1

SUPPORTING STATEMENT

for

NESHAP for Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ) 

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

NESHAP for Wood Furniture Manufacturing Operations (40 CFR part 63, subpart JJ) 

(Proposed Rule), OMB Control Number 2060-0324, EPA ICR Number 1716.07. 

(b) Short Characterization.

This ICR covers information collection requirements in the proposed amendments to the 

Wood Furniture NESHAP (40 CFR part 63, subpart JJ). 

The potential respondents are owners or operators of any existing or new affected source 

with wood furniture manufacturing operations. There are an estimated 406 facilities subject to 

the Wood Furniture Manufacturing NESHAP. The affected source is any wood furniture 

manufacturing facility that is engaged, either in part or in whole, in the manufacture of wood 

furniture or wood furniture components and that is located at a plant site that is a major source as 

defined in 40 CFR part 63.2, excluding sources that meet the criteria established in §63.800(a). 

(b), and (c) of the Wood Furniture Manufacturing NESHAP.

The proposed amendments would prohibit the use of conventional spray guns used in 

wood furniture coating operations; add a new formaldehyde emission limit of 400 pound per 12-

month rolling average; and revise the reporting requirements. These amendments are explained 

further in the following paragraphs.

The prohibition for conventional spray guns has a compliance date 3 years from the 

promulgation date which will allow any facility that is still using such equipment to replace it 

with more efficient spray equipment during those 3 years. Any cost associated with the new 

equipment will be offset by the increased transfer efficiency and reduced coating cost. The 

proposed formaldehyde limit of 400 pounds will require any facility with formaldehyde in their
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wood furniture coatings to calculate their coating usage and associated formaldehyde contents 

each month. The 12-month rolling average must be documented monthly and reported annually.

The additional reporting requirements pertain only to the calculation and documentation 

of formaldehyde usage.

The information collection requirements associated with the proposed amendments to the 

NESHAP are listed in Attachment 1.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both 

major and area sources of HAP that are listed for regulation under CAA section 112(c). A major 

source is a stationary source that emits or has the potential to emit more than 10 tons per year 

(tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a 

stationary source that is not a major source (i.e., an area source does not emit and does not have

the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any

combination of HAP). For major sources, these technology-based standards must reflect the 

maximum degree of emission reductions of HAP achievable (after considering cost, energy

requirements, and non-air quality health and environmental impacts) and are commonly referred 

to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires 

EPA to review these technology-based standards and to revise them “as necessary (taking into 

account developments in practices, processes, and control technologies)” no less frequently than 

every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source 

categories subject to certain CAA section 112(d) standards whether the emissions limitations 

provide an ample margin of safety to protect public health. For MACT standards for HAP 

“classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime 

excess cancer risks to the individual most exposed to emissions from a source in the category or 

subcategory to less than 1-in-1 million,” EPA must promulgate residual risk standards for the 

source category (or subcategory) as necessary to provide an ample margin of safety to protect 

public health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA 

determines that the existing standards are sufficiently protective. EPA must also adopt more 
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stringent standards, if necessary, to prevent an adverse environmental effect, but must consider 

cost, energy, safety, and other relevant factors in doing so. 

Certain records and reports are necessary for the Administrator to confirm the compliance 

status of sources subject to NESHAP, identify any new or reconstructed sources subject to the 

standards, and confirm that the standards are being achieved on a continuous basis. These 

recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean 

Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The 

recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 

40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 

years following the date of each occurrence, measurement, maintenance, corrective action, report,

or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority (State agency, or Regional 

Administrator if there is no delegated State agency) to ensure that the standards and other 

requirements are being achieved. Based on review of the recorded information at the site and the 

reported information, the delegated permitting authority can identify facilities that may not be in 

compliance and decide which facilities, records, or processes may need inspection. 

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of EPA’s ongoing ICRs revealed no duplication of informationgathering efforts.

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

Public notice is provided in the preamble to the proposed rule. The final rule ICR will 

address any public comments received.

(c) Consultations.

The proposed amendments were developed in consultation with individual companies, 

State agencies, and trade associations. The non-EPA persons consulted on the information 

collection activities are identified in Table 1.
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TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Telephone No.

Dick Titus Kitchen Cabinets Manufacturers Association 703-264-1690

Bill Perdue American Home Furnishings Alliance 336-884-5000

Brad Miller Business and Institutional Furniture Manufacturers Assn 616-285-3963

David Darling American Coatings Association 202-462-6272

(d) Effects of Less Frequent Collection.

If the relevant information was collected less frequently, the delegated permitting 

authority (State or EPA) will not be reasonably assured that a facility is in compliance with the 

standards.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f) Confidentiality.

All information submitted to the Agency for which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart 

B--Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979).

(g) Sensitive Questions. 

This section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart JJ are owners or operators of any existing or new 

facility engaged in wood furniture manufacturing operations. Wood furniture manufacturing 

facilities are primarily classified under NAICS codes 337110, Wood Kitchen Cabinet and 

Countertop Manufacturing; 33712, Household and Institutional Furniture Manufacturing; 

337211, Wood Office Furniture Manufacturing; and 337212, Custom Architectural Woodwork 

and Millwork Manufacturing. However, wood furniture manufacturing operations are also colocated at many facilities that are classified under other NAICS codes. Examples include NAICS 
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337910, Other Furniture Related Products Manufacturing, and 321999, All Other Furniture 

Related Products Manufacturing.

There are an estimated 150 facilities that would be subject to the proposed amendments to

the NESHAP involving the formaldehyde emission limit. No new wood furniture manufacturing 

sources are expected during the 3-year period of this ICR.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information 

Requirements, summarizes the data items, including recordkeeping and reporting requirements, 

for the Wood Furniture Manufacturing source category.

(ii) Respondent Activities. The respondent activities that will be required by the 

proposed amendments to the Wood Furniture NESHAP are identified in Table 2 and are 

introduced in section 6(a).

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

Information Management

(a) Agency Activities.

The Agency activities associated with the proposed amendments to the Wood Furniture 

NESHAP are provided in Table 3 and are introduced in section 6(c).

(b) Collection Methodology and Management.

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs of the delegated permitting authority. EPA is the 

permitting authority until the State agency is delegated authority to implement the final 

amendments to the rule. Therefore, information contained in any report submitted to the 

Regional Administrator will be entered into the Air Facility System (AFS), which is operated and 

maintained by EPA’s Office of Compliance. AFS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the AFS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated authorities can edit, store, retrieve and analyze the data.
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(c) Small Entity Flexibility.

The Small Business Administration defines a small entity engaging in wood furniture 

manufacturing operations as a firm having no more than 500 to 1,000 employees (depending on 

the size definition for the affected NAICS code). The proposed amendments would not result in 

any significant adverse impacts on any small entities in the Wood Furniture Manufacturing 

source category. The proposed amendments would not create any new requirements or burdens 

for existing sources other than minimal notification requirements, recordkeeping, and reporting 

requirements. 

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is 

shown in Table 2 for the Wood Furniture Source Category.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the proposed amendments to the Wood Furniture 

NESHAP are shown in Table 2. These numbers were derived from estimates based on EPA’s 

experience with other standards. No burden estimates are provided for new sources because no 

new facilities are expected to become affected sources during the 3-year period of this ICR.

(b) Estimating Respondent Costs.

The information collection activities for the proposed amendments to the Wood Furniture 

NESHAP are presented in Table 2. Because the data are already collected by respondents as part 

of normal operations, no respondent development costs are associated with the information 

collection activities.

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of 

Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private 

industry workers were taken from the United States Department of Labor, Bureau of Labor 

Statistics, Occupational Employment and Wages, March 2009 available at 

http://www.bls.gov/news.release/archives/ecec_06102009.htm. Wages for technical labor are 

based on "Civilian workers – professional and related," with a total compensation of 

$46.47/hour. Wages for management labor are taken from "Civilian workers – management, 
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business, and financial," with a total compensation of $54.65/hour. Wages for clerical labor are 

based on "Civilian workers – office and administrative support," with a total compensation of 

$22.98/hour. These rates represent salaries plus fringe benefits and do not include the cost of 

overhead. An overhead rate of 110 percent is used to account for these costs. The fullyburdened hourly wage rates used to represent respondent labor costs are: technical at $97.59 

/hour, management at $114.77 /hour, and clerical at $48.26 /hour.

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. No capital costs 

or O & M costs are associated with the information collection requirements of the proposed 

amendments to the Wood Furniture NESHAP. The proposed amendments would not require 

affected facilities to purchase new monitoring systems or conduct new performance testing. 

(iii) Annualizing Capital Costs. No capital costs associated with the information 

collection requirements of the proposed amendments to the Wood Furniture NESHAP. 

(c) Estimating Agency Burden and Cost.

Because the information collection requirements were developed as an incidental part of 

standards development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of the 

respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the 

part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal 

Government. Publication and distribution of the information are part of the Compliance Data 

System, with the result that no Federal costs can be directly attributed to the ICR. Examination 

of records to be maintained by the respondents will occur incidentally as part of the periodic 

inspection of sources that is part of EPA’s overall compliance and enforcement program, and, 

therefore, is not attributable to the ICR. The only costs that the Federal government will incur 

are user costs associated with the analysis of the reported information, as presented in Table 3.

The Agency labor rates are from the Office of Personnel Management (OPM) 2010

General Schedule, which excludes locality rates of pay. These rates can be obtained from Salary

Table 2010-GS available on the OPM website, http://www.opm.gov/oca/10tables/pdf/gs_h.pdf.

The government employee labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for 

technical (GS-12, Step 1), and $38.92/hr for management (GS-13, Step 5). These rates were 
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increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates 

used to represent Agency labor costs are: clerical at $25.01/hour; technical at $46.21/hour, and 

management at $62.27/hour. 

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

There are an estimated 406 existing facilities that are subject to the Wood Furniture 

NESHAP. No new sources are expected during the next 3 years. Consequently, the average 

number of wood furniture respondents during the 3-year period of this ICR is 135.

For the proposed amendments to the Wood Furniture NESHAP, the components of the 

total annual burden attributable to this ICR include reading the amendments to the NESHAP;

collecting coating usage information and calculating formaldehyde emissions on a 12-month 

rolling average; and reporting those formaldehyde emissions on an annual basis; all other 

recordkeeping and reporting activities are already accounted for in the ICR for the NESHAP.

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in 

Table 2 are calculated by adding person-hours per year down each column for technical, 

managerial, and clerical staff, and by adding down the cost column. The average annual burden 

for the recordkeeping and reporting requirements in the proposed amendments to subpart JJ for 

the 406 existing facilities that are subject to the Wood Furniture NESHAP is 2,001 person-hours,

with an annual average cost of $188,188. No capital costs would be expected for the proposed 

amendments.

(ii) The Agency tally. The average annual Federal Government cost is $5,182 for 

115 hours for the proposed amendments to subpart JJ. The bottom line Agency burden hours and 

costs presented in Table 3 are calculated by adding person-hours per year down each column for 

technical, managerial, and clerical staff, and by adding down the cost column. 

(iii) Variations in the annual bottom line. This section does not apply since no 

significant variation is anticipated.

(f) Reasons for Change in Burden.

This ICR covers information collection requirements in the proposed amendments to the 

Wood Furniture NESHAP (40 CFR part 63, subpart JJ). 
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(g) Burden Statement

The average annual respondent burden for the proposed amendments to the Wood 

Furniture NESHAP is estimated at 5 hours per facility.

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to a 

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

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

burden estimates, and any suggestions for minimizing respondent burden, including through the 

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

Docket ID No. EPA-HQ-OAR-2010-0786, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 

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

http://www.regulations.gov. This site can be used to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in the 

Docket ID Number identified above. Also, you can send comments to the Office of Information 

and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, 
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DC 20503, Attention Desk Officer for EPA. Please include the Docket ID Number EPA-HQOAR-2010-0786 and OMB Control Number 2060-0324 in any correspondence.
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PART B

This section is not applicable because statistical methods are not used in data collection 

associated with the proposed rule.
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TABLE 2. ANNUAL RESPONDENT BURDEN AND COST--AMENDMENTS TO WOOD FURNITURE MANUFACTURING NESHAP

Burden item

(A) 

Person-hours

per 

occurrence

(B) 

No. of 

occurrences 

per

respondent

(C) 

Person-hours 

per 

respondent 

(C=A*B)

(D) 

Respondents 

per year

(E) 

Technical 

person-hours 

per year 

(E=C*D)

(F) 

Management 

person-hours 

per year

(E*0.05)

(G) 

Clerical 

person-hours 

per year 

(E*0.1)

(H) 

Costa, $ 

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization of 

Technology and Systems

N/A

4. Reporting Requirements

A. Read instructionsb4 1 4 135 540 27 54 $58,403

B. Required activities N/A

C. Create informationc2 12 24 50 1,200 60 120 $129,785

D. Gather existing information N/A

E. Write report

5. Recordkeeping Requirements 

A. Read instructions See 4A

B. Plan activities N/A

C. Implement activities N/A

D. Develop record system N/A

E. Time to enter information See 4C

F. Time to train personnel N/A

G. Time to adjust existing ways to comply with 

previously applicable requirements

N/A

H. Time to transmit or disclose information N/A

I. Time for audits N/A

TOTAL LABOR BURDEN AND COST (SALARY) 1,740 87 174 $188,188

TOTAL NUMBER OF ANNUAL RESPONSES 406

ANNUAL CAPITAL COSTSd

TOTAL ANNUALIZED COSTS $188,188

N/A = not applicable.

a

 This ICR uses the following labor rates: $114.77 for managerial labor, $97.59 for technical labor, and $48.26 for clerical labor. These rates are based on the U.S. Department of 

Labor, Bureau of Labor Statistics, Occupational Employment and Wages, March 2009.

b There are an estimated 406 existing facilities; no new facilities are expected; the average number expected to read the rule during the 3-yr compliance period is 406/3 = 135.

c There are an estimated 150 existing facilities using coatings containing formaldehyde; the average number expected to comply with the proposed formaldehyde limit during the 

3-yr compliance period is 150/3 = 50. 

d

 There would be no capital costs associated with the reporting and recordkeeping requirements of the proposed amendments.
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3. ANNUAL BURDEN AND COST TO THE AGENCY----AMENDMENTS TO WOOD FURNITURE MANUFACTURING NESHAP

Burden item

(A) 

Person-hours 

per occurrence

(B) 

Occurrences 

per respondent

(C) 

EPA personhours/year 

(C=A*B)

(D) 

Facilities 

per year

(E) 

Technical personhours/year 

(E=C*D)

(F) 

Management 

person-hours/year 

(F=0.05*E)

(G) 

Clerical personhours/year 

(G=0.1*E)

(H)

Costa, $

Report Review:

 Plant records of annual formaldehyde 

emissions based on 12-month rolling avgb

2 1 2 50 100 5 10 $5,182

TOTAL BURDEN AND COST $5,182

a

 This ICR uses the following average hourly labor rates: $62.27 for managerial (GS-13, Step 5), $46.21 (GS-12, Step 1) for technical, and $25.01 (GS-6, Step 3) for clerical. 

These rates are from the Office of Personnel Management (OPM) 2010 General Schedule, which excludes locality rates of pay.

b Assumes Agency will review all of the annual reports - including the formaldehyde emissions calculated on a 12-month rolling average.
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ATTACHMENT 1. INFORMATION REQUIREMENTS----AMENDMENTS TO WOOD FURNITURE MANUFACTURING NESHAP

Requirement Citation for existing sources Citation for new sources General Provisions citation

Formaldehyde limit § 63.802(a)(4) § 63.802(b)(4)

Prohibit Conventional Spray Guns § 63.803(h) § 63.803(h)

Monitoring § 63.804(h) § 63.804(h) N/A

Notifications N/A N/A N/A

Plans

 Operation and Maintenance Plan N/A N/A N/A

Records

 Monitoring/inspection information § 63.806(b)(4) § 63.806(b)(4) N/A

Reports § 63.807(c)(3) § 63.807(c)(3) 40 CFR 63.10(e)