

CR $1,683,000 -$11,946,000 -$10,262,000 -$3,081,000 -$8,806,000 -$11,887,000

IPR $379,000 $49,000 $428,000 -$1,963,000 -$2,586,000 -$4,549,000

Reporting & Recordkeeping $11,320,000 $5,772,000 $17,092,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $61,705,000 $2,053,000 $63,760,000 -$17,135,000 -$28,729,000 -$45,863,000
A-2 August 26, 2015

Table 32: . Annual GHG and ODS Emissions Avoided with CARB ODS and HFC Equipment Distribution 

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 1,742,000 2,134,000 3,876,000 67

CR 1,030,000 1,238,000 2,269,000 36

IPR 306,000 276,000 582,000 9

Reporting & Recordkeeping - - - -

Self-sealing Valves on Small Cans 657,000 - 657,000 -

Total 3,735,000 3,648,000 7,384,000 112
A-3 August 26, 2015

A.2. Aggregate Economic Analysis with 200-pound Annual Leak Inspection Threshold

The following table show the impact on results associated with a 200-pound threshold for annual leak inspection of CR and IPR, rather than 500 

pounds (i.e., CR and IPR equipment containing less than 200 pounds receive annual leak inspections and CR and IPR equipment containing 200 or 

more pounds of refrigerant receive quarterly leak inspections). This sensitivity analysis did not affect the estimated annual GHG and ODS 

emissions avoided.

Table 33: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 200-pound Annual Leak Inspection Threshold

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-200 lbs. $14,073,000 $13,578,000 $27,651,000 - - -

CR and IPR ≥200 lbs. $35,123,000 $40,512,000 $75,636,000 - - -

Leak Repair

CC $5,046,000 -$38,191,000 -$33,145,000 -$15,977,000 -$20,221,000 -$36,198,000

CR $1,709,000 -$10,137,000 -$8,428,000 -$4,130,000 -$7,514,000 -$11,644,000

IPR $494,000 $39,000 $533,000 -$2,074,000 -$2,240,000 -$4,314,000

Reporting & Recordkeeping $12,055,000 $6,032,000 $18,087,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $71,570,000 $11,833,000 $83,404,000 -$22,181,000 -$29,975,000 -$52,156,000

A.3. Aggregate Economic Analysis with Higher Post-Repair Leak Rate

The following tables show the impact on results associated with higher post-repair leak rates set at 90% of the threshold leak rate (i.e., if the 

threshold rate is 20%, it is assumed that the system is repaired and has a resulting leak rate of 18%), rather than the rates in Table 14.
A-4 August 26, 2015

Table 34: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Higher Post-Repair Leak Rate 

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $5,046,000 -$38,191,000 -$33,145,000 -$8,374,000 -$10,573,000 -$18,947,000

CR $1,709,000 -$10,137,000 -$8,428,000 -$2,942,000 -$4,766,000 -$7,708,000

IPR $494,000 $39,000 $533,000 -$1,867,000 -$2,016,000 -$3,883,000

Reporting & Recordkeeping $11,304,000 $5,789,000 $17,093,000 - - -

Self-sealing Valves on Small 

Cans $3,070,000 - $3,070,000 - - -

Total $60,809,000 $1,858,000 $62,668,000 -$13,183,000 -$17,355,000 -$30,538,000

Table 35: . Annual GHG and ODS Emissions Avoided with Higher Post-Repair Leak Rate 

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 1,212,000 2,112,000 3,324,000 66

CR 842,000 859,000 1,701,000 24

IPR 310,000 203,000 513,000 7

Reporting & Recordkeeping - - - -

Self-sealing Valves on Small Cans 657,000 - 657,000 -

Total 3,021,000 3,174,000 6,195,000 97
A-5 August 26, 2015

A.4. Aggregate Economic Analysis with 3% Discount Rate

The following table show the impact on results associated with a 3% discount rate, rather than a 7% discount rate. This sensitivity analysis did 

not affect the estimated annual GHG and ODS emissions avoided.

Table 36: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 3% Discount Rate

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $2,437,000 -$18,705,000 -$16,268,000 -$15,977,000 -$20,221,000 -$36,198,000

CR $823,000 -$4,963,000 -$4,139,000 -$4,130,000 -$7,514,000 -$11,644,000

IPR $239,000 $17,000 $255,000 -$2,074,000 -$2,240,000 -$4,314,000

Reporting & Recordkeeping $11,304,000 $5,789,000 $17,093,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $57,059,000 $26,496,000 $83,556,000 -$22,181,000 -$29,975,000 -$52,156,000
A-6 August 26, 2015

A.5. Aggregate Economic Analysis with 2-week Leak Repair Improvement

The following tables show the impact on results associated with the assumption that leaks are detected and repaired two weeks faster as a 

result of the proposed rulemaking, rather than three weeks.

Table 37: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 2-week Leak Repair Improvement

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $4,886,000 -$38,444,000 -$33,558,000 -$10,651,000 -$13,481,000 -$24,132,000

CR $1,645,000 -$10,192,000 -$8,547,000 -$2,754,000 -$5,009,000 -$7,763,000

IPR $479,000 $26,000 $505,000 -$1,383,000 -$1,493,000 -$2,876,000

Reporting & Recordkeeping $11,304,000 $5,789,000 $17,093,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $60,570,000 $1,537,000 $62,108,000 -$14,788,000 -$19,983,000 -$34,771,000
A-7 August 26, 2015

Table 38: . Annual GHG and ODS Emissions Avoided with 2-week Leak Repair Improvement 

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 950,000 1,658,000 2,608,000 52

CR 831,000 718,000 1,549,000 20

IPR 254,000 166,000 420,000 5

Reporting & Recordkeeping - - - -

Self-sealing Valves on Small Cans 657,000 - 657,000 -

Total 2,692,000 2,542,000 5,234,000 78
A-8 August 26, 2015

A.6. Aggregate Economic Analysis with 2-month Leak Repair Improvement

The following tables show the impact on results associated with the assumption that leaks are detected and repaired two months faster as a 

result of the proposed rulemaking, rather than three weeks.

Table 39: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with 2-month Leak Repair Improvement

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $6,552,000 -$36,924,000 -$30,371,000 -$42,605,000 -$53,922,000 -$96,527,000

CR $2,262,000 -$9,864,000 -$7,602,000 -$11,014,000 -$20,037,000 -$31,051,000

IPR $636,000 $105,000 $741,000 -$5,531,000 -$5,972,000 -$11,503,000

Reporting & Recordkeeping $11,304,000 $5,789,000 $17,093,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $63,010,000 $3,464,000 $66,476,000 -$59,150,000 -$79,931,000 -$139,081,000
A-9 August 26, 2015

Table 40: . Annual GHG and ODS Emissions Avoided with 2-month Leak Repair Improvement 

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 3,799,000 6,633,000 10,432,000 209

CR 3,323,000 2,872,000 6,195,000 80

IPR 1,015,000 666,000 1,681,000 21

Reporting & Recordkeeping - - -

Self-sealing Valves on Small Cans 657,000 - 657,000

Total 8,794,000 10,171,000 18,965,000 311
A-10 August 26, 2015

A.7. Aggregate Economic Analysis with Lower Threshold Leak Rates

The following tables show the impact on results associated with lower threshold leak rates of 5% for CC and 15% for CR and IPR, rather than 10% 

and 20% respectively.

Table 41: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Lower Threshold Leak Rates

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $5,463,000 -$38,130,000 -$32,666,000 -$10,475,000 -$21,581,000 -$32,055,000

CR $2,007,000 -$10,109,000 -$8,102,000 -$3,568,000 -$7,587,000 -$11,155,000

IPR $548,000 $43,000 $591,000 -$2,465,000 -$2,410,000 -$4,875,000

Reporting & Recordkeeping $11,316,000 $5,805,000 $17,120,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $61,590,000 $1,967,000 $63,558,000 -$16,508,000 -$31,578,000 -$48,085,000
A-11 August 26, 2015

Table 42: Annual GHG and ODS Emissions Avoided with Lower Threshold Leak Rates 

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 1,509,000 2,648,000 4,157,000 83

CR 1,332,000 1,091,000 2,423,000 30

IPR 404,000 270,000 674,000 9

Reporting & Recordkeeping - - - -

Self-sealing Valves on Small Cans 657,000 - 657,000 -

Total 3,902,000 4,009,000 7,911,000 122
A-12 August 26, 2015

A.8. Aggregate Economic Analysis with Higher Threshold Leak Rates

The following tables show the impact on results associated with threshold leak rates of 15% for CC, 25% for CC, and 30% for IPR, rather than 10%

for CC, and 20% for CC and IPR. 

Table 43: Annual Compliance Costs and Total Annual Refrigerant Savings (2014$) with Higher Threshold Leak Rates

Rule Component

Annual Compliance Costs Annual Refrigerant Savings

HFC ODS Total HFC ODS Total

Leak Inspection

CC, CR, and IPR 50-500 lbs. $17,409,000 $16,822,000 $34,231,000 - - -

CR and IPR ≥500 lbs. $21,777,000 $27,536,000 $49,314,000 - - -

Leak Repair

CC $4,030,000 -$38,333,000 -$34,303,000 -$7,349,000 -$14,092,000 -$21,440,000

CR $1,419,000 -$10,164,000 -$8,745,000 -$3,415,000 -$7,417,000 -$10,833,000

IPR $359,000 $29,000 $389,000 -$1,915,000 -$1,870,000 -$3,786,000

Reporting & Recordkeeping $11,283,000 $5,761,000 $17,044,000 - - -

Self-sealing Valves on Small Cans $3,070,000 - $3,070,000 - - -

Total $59,347,000 $1,651,000 $61,000,000 -$12,679,000 -$23,379,000 -$36,059,000
A-13 August 26, 2015

Table 44: Annual GHG and ODS Emissions Avoided with Higher Threshold Leak Rates 

Rule Component

GHG Emissions Avoided 

(MTCO2eq)

ODS Emissions Avoided 

(ODP-weighted MT)

HFC ODS Total ODS

Leak Inspection and Repair

CC 1,136,000 1,833,000 2,970,000 57

CR 1,513,000 1,064,000 2,578,000 30

IPR 688,000 461,000 1,149,000 15

Reporting & Recordkeeping - - -

Self-sealing Valves on Small Cans 657,000 - 657,000

Total 3,994,000 3,358,000 7,354,000 101
B-1 August 26, 2015

Appendix B. Detailed Tables for Recordkeeping and Reporting

Table 45. Annual Compliance Costs for Recordkeeping and Reporting

Recordkeeping & 

Reporting Rule 

Component

Annual Direct Compliance Costs

Avoided

Compliance

Costs

Total 

Compliance

Costs

HFC ODS Total ODS

Reclaimer recordkeeping 

& reporting $27,000 - $27,000 - $27,000

Refrigerant wholesalers 

recordkeeping $6,498,000 - $6,498,000 - $6,498,000

Owners/operators of 

appliances w/charge 

sizes >50 lbs. maintain 

information on 

purged/destroyed 

refrigerant

<$100 - <$100 - <$100

Develop/maintain plan to 

retire/replace or retrofit 

equipment

- - - -$813,000 -$813,000

Owners/operators of 

appliances w/charge 

sizes >50 lbs. prepare & 

submit requests for 

extensions

$49,000 $55,000 $104,000 - $104,000

Recordkeeping 

associated with leak 

inspection and repair

$4,301,000 $1,616,000 $5,917,000 - $5,917,000

New recordkeeping 

requirement for 5-50 lb. 

appliances

$430,000 $5,049,000 $5,479,000 - $5,479,000

New recordkeeping 

requirement for small 

can manufacturers

<$100 - <$100 - <$100

Removal of requirement 

for certification for 

acquisition of 

recovery/recycling 

equipment

- - - -$118,000 -$118,000

Total $11,304,000 $6,720,000 $18,025,000 -$931,000 $17,093,000

Totals may not sum due to independent rounding.
C-1 August 26, 2015

Appendix C. Detailed Tables for SISNOSE Analysis 

Table 46: Estimated Number of Small Businesses Affected by NAICS Code

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

Agriculture 

and Crop 

Support 

Services

115112 Soil Preparation, Planting, and Cultivating 2,491

115113 Crop Harvesting, Primarily by Machine 383

115114 Postharvest Crop Activities (except Cotton Ginning) 908

Utilities

221111 Hydroelectric Power Generation 5

221112 Fossil fuel electric power generation 15

221113 Nuclear Electric Power Generation 2

221114 Solar Electric Power Generation 3

221115 Wind Electric Power Generation 3

221116 Geothermal Electric Power Generation 0

221117 Biomass Electric Power Generation 2

221118 Other Electric Power Generation 5

221121 Electric Bulk Power Transmission and Control 2

221122 Electric Power Distribution 79

221210 Natural Gas Distribution 18

221310 Water Supply and Irrigation Systems 153

221320 Sewage Treatment Facilities 15

221330 Steam and Air-conditioning Supply 2

211111 Crude Petroleum and Natural Gas Extraction

280

Food 

Manufacturing

311111 Dog and Cat Food Manufacturing 379

311119 Other Animal Food Manufacturing 1,501

311211 Flour Milling 272

311212 Rice Milling 74

311213 Malt Manufacturing 32

311221 Wet Corn Milling 60

311224 Soybean and Other Oilseed Processing 161

311225 Fats and Oils Refining and Blending 167

311230 Breakfast Cereal Manufacturing 70

311313 Beet Sugar Manufacturing 29

311314 Cane Sugar Manufacturing 65
C-2 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

311340 Non-chocolate Confectionery Manufacturing 725

311351 Chocolate and Confectionery Manufacturing from 

Cacao Beans

266

311352 Confectionery Manufacturing from Purchased 

Chocolate

1,961

311411 Frozen Fruit, Juice, and Vegetable Manufacturing 227

311412 Frozen Specialty Food Manufacturing 620

311421 Fruit and Vegetable Canning 953

311422 Specialty Canning 191

311423 Dried and Dehydrated Food Manufacturing 263

311511 Fluid Milk Manufacturing 359

311512 Creamery Butter Manufacturing 41

311513 Cheese Manufacturing 650

311514 Dry, Condensed, and Evaporated Dairy Product 

Manufacturing

187

311520 Ice Cream and Frozen Dessert Manufacturing 581

311611 Animal (except Poultry) Slaughtering 2,467

311612 Meat Processed from Carcasses 2,052

311613 Rendering and Meat Byproduct Processing 183

311615 Poultry Processing 441

311710 Seafood Product Preparation and Packaging 854

311811 Retail Bakeries 11,455

311812 Commercial Bakeries 4,014

311813 Frozen Cakes, Pies, and Other Pastries Manufacturing 325

311821 Cookie and Cracker Manufacturing 516

311824 Dry Pasta, Dough, and Flour Mixes Manufacturing from 

Purchased Flour

616

311830 Tortilla Manufacturing 583

311911 Roasted Nuts and Peanut Butter Manufacturing 342

311919 Other Snack Food Manufacturing 506

311920 Coffee and Tea Manufacturing 710

311930 Flavoring Syrup and Concentrate Manufacturing 223

311941 Mayonnaise, Dressing, and Other Prepared Sauce 

Manufacturing

507
C-3 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

311942 Spice and Extract Manufacturing 566

311991 Perishable Prepared Food Manufacturing 1,075

311999 All Other Miscellaneous Food Manufacturing 955

Beverage and 

Ice 

Manufacturing

312111 Soft Drink Manufacturing 230

312112 Bottled Water Manufacturing 234

312113 Ice Manufacturing 341

312120 Breweries 931

312130 Wineries 2,796

Non-food 

Manufacturing

322121 Paper (except Newsprint) Mills 151

322211 Corrugated and Solid Fiber Box Manufacturing 887

322220 Paper Bag and Coated and Treated Paper 

Manufacturing

789

323111 Commercial Printing (except Screen and Books) 22,310

324110 Petroleum Refineries 87

325120 Industrial Gas Manufacturing 141

325180 Other Basic Inorganic Chemical Manufacturing 476

325211 Plastics Material and Resin Manufacturing 1,045

325320 Pesticide and Other Agricultural Chemical 

Manufacturing

174

325412 Pharmaceutical preparation manufacturing 1,076

325413 In-vitro diagnostic substance manufacturing 185

325414 Biological product (except diagnostic) manufacturing 209

325620 Toilet preparation manufacturing 901

325991 Custom compounding of purchased resins 390

325998 All other miscellaneous chemical product and 

preparation manufacturing

1,025

326122 Plastics pipe and pipe fitting manufacturing 311

326140 Polystyrene foam product manufacturing 316

326160 Plastics bottle manufacturing 185

326199 All other plastics product manufacturing 6,298

326211 Tire manufacturing (except retreading) 93

332431 Metal can manufacturing 80

332812 Metal coating, engraving (except jewelry and 

silverware), and allied services to manufacturers

2,558

332813 Electroplating, plating, polishing, anodizing, and 

coloring

2,580
C-4 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

333241 Food Product Machinery Manufacturing 451

333242 Semiconductor Machinery Manufacturing 165

333415

Air-conditioning and warm air heating equipment and 

commercial and industrial refrigeration equipment 

manufacturing

839

333611 Turbine and turbine generator set units manufacturing 227

334112 Computer storage device manufacturing 119

334419 Other Electronic Component Manufacturing 2,640

334413 Semiconductor and related device manufacturing 808

334510 Electromedical and electrotherapeutic apparatus 

manufacturing

689

334515 Instrument manufacturing for measuring and testing 

electricity and electrical systems

856

334516 Analytical laboratory instrument manufacturing 651

334613 Blank magnetic and optical recording media 

manufacturing

87

336411 Aircraft manufacturing 262

336415 Guided missile and space vehicle propulsion unit and 

propulsion unit parts manufacturing

21

339112 Surgical and medical instrument manufacturing 1,236

339999 All other miscellaneous manufacturing 6,804

Grocery and 

Specialty Food 

Stores

445110 Supermarkets and other grocery (except convenience) 

stores

47,513

445210 Meat markets 5,466

445230 Fruit and vegetable markets 3,027

445299 All other specialty food stores 4,624

722310 Food service contractors 3,593

Warehouse 

Clubs and 

Supercenters

452910 Warehouse clubs and supercenters

31

General 

Merchandise 

Stores

452112 Discount department stores 5

452990 All other general merchandise stores 1,166

453998 All other miscellaneous store retailers (except tobacco 

stores)

1,785

Refrigerated 

Warehousing 

and Storage

493120 Refrigerated warehousing and storage

577

Other 

Warehousing, 484220 Specialized freight (except used goods) trucking, local

2,086
C-5 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

Storage, and 

Transportation

488119 Other airport operations 84

488510 Freight transportation arrangement 1,060

488991 Packing and crating 88

493110 General warehousing and storage 276

493130 Farm product warehousing and storage 20

493190 Other warehousing and storage 63

Non-durable 

Goods 

Wholesalers 

and Dealers

424210 Drugs and druggists' sundries merchant wholesalers 7,084

424410 General line grocery merchant wholesalers 2,414

424420 Packaged frozen food merchant wholesalers 3,031

424430 Dairy product (except dried or canned) merchant 

wholesalers

1,770

424440 Poultry and poultry product merchant wholesalers 481

424460 Fish and seafood merchant wholesalers 2,076

424470 Meat and meat product merchant wholesalers 2,337

424480 Fresh fruit and vegetable merchant wholesalers 4,772

424490 Other grocery and related products merchant 

wholesalers

10,673

424590 Other farm product raw material merchant 

wholesalers

653

424710 Petroleum bulk stations and terminals 2,994

424810 Beer and ale merchant wholesalers 1,399

424930 Flower, nursery stock, and florists' supplies merchant 

wholesalers

3,461

Durable Goods 

Wholesalers 

and Dealers

423410 Photographic equipment and supplies merchant 

wholesalers

811

423740 Refrigeration equipment and supplies merchant 

wholesalers

727

423990 Other miscellaneous durable goods merchant 

wholesalers

9,338

441110 New Car Dealers 19,183

441120 Used Car Dealers 27,127

441210 Recreational Vehicle Dealers 2,777

441222 Boat Dealers 4,973

441228 Motorcycle, ATV, and All Other Motor Vehicle Dealers 6,012

441310 Automotive Parts and Accessories Stores 23,056

441320 Tire Dealers 11,766
C-6 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

Educational 

Services

611110 Elementary and second schools 1,281

611210 Junior Colleges 27

611310 College, universities, and professional schools 111

Hospitals 622110 General medical and surgical hospitals 92

Research and 

Development 54171 Research and development in the Physical, Engineering and Life Sciences

824

Office 

Buildings

511110 Newspaper Publishers 307

511120 Periodical Publishers 321

511130 Book Publishers 149

511140 Directory and Mailing List Publishers 48

511191 Greeting Card Publishers 6

511199 All Other Publishers 45

511210 Software Publishers 380

512110 Motion Picture and Video Production 834

512120 Motion Picture and Video Distribution 26

512131 Motion Picture Theaters (except Drive-Ins) 135

512132 Drive-In Motion Picture Theaters 17

512191 Teleproduction and Other Postproduction Services 132

512199 Other Motion Picture and Video Industries 21

512210 Record Production 25

512220 Integrated Record Production/Distribution 22

512230 Music Publishers 47

512240 Sound Recording Studios 113

512290 Other Sound Recording Industries 26

515111 Radio Networks 38

515112 Radio Stations 212

515120 Television Broadcasting 61

515210 Cable and Other Subscription Programming 23

517110 Wired Telecommunications Carriers 471

517210 Wireless Telecommunications Carriers (except 

Satellite)

144

517410 Satellite Telecommunications 35

51791 Other Telecommunications 256

518210 Data Processing, Hosting, and Related Services 485

519120 Libraries and Archives 143
C-7 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

522220 Sales Financing 153

522291 Consumer Lending 325

522292 Real Estate Credit 691

522293 International Trade Financing 16

522294 Secondary Market Financing 13

522298 All Other Nondepository Credit Intermediation 345

522310 Mortgage and Nonmortgage Loan Brokers 1,342

522320 Financial Transactions Processing, Reserve, and 

Clearinghouse Activities

146

522390 Other Activities Related to Credit Intermediation 362

524113 Direct Life Insurance Carriers 58

524114 Direct Health and Medical Insurance Carriers 47

524126 Direct Property and Casualty Insurance Carriers 242

524127 Direct Title Insurance Carriers 155

524128 Other Direct Insurance (except Life, Health and 

Medical) Carriers

29

524130 Reinsurance Carriers 13

524210 Insurance Agencies and Brokerages 7,967

524291 Claims Adjusting 238

524292 Third Party Administration of Insurance and Pension 

Funds

216

524298 All Other Insurance Related Activities 148

531110 Lessors of Residential Buildings and Dwellings 3,295

531120 Lessors of Nonresidential Buildings (except 

Miniwarehouses)

1,820

531130 Lessors of Miniwarehouses and Self Storage Units 628

531190 Lessors of Other Real Estate Property 571

531210 Offices of Real Estate Agents and Brokers 6,564

531311 Residential Property Managers 1,814

531312 Nonresidential Property Managers 874

531320 Offices of Real Estate Appraisers 1,059

531390 Other Activities Related to Real Estate 1,055

541110 Offices of Lawyers 11,062

541191 Title Abstract and Settlement Offices 655

541199 All Other Legal Services 182
C-8 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

541211 Offices of Certified Public Accountants 3,560

541213 Tax Preparation Services 1,019

541214 Payroll Services 252

541219 Other Accounting Services 2,295

541310 Architectural Services 1,546

541320 Landscape Architectural Services 420

541330 Engineering Services 2,968

541340 Drafting Services 202

541350 Building Inspection Services 377

541360 Geophysical Surveying and Mapping Services 64

541370 Surveying and Mapping (except Geophysical) Services 611

541380 Testing Laboratories 317

541410 Interior Design Services 893

541420 Industrial Design Services 121

541430 Graphic Design Services 1,095

541490 Other Specialized Design Services 136

541511 Custom Computer Programming Services 3,204

541512 Computer Systems Design Services 2,750

541513 Computer Facilities Management Services 204

541519 Other Computer Related Services 662

541611 Administrative Management and General 

Management Consulting Services

3,821

541612 Human Resources Consulting Services 882

541613 Marketing Consulting Services 1,628

541614 Process, Physical Distribution and Logistics Consulting 

Services

405

541618 Other Management Consulting Services 434

541620 Environmental Consulting Services 537

541690 Other Scientific and Technical Consulting Services 1,615

54171 Research and Development in the Physical, 

Engineering, and Life Sciences

775

541720 Research and Development in the Social Sciences and 

Humanities

149

541810 Advertising Agencies 852

541820 Public Relations Agencies 473

541830 Media Buying Agencies 52
C-9 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

541840 Media Representatives 125

541850 Outdoor Advertising 136

541860 Direct Mail Advertising 188

541870 Advertising Material Distribution Services 48

541890 Other Services Related to Advertising 513

541910 Marketing Research and Public Opinion Polling 297

541921 Photography Studios, Portrait 635

541922 Commercial Photography 266

541930 Translation and Interpretation Services 125

541940 Veterinary Services 1,747

541990 All Other Professional, Scientific and Technical Services 1,166

551111 Offices of Bank Holding Companies 38

551112 Offices of Other Holding Companies 328

561110 Office Administrative Services 1,638

561210 Facilities Support Services 100

56131 Employment Placement Agencies 511

561320 Temporary Help Services 800

561330 Professional Employer Organizations 278

561410 Document Preparation Services 319

561421 Telephone Answering Services 102

561422 Telemarketing Bureaus and Other contact Centers 138

561431 Private Mail Centers 356

561439 Other Business Service Centers (including Copy Shops) 198

561440 Collection Agencies 279

561450 Credit Bureaus 40

561491 Repossession Services 58

561492 Court Reporting and Stenotype Services 215

561499 All Other Business Support Services 212

561510 Travel Agencies 781

561520 Tour Operators 194

561591 Convention and Visitors Bureaus 66

561599 All Other Travel Arrangement and Reservation Services 107

561611 Investigation Services 312

561612 Security Guards and Patrol Services 367
C-10 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

561613 Armored Car Services 9

561621 Security Systems Services (except Locksmiths) 353

561622 Locksmiths 250

561710 Exterminating and Pest Control Services 700

561720 Janitorial Services 3,307

561730 Landscaping Services 5,994

561740 Carpet and Upholstery Cleaning Services 572

561790 Other Services to Buildings and Dwellings 781

561910 Packaging and Labeling Services 117

561920 Convention and Trade Show Organizers 262

561990 All Other Support Services 829

712110 Museums 309

712130 Zoos and Botanical Gardens 37

721110 Hotels (except Casino Hotels) and Motels 2,598

721120 Casino Hotels 8

813110 Religious Organizations 11,736

813211 Grantmaking Foundations 552

813212 Voluntary Health Organizations 167

813219 Other Grantmaking and Giving Services 192

813311 Human Rights Organizations 155

813312 Environment, Conservation and Wildlife Organizations 322

813319 Other Social Advocacy Organizations 372

813410 Civic and Social Organizations 1,796

813910 Business Associations 1,054

813920 Professional Organizations 405

813930 Labor Unions and Similar Labor Organizations 969

813940 Political Organizations 150

813990 Other Similar Organizations (except Business, 

Professional, Labor, and Political Organizations) 

1,389

92 Public Administration -

Arts, 

Entertainment, 

and Recreation

711310 Promoters of performing arts, sports, and similar 

events with facilities

205

713940 Fitness and recreational sports centers 2,046

Reclaimers

325120 Industrial Gas Manufacturing 1

423930 Recyclable Material Merchant Wholesalers 26
C-11 August 26, 2015

Industry NAICS Code and Definition

Estimated Number of 

Small Businesses 

Affected by the Rule

562920 Materials Recovery Facilities 3

562212 Solid Waste Landfill 2

424690 Other Chemical and Allied Products Merchant 

Wholesalers

22

Disposal 

Establishments

562920 Materials Recovery Facilities 32

562212 Solid Waste Landfill 24

423990 Other Miscellaneous Durable Goods Merchant 

Wholesalers

289

Service 

Establishments

811310 Commercial Industrial Machinery and Equipment (not 

Automotive and Electronic) Repair and Maintenance

1,800

811412 Appliance Repair and Maintenance 376

Refrigerant 

Wholesalers

325120 Industrial Gas Manufacturing 52

424690 Other Chemical and Allied Products Merchant 

Wholesalers

3,700

42 Wholesale Trade 189,364

Service 

Technicians 238220 Plumbing, heating, and air-conditioning contractors

295,592

Small Can 

Manufacturers

441310 Automotive Parts and Accessories Stores 2

325120 Industrial Gas Manufacturing 3

Total 950,486
Appendix D. Sensitivity Analysis for SBREFA

D.1. Aggregate Economic Analysis with 3% Discount Rate

The following table shows the impacts to small businesses associated with a 3% discount rate.

Table 47. Aggregated Economic Impacts on Small Businesses with 3% Discount Rate

Economic Impact Industry

Number of Small Entities 

Subject to the Rule and 

Experiencing Given Economic 

Impact

Percent of All Small 

Entities Subject to the 

Rule That are 

Experiencing Given 

Economic Impact

Less than 1% for 

all affected small 

entities a

Agriculture and Crop Support Services 3,780

Grocery & Specialty Food Stores 64,170

Warehouse Clubs & Supercenters 10

Utilities 560

Food Manufacturing 37,840

Beverage & Ice Manufacturing 4,530

Non-food Manufacturing 57,810

General Merchandise Stores <5

Refrigerated Warehousing and Storage 560

Other Warehousing, Storage, and Transportation 3,670

Non-durable Goods Wholesalers and Dealers 43,140

Durable Goods Wholesalers and Dealers 105,750

Educational Services 1,420

Hospitals 90

Research and Development 820

Office Buildings 128,510

Arts, Entertainment, and Recreation 2,250

Reclaimers 50

Refrigerant Wholesalers 193,120

Service Technicians 295,590

Small Can Manufacturers <5

Total 943,680 99%

1% or more for 

one or more 

Agriculture and Crop Support Services <5

Grocery & Specialty Food Stores 40
D-2 August 26, 2015

Economic Impact Industry

Number of Small Entities 

Subject to the Rule and 

Experiencing Given Economic 

Impact

Percent of All Small 

Entities Subject to the 

Rule That are 

Experiencing Given 

Economic Impact

affected small 

entities

Warehouse Clubs & Supercenters 20

Food Manufacturing 10

Non-food Manufacturing <5

Other Warehousing, Stor, Trans. <5

Durable Goods Wholesalers 20

Office Buildings 20

Small Can Manufacturers <5

Total 120 0.01%

Greater than 3% 

for one or more 

affected small 

entities b

Grocery & Specialty Food Stores 10

Warehouse Clubs & Supercenters 20

Non-food Manufacturing <5

Other Warehousing, Stor, Trans. <5

Durable Goods Wholesalers 10

Office Buildings 20

Total 60 0.01%

Totals may not sum due to independent rounding.

a

Represents small entities affected with an economic impact equal to or lesser than 1% but greater than 0%. 

b This category aggregates the number of small entities that would be expected to experience an impact of 1% to 3% with the 

number of small entities that would be expected to experience an impact of 3% or greater.
E-3 August 26, 2015

Appendix E. NAICS Codes

E.1. NAICS Classification for Leak Repair Requirements

Table 48: NAICS Codes Included in the Leak Repair Regulation Analysis

Sector 

Description NAICS Category NAICS Code NAICS Code Definition

Agriculture and 

Crop Support 

Activities

Support Activities for 

Agriculture and Forestry 

(115)

115112 Soil Preparation, Planting, and Cultivating

115113 Crop Harvesting, Primarily by Machine

115114 Postharvest Crop Activities (except Cotton Ginning)

Arts, 

Entertainment, 

and Recreation

Arts, Entertainment, and 

Recreation (71)

711310 Promoters of performing arts, sports, and similar events 

with facilities

713940 Fitness and recreational sports centers

Beverage and 

Ice 

Manufacturing

Beverage Manufacturing 

(312)

312111 Soft drink manufacturing

312112 Bottled water manufacturing

312113 Ice manufacturing

312120 Breweries

312130 Wineries

Durable Goods 

Wholesalers 

and Dealers

Merchant Wholesalers -

Durable Goods (423)

423410 Photographic equipment and supplies merchant 

wholesalers

423740 Refrigeration equipment and supplies merchant 

wholesalers

423990 Other miscellaneous durable goods merchant 

wholesalers

Motor Vehicle and Parts 

Dealers (441)

441110 New Car Dealers

441120 Used Car Dealers

441210 Recreational Vehicle Dealers 

441222 Boat Dealers

441228 Motorcycle, ATV, and All Other Motor Vehicle Dealers

441310 Automotive Parts and Accessories Stores

441320 Tire Dealers

Educational 

Services

Educational Services 

(611)

611110 Elementary and second schools

611210 Junior Colleges

611310 College, universities, and professional schools

Food 

Manufacturing

Food Manufacturing 

(311)

311111 Dog and Cat Food Manufacturing

311119 Other Animal Food Manufacturing
E-4 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

311211 Flour Milling

311212 Rice Milling

311213 Malt Manufacturing

311221 Wet Corn Milling

311224 Soybean and Other Oilseed Processing

311225 Fats and Oils Refining and Blending

311230 Breakfast Cereal Manufacturing

311313 Beet Sugar Manufacturing

311314 Cane Sugar Manufacturing

311340 Nonchocolate Confectionery Manufacturing

311351 Chocolate and Confectionery Manufacturing from Cacao 

Beans

311352 Confectionery Manufacturing from Purchased Chocolate

311411 Frozen Fruit, Juice and Vegetable Manufacturing

311412 Frozen Specialty Food Manufacturing

311421 Fruit and Vegetable Canning3

311422 Specialty Canning

311423 Dried and Dehydrated Food Manufacturing

311511 Fluid Milk Manufacturing

311512 Creamery Butter Manufacturing

311513 Cheese Manufacturing

311514 Dry, Condensed, and Evaporated Dairy Product 

Manufacturing

311520 Ice Cream and Frozen Dessert Manufacturing

311611 Animal (except Poultry) Slaughtering

311612 Meat Processed from Carcasses

311613 Rendering and Meat Byproduct Processing

311615 Poultry Processing

311710 Seafood Product Preparation and Packaging

311811 Retail Bakeries

311812 Commercial Bakeries

311813 Frozen Cakes, Pies, and Other Pastries Manufacturing

311821 Cookie and Cracker Manufacturing

311824 Dry Pasta, Dough, and Flour Mixes Manufacturing from 

Purchased Flour

311830 Tortilla Manufacturing
E-5 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

311911 Roasted Nuts and Peanut Butter Manufacturing

311919 Other Snack Food Manufacturing

311920 Coffee and Tea Manufacturing

311930 Flavoring Syrup and Concentrate Manufacturing

311941 Mayonnaise, Dressing and Other Prepared Sauce 

Manufacturing

311942 Spice and Extract Manufacturing

311991 Perishable Prepared Food Manufacturing

311999 All Other Miscellaneous Food Manufacturing

General 

Merchandise 

Stores

General Merchandise 

Stores (452)

452112 Discount department stores

452990 All other general merchandise stores

All Other Miscellaneous 

Store Retailers (except 

Tobacco Stores) 

(453998)

453998 All other miscellaneous store retailers (except tobacco 

stores)

Grocery and 

Specialty Food 

Stores

Grocery Stores (4451) 445110 Supermarkets and other grocery (except convenience) 

stores

Specialty Food Stores 

(4452)

445210 Meat markets

445230 Fruit and vegetable markets

445299 All other specialty food stores

Food Service 

Contractors (72231) 722310 Food service contractors

Hospitals Hospitals (622) 622110 General medical and surgical hospitals

Non-durable 

Goods 

Wholesalers 

and Dealers

Merchant Wholesalers –

Non-durable Goods 

(424)

424210 Drugs and druggists' sundries merchant wholesalers

424410 General line grocery merchant wholesalers

424420 Packaged frozen food merchant wholesalers

424430 Dairy product (except dried or canned) merchant 

wholesalers

424440 Poultry and poultry product merchant wholesalers

424460 Fish and seafood merchant wholesalers

424470 Meat and meat product merchant wholesalers

424480 Fresh fruit and vegetable merchant wholesalers

424490 Other grocery and related products merchant 

wholesalers

424590 Other farm product raw material merchant wholesalers

424710 Petroleum bulk stations and terminals

424810 Beer and ale merchant wholesalers

424930 Flower, nursery stock, and florists' supplies merchant 

wholesalers
E-6 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

Non-food 

Manufacturing

Paper Manufacturing 

(322)

322121 Paper (except newsprint) mills

322211 Corrugated and solid fiber box manufacturing

322220 Paper Bag and Coated and Treated Paper Manufacturing

Printing and Related 

Support Activities (323) 323111 Commercial Printing (except Screen and Books)

Petroleum 

Manufacturing (324) 324110 Petroleum refineries

Chemical Manufacturing 

(325)

325120 Industrial gas manufacturing

325180 Other Basic Inorganic Chemical Manufacturing

325211 Plastics material and resin manufacturing

325320 Pesticide and other agricultural chemical manufacturing

325620 Toilet preparation manufacturing

325991 Custom compounding of purchased resins

325998 All other miscellaneous chemical product and 

preparation manufacturing

Pharmaceutical 

Manufacturing (3254)

325412 Pharmaceutical preparation manufacturing

325413 In-vitro diagnostic substance manufacturing

325414 Biological product (except diagnostic) manufacturing

Plastics and Rubber 

Manufacturing (326)

326122 Plastics pipe and pipe fitting manufacturing

326140 Polystyrene foam product manufacturing

326160 Plastics bottle manufacturing

326199 All other plastics product manufacturing

326211 Tire manufacturing (except retreading)

Metals Manufacturing 

(332)

332431 Metal can manufacturing

332812 Metal coating, engraving (except jewelry and 

silverware), and allied services to manufacturers

332813 Electroplating, plating, polishing, anodizing, and coloring

Machinery 

Manufacturing (333)

333241 Food Product Machinery Manufacturing

333242 Semiconductor Machinery Manufacturing

333415

Air-conditioning and warm air heating equipment and 

commercial and industrial refrigeration equipment 

manufacturing

333611 Turbine and turbine generator set units manufacturing

Computer and Electronic 

Product Manufacturing 

(334)

334112 Computer storage device manufacturing

334419 Other Electronic Component Manufacturing

334413 Semiconductor and related device manufacturing

334419 Other electric component manufacturing
E-7 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

334510 Electromedical and electrotherapeutic apparatus 

manufacturing

334515 Instrument manufacturing for measuring and testing 

electricity and electrical systems

334516 Analytical laboratory instrument manufacturing

334613 Blank magnetic and optical recording media 

manufacturing

Transportation 

Equipment 

Manufacturing (336)

336411 Aircraft manufacturing

336415 Guided missile and space vehicle propulsion unit and 

propulsion unit parts manufacturing

Medical Equipment and 

Supplies Manufacturing 

(3391)

339112 Surgical and medical instrument manufacturing

Miscellaneous 

Manufacturing (339999) 339999 All other miscellaneous manufacturing

Office Buildings

Publishing Industries 

(except Internet) (511)

511110 Newspaper Publishers

511120 Periodical Publishers

511130 Book Publishers

511140 Directory and Mailing List Publishers

511191 Greeting Card Publishers

511199 All Other Publishers

511210 Software Publishers

Motion Picture and 

Video Industries (512)

512110 Motion Picture and Video Production

512120 Motion Picture and Video Distribution

512131 Motion Picture Theaters (except Drive-Ins)

512132 Drive-In Motion Picture Theaters

512191 Teleproduction and Other Postproduction Services

512199 Other Motion Picture and Video Industries

512210 Record Production

512220 Integrated Record Production/Distribution

512230 Music Publishers

512240 Sound Recording Studios

512290 Other Sound Recording Industries

Broadcasting (515)

515111 Radio Networks

515112 Radio Stations

515120 Television Broadcasting

515210 Cable and Other Subscription Programming

Telecommunications 517110 Wired Telecommunications Carriers
E-8 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

(517) 517210 Wireless Telecommunications Carriers (except Satellite)

517410 Satellite Telecommunications

51791 Other Telecommunications

Data Processing, 

Hosting, and Related 

Services (518)

518210 Data Processing, Hosting, and Related Services

Libraries and Archives 

(519) 519120 Libraries and Archives

Credit Intermediation 

and Related Activities 

(522)

522220 Sales Financing

522291 Consumer Lending

522292 Real Estate Credit

522293 International Trade Financing

522294 Secondary Market Financing

522298 All Other Nondepository Credit Intermediation

522310 Mortgage and Nonmortgage Loan Brokers

522320 Financial Transactions Processing, Reserve, and 

Clearinghouse Activities

522390 Other Activities Related to Credit Intermediation

Insurance Carriers (524)

524113 Direct Life Insurance Carriers

524114 Direct Health and Medical Insurance Carriers

524126 Direct Property and Casualty Insurance Carriers

524127 Direct Title Insurance Carriers

524128 Other Direct Insurance (except Life, Health and Medical) 

Carriers

524130 Reinsurance Carriers

524210 Insurance Agencies and Brokerages

524291 Claims Adjusting

524292 Third Party Administration of Insurance and Pension 

Funds

524298 All Other Insurance Related Activities

Real Estate (531)

531110 Lessors of Residential Buildings and Dwellings

531120 Lessors of Nonresidential Buildings (except 

Miniwarehouses)

531130 Lessors of Miniwarehouses and Self Storage Units

531190 Lessors of Other Real Estate Property

531210 Offices of Real Estate Agents and Brokers

531311 Residential Property Managers

531312 Nonresidential Property Managers
E-9 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

531320 Offices of Real Estate Appraisers

531390 Other Activities Related to Real Estate

Professional, Scientific, 

and Technical Services 

(541)

541110 Offices of Lawyers

541191 Title Abstract and Settlement Offices

541199 All Other Legal Services

541211 Offices of Certified Public Accountants

541213 Tax Preparation Services

541214 Payroll Services

541219 Other Accounting Services

541310 Architectural Services

541320 Landscape Architectural Services

541330 Engineering Services

541340 Drafting Services

541350 Building Inspection Services

541360 Geophysical Surveying and Mapping Services

541370 Surveying and Mapping (except Geophysical) Services

541380 Testing Laboratories

541410 Interior Design Services

541420 Industrial Design Services

541430 Graphic Design Services

541490 Other Specialized Design Services

541511 Custom Computer Programming Services

541512 Computer Systems Design Services

541513 Computer Facilities Management Services

541519 Other Computer Related Services

541611 Administrative Management and General Management 

Consulting Services

541612 Human Resources Consulting Services

541613 Marketing Consulting Services

541614 Process, Physical Distribution and Logistics Consulting 

Services

541618 Other Management Consulting Services

541620 Environmental Consulting Services

541690 Other Scientific and Technical Consulting Services 

54171 Research and Development in the Physical, Engineering, 

and Life Sciences
E-10 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

541720 Research and Development in the Social Sciences and 

Humanities

541810 Advertising Agencies

541820 Public Relations Agencies

541830 Media Buying Agencies

541840 Media Representatives

541850 Outdoor Advertising

541860 Direct Mail Advertising

541870 Advertising Material Distribution Services

541890 Other Services Related to Advertising

541910 Marketing Research and Public Opinion Polling

541921 Photography Studios, Portrait

541922 Commercial Photography

541930 Translation and Interpretation Services

541940 Veterinary Services

541990 All Other Professional, Scientific and Technical Services

Management of 

Companies and 

Enterprises (551)

551111 Offices of Bank Holding Companies

551112 Offices of Other Holding Companies

Administrative and 

Support Services (561)

561110 Office Administrative Services

561210 Facilities Support Services

56131 Employment Placement Agencies

561320 Temporary Help Services

561330 Professional Employer Organizations

561410 Document Preparation Services

561421 Telephone Answering Services

561422 Telemarketing Bureaus and Other contact Centers

561431 Private Mail Centers

561439 Other Business Service Centers (including Copy Shops)

561440 Collection Agencies

561450 Credit Bureaus

561491 Repossession Services

561492 Court Reporting and Stenotype Services

561499 All Other Business Support Services

561510 Travel Agencies
E-11 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

561520 Tour Operators

561591 Convention and Visitors Bureaus

561599 All Other Travel Arrangement and Reservation Services

561611 Investigation Services

561612 Security Guards and Patrol Services

561613 Armored Car Services

561621 Security Systems Services (except Locksmiths)

561622 Locksmiths

561710 Exterminating and Pest Control Services

561720 Janitorial Services

561730 Landscaping Services

561740 Carpet and Upholstery Cleaning Services

561790 Other Services to Buildings and Dwellings 

561910 Packaging and Labeling Services

561920 Convention and Trade Show Organizers

561990 All Other Support Services

Museums, Historical 

Sites and Similar 

Institutions (712)

712110 Museums

712130 Zoos and Botanical Gardens

Accommodation (721)

721110 Hotels (except Casino Hotels) and Motels

721120 Casino Hotels

Religious, Grantmaking, 

Civic, Professional, and 

Similar Organizations 

(813)

813110 Religious Organizations

813211 Grantmaking Foundations

813212 Voluntary Health Organizations

813219 Other Grantmaking and Giving Services

813311 Human Rights Organizations

813312 Environment, Conservation and Wildlife Organizations

813319 Other Social Advocacy Organizations

813410 Civic and Social Organizations

813910 Business Associations

813920 Professional Organizations

813930 Labor Unions and Similar Labor Organizations 

813940 Political Organizations

813990 Other Similar Organizations (except Business, 

Professional, Labor, and Political Organizations) 
E-12 August 26, 2015

Sector NAICS Category NAICS NAICS Code Definition

Other 

Warehousing, 

Storage, and 

Transportation

Transportation and 

Warehousing (48)

484220 Specialized freight (except used goods) trucking, local

488119 Other airport operations

488510 Freight transportation arrangement

488991 Packing and crating

Warehousing and 

Storage (4931)

493110 General warehousing and storage

493130 Farm product warehousing and storage

493190 Other warehousing and storage

Refrigerated 

Warehousing 

and Storage

Refrigerated 

Warehousing and 

Storage (49312)

493120 Refrigerated warehousing and storage

Research and 

Development

Research and 

Development (5417) 54171 Research and development in the Physical, Engineering and Life Sciences

Utilities

Utilities (221)

221111 Hydroelectric Power Generation

221112 Fossil fuel electric power generation

221113 Nuclear Electric Power Generation

221114 Solar Electric Power Generation

221115 Wind Electric Power Generation

221116 Geothermal Electric Power Generation

221117 Biomass Electric Power Generation

221118 Other Electric Power Generation

221121 Electric Bulk Power Transmission and Control

221122 Electric power distribution

221210 Natural gas distribution

221310 Water supply and irrigation systems

221320 Sewage treatment facilities

221330 Steam and air-conditioning supply

Oil and gas extraction 

(211) 211111 Crude petroleum and natural gas extraction

Warehouse 

Clubs and 

Supercenters

Warehouse Clubs and 

Supercenters (45291) 452910 Warehouse clubs and supercenters

Source: U.S. Census Data. 2012.
E-13 August 26, 2015

E.2. NAICS Classification for Small Can Requirements

Table 49: NAICS Codes Included in the Small-can Analysis

Industry NAICS 

Code Definition

Small Can Manufacturers 441310 Automotive Parts and Accessories Stores

325120 Industrial Gas Manufacturing

Source: U.S. Census Data. 2012.

E.3. NAICS Classification for Recordkeeping and Reporting 

Requirements

Table 50: NAICS Codes Included in the Recordkeeping and Reporting Requirements Analysis

Industry NAICS 

Code Definition

Reclaimers 325120 Industrial Gas Manufacturing

423930 Recyclable Material Merchant Wholesalers

562920 Materials Recovery Facilities

562212 Solid Waste Landfill

424690 Other Chemical and Allied Products Merchant Wholesalers

Disposal Establishments 562920 Materials Recovery Facilities

562212 Solid Waste Landfill

423990 Other Miscellaneous Durable Goods Merchant Wholesalers

Service Establishments 811310 Commercial Industrial Machinery and Equipment (not Automotive and 

Electronic) Repair and Maintenance

811412 Appliance Repair and Maintenance

Refrigerant Wholesalers 325120 Industrial Gas Manufacturing

424690 Other Chemical and Allied Products Merchant Wholesalers

42 Wholesale Trade

Small Can Manufacturers 441310 Automotive Parts and Accessories Stores

325120 Industrial Gas Manufacturing

Service Technicians 238220 Plumbing, heating, and air-conditioning contractors

Source: U.S. Census Data. 2012.
F-14 August 26, 2015

Appendix F. Costs Incurred by DIYers for a Sales Restriction

To estimate the costs incurred by DIYers for a refrigerant sales restriction without an exemption for 

small cans, total annual sales of DIY small cans (14.1 million) were divided by the average number of 

cans used per servicing event (1.3). The result (10.8 million) is assumed to be equivalent to the number 

of annual DIY servicing events that would necessitate a DIYer to either become a certified technician 

under section 609 or take her or his vehicle to a professional service shop. Table 51 and Table 52 below 

show key assumptions and the estimated costs incurred by DIYers for each course of action. 

Table 51. Costs Incurred by DIYers to Take Vehicle to a Professional Service Shop

Action to 

Comply with 

Sales Restriction

Annual Sales 

of R-134a 

Small Cans to 

DIY Market1

(millions)

Number of 

Annual 

Servicing 

Events2

(millions)

Cost of 

Professional 

Service Job3

Cost of R-134a 

Small Can4

Percent of 

DIYers Who 

Would 

Forgo AC5

Total Annual Cost

to DIYers (million 

$)6,7

Take vehicle to 

professional 

service shop

14.1 10.8 $50–$200 $7.49–$19.99 19% $333.2–$1,473.1

1

Represents an average of the total R-134a cans sold in the United States in 2006 and 2007 (NPD 2008; CARB 

2009b).

2

Based on research commissioned by CARB, the average number of cans used per recharging event is 1.3 (Clodic 

et al. 2008; CARB 2009b).

3

Based on a survey of professional shops, costs for a professional diagnosis and recharging range from $50 to $200

(Clodic et al. 2008).

4

Based on various results from an online search.

5

Based on research commissioned by CARB, 19% of DIYers would opt to forgo AC rather than take their vehicles to 

a professional service shop (Clodic et al. 2008; CARB 2009b).

6

Total annual costs exclude DIYers who would opt to forgo AC.

7

Total annual costs exclude the cost to purchase a can of R-134a since the cost of the refrigerant is already 

factored into the cost for a professional service job.

Table 52. Costs Incurred by DIYers to Become a 609 Certified Technician

Action to 

Comply with 

Sales 

Restriction

Annual Sales 

of R-134a 

Small Cans to 

DIY Market1

(millions)

Number of 

DIY 

Vehicles2,3

(millions)

Number of 

DIY 

Operators4

(millions)

Cost of 609 

Technician 

Certification 

Training Manual 

& Exam5

Percent of 

DIYers 

Who 

Would 

Forgo AC6

Total Annual Cost 

for DIYers to 

Become Certified 

Technicians 

(million $)7,8

Become a 

certified 

technician 

under section 

609

14.1 10.8 7.1 $20 19% $114.5
F-15 August 26, 2015

1 Represents an average of the total R-134a cans sold in the United States in 2006 and 2007 (NPD 2008; CARB 

2009b).

2

Based on research commissioned by CARB, the average number of cans used per recharging event is 1.3 (Clodic 

et al. 2008; CARB 2009b).

3

Assumed a DIY service rate of once per year per vehicle (CARB 2009b).

4

Assumed some DIYers own and service more than one vehicle per year. According to data from the Oak Ridge 

National Laboratory on household vehicle ownership, approximately 38% of households own one vehicle, 41% of 

households own two vehicles, and 21% of households own three or more vehicles (ORNL 2014).

5

Based on various results from an online search.

6

Assumed 19% of DIYers would opt to forgo AC rather than become a certified technician (Clodic et al. 2008; CARB 

2009b).

7

Total annual costs exclude DIYers who would opt to forgo AC.

8

Total costs do not include the value of leisure time a DIYer would spend to become a 609 certified technician.