1

**INFORMATION COLLECTION REQUEST (ICR 1617.07)**  **FOR SERVICING OF MOTOR VEHICLE AIR CONDITIONERS**  **SUPPORTING STATEMENT 1.**  **Identification of Information Collection** a) Title : "Servicing of Motor Vehicle Air Conditioners" OMB Control Number : 2060

- 0247 EPA Number : 1617.0 7 b) Short Characterization/Abstract History

. Section 609 of the Clean Air Act Amendments of 1990 (Act) provides general guidelines for motor vehicle air conditioning (MVAC) refrigerant handling and MVAC servicing. Itstates that “no perso n repairing or servicing motor vehicles for consideration may perform any

service on a motor vehicle air conditioner involving the refrigerant for such air conditioner without properly using approved refrigerant recovery and/or recovery

and recycling equip ment (here after referred to as “refrigerant handling equipment”) and no such person may perform such service unless such person has been properly trained and certified

. ” In1992, EPA developed regulations under section 609 that were published in 57 FR 3124 2 , and codified at 40 CFR Subpart B (§ 82.30 et seq. ). The information required to be collected under the Section 609 regulations is currently

approved for use through December 31, 200 8

. This supporting statement is submitted to justify

an extension of the approval of use of this information. Pursuant to new requirements under the Paperwork Reduction Act, a notice was published in the Federal Register on October 4, 2005 , announcing the intent to extend the renewal of this I nfor mation Collection Request and requesting comment on the renewal. Descriptions of the recordkeeping and reporting requirements mandated by section 609 and delineated in 40 CFR 82 subpart B are summarized below in this section. The chart located at the end of this document displays the estimated cost s of these requirements. Approved Refrigerant Handling Equipment. Inaccordance with Section 609(b)(2)(A), 40 CFR 82.36 requires that refrigerant handling equipment be certified by EPA or independent standards testing organization. Certifi cation standards are particular to the ty pe of equipment and the refrigerant to be recovered, and must be consistent with the Society of Automotive Engineers (SAE) standards for MVAC equipment

. Approved independent standards testing organizations. Secti on 609(b)(2)(A) of the Act requires independent laboratory

testing of refrigerant handling equipment to be certified by EPA. The Stratospheric Protection Division ( SPD ) requires independent laboratories to submit an application that documents : the organization’s capacity to accurately

test equipment compliance with applicable standards consistent with the SAE standards for handling refrigerant, an absence2

of conflict of interest or financial benefit based on test outcomes , and an agreement to allow EPA acce ss to verify

application information

. Once an independent laborato ry has been approved by EPA, the application is kept on file in the SPD. Two laboratories

– Underwriters Laboratories In c . and Intertek/ETL Testing Laboratories

– are currently approved to test refrigerant handling equipment. EPA does not anticipate that any organizations will apply

to EPA in the future to become approved independent standards testing organizations. Therefore, annual hours and costs related to information submitted by these organizations have been eliminated. Technician training and certification. According to Section 609(b)(4) of the Act, automotive technicians are re quired to be trained and certified in the proper use of approved refrigerant handling equipment. Programs that perform technician training and certification activities must apply to the S PD for ap p roval by submitting verification that its program meets EPA standards. The information requested is used by the S PD to guarantee a degree of uniformity in the testing programs for motor vehicle service techni cians. Due to rapid developments in technology , the Agency requires that each approved technician certifi cation program conducts periodic reviews and updates of test material, submitting a written summary of the review and program changes to EPA every two years (as per 40 CFR §82.40 (c))

. After the test has been approved by EPA, a hard copy

remains on file wi th S PD. Currently , 19 t esting programs are approved by EPA to train technicians in the proper use of refrigerant handling equipment. Five of these programs are designed specifically for individual company ’s own employees. Certification, reporting and reco rdkeeping. To facilitate enforcement under Section 609, EPA developed several recordkeeping requirements. All required records must be re tained on

- si te for a minimum of three years, unless otherwise indicated (40 CFR §82.42 (b))

. Section 609(c) of the A ct states that by January 1, 1992 , no perso n may

service any

motor vehicle air conditioner without being properly trained and certified, nor without using properly approved refrigerant handling equipment. To this end, 40 CFR 82.42 (a) states that by January 1, 1993 , each service provider must have submitted to EPA on a one - time basis a statement signed by the owner of the equipment or another responsible officer that provides the name of the equip

ment purchaser, the address of the service establishment where the equipment will be located , the manufacturer name, equipment model number, date of manufacture, and equipment serial number. The statement must also indicate that the equipment will be properly used in servicing motor vehicle air condition ers and that each individual authorized by the purchaser to perform service is property

trained and certified

. The information is used by the SPD to verify

compli ance with Section 609 of the Act. Any person who owns approved refrigerant handling equipment must mai ntain records of the name and address of any facil ity to which refrigerant is sent. A dditionally , any person who owns approved refrigerant handling equipment must retain records demonstrating that all persons authorized to operate the equipment are currently certified technicians.3

Finally , any

person who sells or distributes a class Ior class II refrigerant that is in a container of less than 20 pounds must verify that the purchaser is a properly trained and certified technician, unless the purchase of small containers is for resale only . In that case, the seller must obtain a written statement from the purchaser that the containers are for resale only, and must indicate the purchaser's name and business address. When a certified technician purchas es sma ll contain ers of refrigerant for servicing motor vehicles, the seller must have a reasonable basis for believing the accuracy

of the information presented by the purchaser. Inall cases, the seller must display a sign where sales occur that states the cer tification requirements for purchasers. **2. Need for and Use of the Collection**  a) Authority

for the Collection The information requested for all entities that service motor vehicle air conditioning is required by

Section 609(d) of the Act and 40 CFR 82. 36, 82.40, 82.42

. This includes certification of both approved equipment and properly trained personnel. Section 609(b)(2)(A) and 40 CFR 82.38 require the approval of independent standards testing organization by EPA. Automotive air conditioning technician certification programs are referred to in Section 609(b)(4) , and applicable requirements for program certification are detailed in 40 CFR 82.40

. R eporting requirements associated with the sale of small containers for resale only are noted in Section 609(e ) of the Act and 40 CFR 82.42(b)(3). The reporting requirements for the motor vehicle recycling program are derived from Section 114 of the Act. b) Practical Utility

/Users of the Data MVAC service establishments are required , by S ection 609 of the Act , to have purchased approved refrigerant handling equipment and to have only properly trained and certified personnel using the equipment by January 1, 1992. They

must submit certification form or statement to EPA by

January 1, 1993 ce rtifying that the MVAC service establishment has acquired and is properly

using, approved equipment and that each individual authorized to use the equipment is properly trained and certified

. The Agency uses the certifi cates to confirm compliance with Se ction 609.

i) Equipment Certification As per 30 CFR §82.36 (a) (1), the Agency is required either to certify refrigerant handling equipment itself or to approve independent laboratories to test and certify equipm ent. Inorder for EPA to certify

equipment , the Agency

must be provided with information that proves the equipment’s ability

to recover and/or recycle refrigerant according to the SAE J standards adopted into the appendices at 40 CFR part 82, subpart B

. Certification standards are particular to th e ty pe of equipment used and refrigerant being recovered. Since EPA does not have the capabilities to test all refrigerant handling equipment on a national scale, the Agency relies on approved l aboratories to test equipment. Currently ,4

Underwriters Laborato ries (UL) and Intertek/ETL Testing Laboratories (ETL) certify e quipment on a voluntary

basis. The Agency

established an approval system at 40 CFR §82.38 to evaluate procedures of laboratories that may request approval in the future

. In formation submitt ed by the laboratories must include documentation of their capacity to accurately

test equipment, an absence of a conflict of interest or financial benefit based on test results, and agreement to allow EPA access to verify

information. The SPD uses the inf ormation provided by

independent laboratories to evaluate their capacity to properly test refrigerant handling equip ment. The Agency has required only the submission of information that will enable it to e nsure that all approved laboratories can test equipment under Agency standards and the adopted SAE J standards. ii) Te chnician Certification Programs Technicians must pass a test at the completion of a certification program in order to perform any

service or repair on MVACs and in order to use the approved equipment as stipulated in Section 609 and 40 CFR 82.34, 82.40. Technician certification programs must submit verification to EPA of their compliance with standards set forth in 40 CFR 82.40. SPD uses certification program information to ensure that Agency standards are met, and that they are at least as stringent as the SAE J standards of the Society of Automotive Engineers

. Because of the rapidly

changing nature of the motor vehicle air conditioning market, EPA requires that technician certificatio n programs conduct internal reviews and update their program periodically . By

requiring a written summary of the review and any

program changes to be reported to EPA every

two years, the Agency

ensures the accuracy

of the information, and maintains parity among testing programs.

iii) Refrigerant Sent Off

-site EPA requires service establishments to record the name and address of any off

- site facility which is reclaiming refrigerant , per 40 CFR §82.42 (b)(1)

. This information is used to verify compli ance with the motor vehicle air conditioning recycling program. iv) Purchases of Small Cans D istributors who purchase small containers of refrigerant must be properly trained and certified according t o the standards set forth in 40 CFR § 82.40, unless the p urchaser provides a written statement verifying that the small containers were purchased for resale only

. The seller may keep the initial statement from a distributor and update the file with the amounts of refrigerant purchased in the form of small contai ners. These records are used to e nsure that small containers of refrigerant are not available for non

- certified technicians. By requiring only

minor additions to the existing invoice procedures, the Agency has e nsured total compliance with Section 609. **3 .**  **Non -**  **duplication, Consultations, and Other Collection Criteria**5

a) Non

- D uplication The specific information requested by this notice is not currently collected by

any other office within EPA or any

other government agency

. b) Public Noti c e Required P rior to I CR Submission to OMB Incompliance with the Paperwork Reduction Act of 1995, EPA will issue a public notice in the Federal Register soliciting public comments for a 60

- day period.

c ) Consultations Indeveloping the regulations under the Act, E PA established an advisory council for issues relating to stratospheric ozone. The Stratospheric Ozone Protec tion Advisory Council (STOPAC) membership included representatives from affected industries, environmental interest groups, and academics in related fields. Within STOPAC, subcommittees were formed to look at the more detailed issues. The subcommittee on motor vehicle air condi tioning met several times , and discussed all aspects of the proposed regulations for Section 609 of the Act. The Federal R egister Notice required under 5 CFR 1320.8(d) soliciting comments on this collection of information , was published on 9/4/98 (63 FR 47284); no comments were received. To update this I CR, information was recently obtained from six technician certification organizations

. d) Effects of Less Frequent Collection The equipment certification time table was established by Congress in Section 609. Since the certification submission is a one

- time occurrence, a less frequent collection of this information would make it impossible to comply with Section 609. V erification s of applications for technician certification programs and independent standards testing organizations are required to be submitted to EPA under Section 609 of the Act. The review is a one

- time occ urrence and must take place to allow the Agency to approve programs under the Act.
e) General Guidelines Th e Section 609 regulations do not exceed any of the guidelines. f ) Confidentiality6

This section does not apply because this I CR does n ot request information of a confidential nature. g) Sensitive Questions This section does not apply because this I CR does not request information of a sensitive nature. **4. The Respondents and the Information Requested**  a) Respondents / NAI CS Codes The following is a list of NAI CS codes for organizations potentially affected by the information requirements covered under this I CR . It is meant to include any establishment that may

service or maintain motor vehicle air conditioners. 441 1 Automobile De alers 4413 Automotive Parts, Accessories, and Tire Stores 447 11 45299 All Other General Merchandise Stores 8111 98 All Other Automotive Repair and Maintenance Other affected groups include: In dependent Standards Testing Organizations Organiz ations with Technician Certification Programs b) In formation Requested i) Data Items, inclu ding Recordkeeping Requirements All entities that service motor vehicle air conditioners must send to EPA , on a one - time basis , certification of an appropriate MVAC refrigerant handling device

. This certification must include the name of the purchaser of the equipment, address of the establishment where the equipment will be located , name of equipment manufacturer, model number, date of manufacture , and serial number . The statement must be signed by the owner of the equipment or other responsible officer , and must indicate that the equipment will be properly used in servicing motor vehicle air condition ers , and that each individual authorized by the purchaser to p erform service is property

trained and certified. In dependent laboratory

testing of refrigerant handling equipment is designed to ensure that the equipment is capable of safely meeting the standards set forth by EPA in appendices to 40 CFR 82 Subpart B. T o establish a degree of uniformity to the equipment certification programs, EPA requires organizations to submit applications documenting : the equipment used7

for equipment testing; the expertise and technical experience of their personnel; thorough knowled ge of the standards in the ap pendices to 40 CFR 82 Subpart B; test procedures to be used and the rationale for them; absence of a confli ct of interest or financial benefit based on test results; and agreement to allow EPA access to verify information. Spec ific reporting requirements may include: equipment ability to remove moisture, oil, and non

- condensable gas es from refrigerant , and a list of testing equipment used. Technician certification programs interested in certifying technicians are required to do cument that their program meets EPA standards. An acceptable program includes the following components: adequate training through on

- the

- job or on

- site instructional training, or self

- study ; a test that effectively covers all relevant standards dealing wi th the servicing and repair of motor vehicle air conditioners , anticipated future technological developments , the regulatory

requirements imposed by EPA under Section 609 of the Act , the environmental conse

quences of the release of refrigerant during the servicing and repair of motor vehicle air conditioners , and the adverse effects of stratospheric ozone depletion ; a test grader who receives no benefit based on test results; means of identifying the individual taking the test; the measures taken at the te st site to e nsure that the tests are completed honestly by each technician; individual proof of certification in the form of a certificate or card and unique certification number. Certification programs are required to conduct a periodic review of their test material and submit to EPA a written program review summary and any material changes every

two years. Service establishments that own approved refrigerant handling equipment and send used refrigerant off

- site for recycling or reclamation must re cord the facility name and address to which any

refrigerant is sent. Inaddition, the seller of small containers to an uncertified purchaser must be provided with a written statement that the containers are for resale only . The statement must also contain the purchaser’s name and address . Finally , any person who owns equipment must retain records demonstrating that all technicians authorized to operate the equipment are certified pursuant to the Clean Air Act. All of these records must be kept on

- site for a minimum of three years. ii) Respondent Activities All Entities That Service Motor Vehicle Air Conditioners

 One

- Time Equipment and User Certification F orm s : o Compile documentation for a certification that states the following: The name of the purchase r of the equipment, address of the establishment where the equipment will be located, name of equipment manufacturer, model number, date of manufacture, and serial number. The statement must be signed by the owner of the equipment or other responsible offi cer, and indicate that the equipment will be properly used in servicing motor vehicle air condition ers and that each individual authorized by the purchaser to perform service is property trained and certified. In many cases a form is provided by the8 manuf acturer of the equip ment. Prepare and submit completed certification to EPA.

 Records of Certified Technicians: o Maintain records on

- site , for a minimum of three years, demonstrating that all equipment users are properly trained and certified

.

 Records of Refrigerant Sent Off

- site: o Record and file the facility address to which any

refrigerant is sent for off

- site reclamation or recycling. Recordkeeping is required for a minimum of three ye ars.

 Records of Class Ior Class I I Refrigerant in Small Containers S old for Re

- Sale : o Verify that purchaser is properly trained and certified

. o Compile , file , and keep for a minimum of three years written statements from uncertified purchasers verifying their intent to only resell the small containers of refrigerant. In d ependent Standards Testing Organizations

 New In dependent Standards Testing Organization Certification o Research SAE J standards on MVAC refrigerant handling equipment. o Compile test methodology , a list of required equipment, and other information regarding the SAE standards for the application to EPA. o Prepare and s ubmit application to EPA that documents capacity to accurately test whether refrigerant handling equipment complies with the applicable standards , an absence of conflict of interest or financial be nefit based on test results and an agreement to allow EPA access to verify information to ensure that the testing program fulfills the applicable SAE J standards , adopted in the appendices at 40 CFR part 82, subpart B, for recycling and recovery equipment. Substantially

I dentical Equipment

 Substantially

I dentical Equipment Owners or Manufacturers o Lo cate information that will verify that the equipment can perform to the applicable SAE J standards, including process flow sheets and a list of components. o Compile supporting information and submit it to EPA

. Technician Certification Programs

 New Technician Certification Program Certification:9 o Compile documents and s ubmit to EPA verification that training program meets EPA requirements

.

 Technician Certificat ion Program Review: o Conduct periodic program review s . o Prepare and submit summary of program review to EPA every two years . **5. The Information Collected: Agency Activities, Collection Methodology, and**  **Informa tion Management**  a) Agency

Activities

 One

- Tim e Equipment and User Certification F orms : o Review and s tore certification applications and supporting documents from all entities that have purchased approved refrigerant handling equipment

.

 Records of Certified Technicians: o No Agency

action required.

 Rec ords of Refrigerant Sent Off

- s ite: o No Agency

action required.

 Records of Refrigerant S old for Re

- Sale : o No Agency

action required.

 New In dependent Standards Testing Organization Certification : o Review applications from independent labs that request approva l to certify refrigerant handling equipment.

 New Technician Certification Program Certification: o Review applications from new technician certification programs.

 Technician Certification Program Review: o Review summaries of certification program updates ev ery two years.10

b) Collection Methodology and Management S PD and the EPA regional offices have planned and allocated resources for the efficient and effective management and use of this information. The Agency has developed a sample form that manufacture rs may

distribute to service establishments that have purchased approved refrigerant handling equipment. An establishment may submit the form provided by the manufacturer of the equipment. Entities are not required to use the manu facturer's form, but they must submit the required information. The information submitted by each service establishment is maintained by

the EPA R egional offices. In dependent standards testing organizations must submit to the Agency an application documenting their capacity to accurately

test whether refrigerant handling equipment complies with the applicable standards , an absence of conflict of interest or financial benefit based on test results, and an agreement to allow EPA access to verify information . The Agency examines th e submitted test procedures for their ability to meet the SAE standards as specified in Section 609 of the Act. These applications may be submitted manually

or electronically , as long as they are made available for Agency review. Equipment manufacturers o r equipment owners that are interested in having their equipment determined substantially identical must submit information to the Agency for an evaluation of the equipment. The information provided is kept on file at EPA for reference. Technician certif

ication programs must submit to the Agency a verification of their compliance with EPA regulations for review and approval by the S PD. Program materials include, but are not limited to: video tapes, scripts, manuals, booklets, and software or other forms o f electronic information. Testing of technicians may be performed either manually or electronically . The certification programs and their review reports are kept on file at EPA for reference. The Agency

has determined that periodic on

- site inspection i s the most effective method to e nsure compliance with S ection 609. R ecords should be kept at the location where service involving refrigerant is performed or where small containers of refrigerant are distributed for resale. c) Small Entity

Flexibility Se ction 609 contains a provision that allow ed small entities (i.e., those which performed service on fewer than 100 motor vehicle air conditioners during the calendar year 1990) an additional ye ar to comply with the provisions of Section 609. EPA expects a small number of technician certification programs and independent equipment standard testing organizations to apply for approval. The requirement to submit the program application for Agency approval is not burdensome and is not expected to prevent small11

entities from developing programs. The Act does not require programs to be developed, only that once developed they

be submitted to EPA. The substantially

identical determination is designed to examine equipment sold before the regulations were proposed and that had not been certified by an approved independent laboratory . This provision will benefit small entities that may have purchased recycling or recover equipment in a good faith effort to recover refrigerant prior to a regulatory mandate. EPA does not expect any

new indepen dent standards testing programs to apply for approval. The name and address of the refrigerant handling facility to which refrigerant is sent by an establishment with recover y- only capabilities is a standard part of existing rec ordkeeping procedures for business transactions. The regulations regarding records maintained by persons who sell small containers of refrigerant solely require that the resale

- only statement be added into invoicing procedures for sales to uncertified purchasers

. d) Collection Schedule All entities operating at the time the regulations were introduced were required to submit certification forms to EPA by January 1, 1993. The certification for refrigerant handling equipment is intended as a one

- time infor mation request for the life of the equipment

. After the initial EPA approval, technician training programs must review their programs periodically to account for technological developments. A summary of the program review and any changes must be submitte d to EPA every two years . **6. Estimating the Burden and Cost of the Collection**  a) Estimating Respondent Burden The basis of the analysis is the identification of the principal steps involved in comply ing with EPA recordkeeping and reporting requirem ents and the estimated burden associated with each step. The burden has been estimated by identifying the number of times the step will be undertaken and the number of hours required to complete each step. Appendix 1 presents the estimated annual respondent burden and costs for information collection activities associated with Section 609 of the Act. Time required for completion of each activity is derived from the estimates in the previous I CR, with several excep tions. In this I CR, the maintenance of records of technician certification (of photocopying and filing the technician’s certification card) is estimated to require 0.083 clerical work hours per establishment (5 minutes) , which remain unchanged from the pre vious IC R. Additionally , in this I CR, the one - time equipment and user certification for compilation, preparation, and submission is estimated to require 0.1 7 hours (10 minutes) per12

establishment, wh ich remain unchanged from the previous I CR. Generally , thi s one - time certification is submitted by a new motor vehicle service facility, or by first

- time refrigerant handling equipment owners or lessees, or when there’s been a change in ownership on an existing service facility , consistent with the recordkeeping a and reporting requirements on 40 CFR 82.42

. This labor burden includes completion and mailing of a prepared form . The form requires information on establishment name , name of the equipment owner or lessee , address, and telephone number, as well as equipm ent manufacturer, model number, serial number, and ye ar . Inthis I CR, 1.5 hours has been allotted per establishment to conduct the reviews, and 0.5 hours has been allotted per establishment to prepare and submit the summary , which are unchanged from the time allotted in the previous I CR

. Itshould be noted that m inimal records need to be developed by industry establishments, and these records can be stored as hard copies; there is no need for the creation (or maintenance) of a database system . Therefore , no additional hours or costs are required for these activities. b) Estimating Respondent Costs i) Estimating Labor Costs Respondent labor costs (hourly rate plus overhead and fringe) are estimated using data from the Bureau of Labor Statistics. 1 Av erage hourly wages are multiplied by

a factor of 2.1 to reflect the estimated additional costs for overhead and fringe . General recordkeeping tasks are assigned to administrative assistants, whereas preparations of applications and reports are assigned to managers. The following job characterizations were used in Table 1 :

 General and Operations Manager : $ 45.74 /hr x 2.1 = $ 96.05  Executive Secretaries and Administrative Assistants : $ 21.91 /hr x 2.1 = $ 46.01  Automotiv e Service Technicians and Mechanics: $17. 39 hr x 2.1 = $36. 52 **Table 1**  **. Average Hourly Establishment Labor Costs**  Managerial Clerical Technical $ 96.05 $ 46.01 $ 36. 52 ii) Estimating Capital and Operations and Maintenance Costs The Agency

estimates that there are no capital/operations and maintenance costs assoc iated with the requirements of S ection 609, and therefore , with the renewal of this information collection request.
1 Labor rates were retrieved from the “May 2011 National Industry

- Specific Occupational Employment and Wage Estimates” for the General and Operations Manager (11

- 1021), Executive Secretaries and Administrative Assistants (43

- 6011), and Automotive Service Technicians and Mechanics (49

- 3023) provided by the U.S. Bureau of Labor Statistics at, http://www.bls.gov/oes/2011/may/oes_nat.htm#43

- 0000

.13

c) Estimating Agency Burden and Cost The basis of this analysis is the identification of the steps involved in implementing and operating the system. The costs associated with each step have been estimated by identifying the number of times the step will be undertaken, the number of hours required to complete e ach step, and the total dollar cost. Appendix 2 presents the estimated Agency burden hours and costs associated with the information collection activities for this I CR. Agency labor costs are based on the 20 11 GS S alary

Schedule for the locality pay area of Washington

- Baltimore

-Northern Virginia, DC

- MD

- PA

- WV , which are multiplied by 1.6, the standard government benefits multiplier. 2 See Table 2 for EPA estimates of average h ourly labor costs for managerial and clerical staff

, whose wage estimates are based on GS 1 2 step 2, and GS 7 step 2 hourly rates respectively . As shown , EPA estimates that the annual Agency burden for all ac tivities covered in this I CR is 188.38 hours at a total cost of $ 6,223.98 pe r year. Wage estimates are based on the following characterizations of occupations:

 GS 1 2 Step 2

- Managerial: $ 3 6.04 /hr x 1.6 = $ 5 7.65 /hr  GS 7 Step 2

– Clerical (43

- 4199) : $ 19. 5 7 /hr x 1.6 = $ 31. 3 1/hr

**Table 2**  **. Average Hourly Agency Labor Costs** 

Managerial Clerical $ 57.65 $ 31. 31 Estimates of burden hours are based on assumptions that filing and recording information will take very

little time. Specific estimates are detailed in Appendix 2. No addition al hours or costs will be incurred for preparation or development of a recordkeeping database. For the establishment activities that simply require on

- site recordkeeping, EPA has no correlated burden. Similarly , for the activities currently not applicable to any

establishments, EPA has no correlated burden. d) Estimating the Respondent Universe and Total Burden and Costs An average estimate of 180 equipment certification forms are received and processed by EPA each month . T herefore, it is estimated that 2 , 200 establishments will compile and submit one - time certification forms to EPA each year. While these certification forms were historically sent by respondents to EPA Headquarters and then forwarded on to EPA Regional offices, as appropriate, they

are n ow sent directly

from establishments to EPA Regional offices. The previous IC R estimated that there will be 55 ,000 records of technicians maintained in establishments per year demonstrating that all equipment users are properly trained and certified.

2 Labor rates were retrieved from the “May 2011 National Industry

- Specific Occupational Employment and Wage Estimates” for the Federal Executive Branch (NAICS Code 9 99100) provided by the U.S. Bureau of Labor Statistics at, http://www.bls.gov/oes/current/naics4_999100.htm

.14

H owever, b ased a decrease of number of technician certification programs and on data collected in March 20 12 from 6 out of 19 technician certification centers , it is estimated that 5 0 ,000 new MVAC technicians are certified each year . Assuming that MVAC serv ice establishments will hire these newly

certified technicians and maintain records demonstrating their certification , this IC R estimates that there will be 5 0 ,000 records regarding certified technicians using proper refrigerant handling equipment will be maintained each year . The previous IC R estimate d that 5 , 000 establishments per year that send refrigerant off

site for handling , assuming all establishments sent refrigerant fro reclamation. However, b ecause most service establishments recycle refrigerant on
- site, the number of entities that send refrigerant off

- site for recycling/reclamation is very low . The agency

estimates that 3% of the total servicing establishments currently operating in the United States ( 4100) , 3 will send the refrigerant off

- site for reclamation. Therefore, 120 facilities are estimated to keep record and file off sire facility

address of refrigerant sent for reclamation. Itis estimated that there are 27 5 purchases of small class Ior class I I refrigerant containers made by unc ertified purchasers for resale only

. Th is number is reduced from the estimate of 1,370 purchases in the previous I CR , derived from an estimate of CFC

- 12 vehicles on road , which estimated about 80% reduction of the existing CFC

- 12 vehicle fleet estimated in 2008

. T here are currently

two independent standards testing organizations, and it is unlikely that any others will apply

for approval. Additionally , no significantly identical equipment is expected to be submitted to the Agency for review. There are currently 19 technician certification programs that must submit program reviews every

other year. It is estimated that EPA will review 1 program per year. . e) Bottom L ine Burden Hours and Cost Tables i) Respondent Tally Total Annual Burden Hours: 4,522. 7 5 hrs. Total Annual Cost: $ 2 08 , 307

. 40 ii) The Agency Tally Total Annual Burden Hours: 188.38 hrs. Total Annual Cost: $ 6,223.98 iii) Variations in the Annual Bottom Line Changes to the annual bottom line are due to a more accurate estimate in hourly wages

3 BLS, 201115

and a shift in the time requirements and number of reporting establishments. See below for a more complete discussion of these changes. f) Reasons for Change in Burden The previously

approved IC R ’s supporting statement described an esti mated burden or estimated a total annual respondent burden of 2,865 hours. By comparison, this I CR estimates a total annual burden of 4,522. 7 5 hours

. Hence, there is a decrease of 2,177. 2 5 hours and a decrease of $ 54,6 37

. 07 since the previously approved I C R. This change can be attributed to the following factors.

 Inthe previous I CR, respondent hourly wages were $47.73, $18.83, and $17.53 for managers, administrative assistants, and technicians, respectively

. Inthis I CR, to increase accuracy , wages have been estimated based on the most current Bureau of Labor Statistics (20 11 ) national averages for managers , administrative assistants , and technicians to be $ 4 5.74 , $ 21.91 , and $17. 39 , respectively

. These baseline wages were then multiplied by a factor of 2 .1 to incorporate overhead and fringe costs into the hourly cost estimate , resulting in estimated hourly cost s of $ 96.05 , $ 46. 01 , and $36. 52

.

 The number of technician certification programs decreased from 2 4 to 19 since the previous I CR because several program s went out of business.

 Inthis I CR, time requirements for each EPA activity related to establishments’ report submissions have been estimated

. Additionally , wages for clerical and managerial EPA work has been estimated based on the 20 11 GS Salary Sc hedule for the locality

pay area of Washington

- Baltimore

-Northern Virginia, DC

- MD

PA

- WV. T hese baseline wages were multiplied by a factor of 1.6, the standard government benefits multiplier, to arrive at an accurate hourly cost.

 The previous I CR estimate d that 55 ,000 new technician certifications would be rec orded and filed by

owners of approved refrigerant handlin g equipment each ye ar. However, this I CR estimates the number to be 5 0 ,000. B ased on data collected in March 20 123 from some technician certif ication centers, it is estimated that 5 0 ,000 new MVAC technicians are certified each year. The time allotted to this activity

in the last I CR was 0. 083 hours per certification ; no change in time allotted per certification is expected on this I CR. 0. 083 hours.

 The previous I CR estimated that equipment and user certification form compilation and submission would require 0. 17 hours per establishment. That estimate remains unchanged in this I CR.

 In20 08 it was estimated that there would be 1,370 purchases of small containers of class Iand class II refrigerant for resale only by uncertified purchasers. Itis16 estimated that at the time (in 200 8 ), there were an estimated 3 million R

- 12 MVACs on the road. Today , it is estimated that there are only 600 thousand R

- 12 MVACs on the road, or roughly 8 0 % less than there were in 200 8 . Therefore, to account for the decreased market for small containers of CFC

- 12 refrigerant, this IC R estimates that the number of purchases for resale only by uncertified purchasers of small cans will be 80 % less than in 200 8 , or 27 5 purchases

.

 Finally , the substantially identical equipment approval process is no longer applicable for CFC

- 12 and HFC

- 134a refrigerant handling equipment manufactured prior proposal of refrigerant equipment handling regulations . This portion of Section 609(b)(2)(B) of the Act and 40 CFR 82.36(b) allowed for equip ment that was purchased before the proposal of the regulations to be approved by

EPA if it was substantially identical to equipment that had been certif ied by the EPA or approved independent laboratory . The substantially identical equipment regulation only relates to CFC

- 12 recovery and recycling equipment initially

purchased before September 4, 1991; CFC

- 12 recovery

- only equipment initially

purchased bef

ore April 22, 1992; HFC

- 134 a recovery and recycling, or recovery

- only equipment initially

purchased before March 6, 1996; equipment that recovers but does not recycle any single, specific refrigerant other than CFC

- 12 or HFC

- 134 a that was initially purchas ed before March 6,1996; or equipment that recovers and recycles HFC

- 134a and CFC

- 12 refrigerant using common circuitry

that was initially

purchased before March 6, 1996. Because the average lifetime of such equipment is roughly 7 years, all such equipment is obsolete today

. Therefore, documentation requirements related to this section for CFC

- 12 and HFC

- 134a have been removed from this I CR. g) Burden Statement The industry

reporting burden for this collection is estimated in Appendix 1 . It includes the time needed to comply with EPA's certification requirements and Agency reviews. The total respondent burden is estimated at 4, 5 22. 7 5 hours. The Agency

burden for this collection is estimated in Appendix 2 . It includes the time needed to record, review, an d file all certification applications and related materials. The total Agency burden is estimated at 188.38 hours. Send comments on the Agency ’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minim izing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2137), 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460; and to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Include the EPA I CR number and OMB control number in any correspondence.17 

### Appendix 1 **Industry Reporting Burden**
**INFORMATION COLLECTION**

**ACTIVITY Frequency/**  **Num ber of**  **Responses per Year**  **Labor Hours per Response Costs** 

**General and Operations**  **Manager $**  **96.05 Autom**  **otive**

**Service Technicians**  **and Mechanics**  **$ 36.52**  **Executive**

**Secretaries and**  **Adm inistrative**  **Assistants 46.**  **01 Total** 

**Labor Hours**  **Average**

**Total Hours**  **Total Labor**

**Costs per Response**  **Average Cost/Year**

**ENTITIES THAT SERVICE MV** **ACs One**  **- Tim**  **e Equipm ent and User**  **Certification Form s**  Compile, Prepare, and Submit Certification 22 00

- 0.1 7 0.17 3 74 $ 7. 82 $ 17,207

. 74 **Records of Technician Certification**  Maintain Records On

- Site of Certification of Technicians 5 0 ,000 0.08 0.08 4000 $ 3.68 $ 184

. 040.00 **Records of CFC**  **- 12**  **Refrigerant Sent Off**  **- Site**  Record and file off

- site facility addres s 120

- 0.25 0.25 30 $ 9.13 $ 1,095.60 **Records of CFC**  **- 12**  **Refrigerant Sold**  Verify certification of purchaser N/A N/A N/A N/A N/A N/A N/A N/A Obtain and file written statements from purchaser verifying intent to only resell small containers 27 5 0.25 0.25 68. 7 5 $ 11.50 $ 31 63.20 **Subtotal** 52700 0.75 4472. 7 5 $ 32.13 $ 205, 506

. 50 **INDEPENDENT STANDARDS TESTING ORGANIZATIONS**  **New Independent Standards**  **Testing Organization Certification** 18

**INFORMATION COLLECTION**

**ACTIVITY Frequency/**  **Num ber of**  **Responses per Year**  **Labor Hours per Response Costs** 

**General and Operations**  **Manager $**  **96.05 Autom**  **otive**

**Service Technicians**  **and Mechanics**  **$ 36.52**  **Executive**

**Secretaries and**  **Adm inistrative**  **Assistants 46.**  **01 Total** 

**Labor Hours**  **Average**

**Total Hours**  **Total Labor**

**Costs per Response**  **Average Cost/Year**

Research SAE standards on MVAC recovery equipment
- N/A N/A N/A N/A N/A N/A N/A Compile information for application to EPA

- N/A N/A N/A N/A N/A N/A N/A Prepare and submit application to EPA

- N/A N/A N/A N/A N/A N/A N/A **Subtotal** N/A N/A N/A N/A N/A N/A N/A **TECHNICIAN CERTIFICATION PROGRAMS**  **New Technician Certification**  **Program Certification**  Compile documents and submit to EPA for verification of program 1 N/A N/A 40 40 40 $ 1,840.40 $ 1,840.40 **Technician Certification Program Review**  Conduct periodic program reviews 10 0 .5 0 .5 5 $ 48.03 $ 480.25 Prepare and Submit summary of program review to EPA every two years 10 0.50 0.50 5 $ 48.03 $ 480.25 **Subtotal** 2 1 2.00

- 2.00 50 $ 1936.46 $ 2, 800.90 **ANNUAL TOTAL N/A**  **4 522.**  **7 5**  **$ 1968.59**  **$ 208,**  **307 .**  **40**19 

### Appendix 2 **Agency Reporting Burden** 

**INFORMATION COLLECTION ACTIVITY**  **Frequency/ Num** **ber of Responses per**  **Year Labor Hours per Response**  **Costs**

**Manager Clerical**  **Total Labor**  **Hours Average** 

**Total Hours**  **Total Labor**

**Costs per Response**  **Average**

**Cost/Year $**  **57.65 $31.**  **31 One**  **- Tim**  **e Equipm ent and**  **User Certification Form s**  Review and file applications 2 , 2 00 0.08 0.08 176 $ 2. 5 0 $ 5,510.56 **New Independent Standards**  **Testing Organization Certification**  Review applications from testing organizations who reque st to certify equipment 0

- - $

- $

- **New Technician Certification**  **Program Certification**  Review applications from new technician certification programs 1 10 10 10 $ 576.50 $ 576.50 **Technician Certification Program**  **Review** Review summaries of certification program updates every two years 9.5 0.25 0.25 2.375 $ 14.41 $ 136.90 **Annual Total 188.38**  **$ 593.41**  **$ 6,223.98**