SUPPORTING STATEMENT FOR 

INFORMATION COLLECTION REQUEST RENEWAL:

MOBILE AIR CONDITIONER RETROFITTING PROGRAM

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

This ICR is entitled "Mobile Air Conditioner Retrofitting Program (Renewal)," EPA ICR 

Number 1774.06, and OMB Number 2060-0350.

1(b) Short Characterization

The Significant New Alternatives Policy (SNAP) Program, under Section 612 of the Clean Air 

Act (CAA), enables the Agency to review available substitutes for ozone depleting substances 

(ODSs) and determine their acceptability. The Stratospheric Protection Division (SPD) is 

responsible for enacting regulations to phase out chemicals that damage the stratospheric ozone 

layer and; therefore, pose a threat to human health and the environment. Depletion of 

stratospheric ozone can result in sharp increases in melanoma and non-melanoma cancers due to 

increased exposure to ultraviolet-A (UV-A) and ultraviolet-B (UV-B) radiation, and a higher 

incidence of cataracts (a leading cause of blindness). Under the SNAP program, companies 

submit applications of substitutes for ODSs. After all necessary information is received, SPD has 

90 days to review the data submitted, and determine if the substitute is acceptable, unacceptable, 

or if its use must be restricted. For every submission, SPD reviews factors such as impact on 

human health and the environment, ozone depleting potential, atmospheric lifetime, global 

warming potential, and flammability. Because many substitutes are produced for multiple uses, 

SPD must determine what uses are appropriate based on the factors mentioned. Once SPD makes 

a decision of acceptability of a substitute, a Notice is published in the Federal Register listing 

acceptable substitutes under SNAP. If the substitute is found unacceptable or use restrictions are 

required, a notice-and-comment rulemaking is necessary. A comprehensive list of substitutes, 

their uses, and any relevant restrictions is maintained for distribution to interested parties. 

SPD requires technicians retrofitting motor vehicle air conditioners (MVACs) containing ODS 

such as CFC-12 to use an approved SNAP substitute and to provide basic information on a label 

to be affixed to a visible section of the MVAC. The label must include the name of the substitute 

refrigerant, when and by whom the retrofit was performed, environmental and safety information 

about the substitute refrigerant, and other information. This information is needed so that 

subsequent technicians working on the MVAC system will be able to service the system properly, 

decreasing the likelihood of significant refrigerant emissions, cross-contamination and potential 

failure of air conditioning systems and refrigerant recovery/recycling equipment. EPA requires

that when retrofitting CFC-12 MVAC systems with an approved SNAP refrigerant, the 

technician must first extract the CFC-12, and then install new fittings unique to the new

refrigerant.
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EPA estimates that 294 technicians will be responsible for providing this information over the 

next 3 years, at a total cost (labor plus materials) of about $1,750.00.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

The SNAP program reviews potential alternatives to ozone-depleting refrigerants used in various 

sectors, including MVACs. When chlorofluorocarbons (CFCs), and specifically CFC-12, were

phased out SPD faced the challenge of identifying acceptable alternative refrigerants that

allowed consumers choice to retrofit CFC-12 MVAC systems to use alternatives. EPA notes that 

in the U.S. prior to the 1993 model year all MVACs used CFC-12 and that after 1995, original 

equipment manufacturers (OEMs) were producing MVACs with HFC-134a. EPA estimates that 

there are currently, in 2013, about 330,000 automobiles, originally designed to use CFC-12 in 

their MVACs, operating in the U.S. Of the automobiles originally designed to use CFC-12 in 

their MVACs that are expected to be operational during the three year term of this ICR, EPA 

estimates 294 (about 0.1%) or less will be retrofitted to use alternative refrigerants between 

October 31, 2013 and October 30, 2016 (the term of this ICR). The remaining MVAC systems 

will either (1) continue to operate without service, (2) continue to operate with minor service 

including repairs and refilling with available supplies of CFC-12, (3) will be recycled or 

disposed of along with the entire motor vehicle, (4) will cease to function but will not be 

retrofitted, or (5) have already been retrofitted to an acceptable alternative refrigerant and will 

not be retrofitted again.

The purpose of this Information Collection Request (ICR) is to estimate the burden associated 

with the 40 CFR part 82 subpart G requirements that service technicians label MVAC systems

with information about new refrigerants when they retrofit a system. It is necessary to assess the 

time it will take for the service technician to fill out and place the label on the retrofitted air 

conditioner. This label will acknowledge that the retrofitting has been completed, and that the 

MVAC no longer uses CFC-12. In addition, the label provides essential information to 

technicians about the specific refrigerant used in the air conditioning system.

Section 612 of the CAA requires EPA to promulgate rules making it unlawful to replace any 

ODS with any substitute that the Administrator determines may present adverse effects to human 

health or the environment where the Administrator has identified an alternative that (1) reduces 

the overall risk to human health and the environment, and (2) is currently or potentially available.

EPA is concerned that the existence of several substitutes in this end-use may increase the 

likelihood of significant refrigerant cross-contamination and potential failure of air conditioning 

systems and recovery/recycling equipment. In addition, continuing the smooth transition to 

substitutes strongly depends on the continued purity of the recovered, recycled and/or reclaimed 

CFC-12 supply.
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2(b) Practical Utility/Users of the Data

The purpose of the label is to alert service technicians and motor vehicle owners that the MVAC 

has been retrofitted to use an acceptable non-CFC refrigerant. The label will provide essential 

information to technicians about the specific refrigerant used in the air conditioning system.

Technicians need this information to avoid service practices that might result in refrigerant crosscontamination and system failure.

3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non duplication

The required label is put on CFC-12 air conditioners that are being retrofitted with an acceptable 

substitute. The label will be the only required mechanism to indicate the use of a substitute, and 

therefore will not be duplicative.

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

A Federal Register Notice soliciting public comment was published on 6/20/2013 (78 FR 37220). 

No comments were received. EPA will publish a second FR notice when this ICR is submitted 

to OMB for review.

3(c) Consultations

EPA consulted with the following individuals in preparing this ICR renewal:

• Angelo Patti, Chairman of the Interior Climate Control Committee of Society of 

Automotive Engineers (SAE), regarding the number of air conditioners likely to be 

retrofitted.

• Ward Atkinson, Suntest Engineering, regarding the number of air conditioners likely to 

be retrofitted and the cost burden.

• Paul DeGuiseppi, Mobile Air Conditioning Society Worldwide, regarding the percent of 

air conditioners likely to be retrofitted.

• Fred Sciance, Manager, Environment and Climate Policy General Motors (GM) Public 

Policy Center, regarding the number of R-12 air conditioners on the road today and the 

percent likely to be retrofitted.

EPA received comments from the four individuals listed above. They are highly supportive of 

EPA’s effort to ensure the labeling of cars retrofitted from R-12 to R-134a. They believe that due 

to better maintenance and longer lifetimes of vehicles, the number of cars remaining on the road 

today with R-12 may be higher than the number estimated by EPA. Despite varying estimates on 

the number of cars on the road today using R-12, they all agree with the estimated number of 

retrofits to be performed and labeled over the next three years.
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Two of the four specifically stated that the estimated number of cars using R-12 on the road 

today is likely too low; however, they concluded that the estimated number of retrofits is 

accurate. Angelo Patti, Chairman of the SAE Interior Climate Control Committee stated that 

“due to the increased age and dwindling value of these remaining vehicles, I believe the 

estimated number of future retrofits is probably accurate. In other words most of the remaining 

vehicles will simply not be repaired or retrofit because the cost would be too high relative to the 

value of the vehicle.” Fred Sciance, GM, concluded, “although there will be many of these 

vehicles still in service, I concur with your estimate of the number of conversions of R-12 

systems to alternative refrigerants, since most of these vehicles would either be serviced with R12 or left unrepaired.”

The EPA believes the comments received in response to the request for consultation are 

consistent with the proposal put forward in June 20, 2013 Federal Register notice. Therefore, the 

EPA has not changed the conclusions of this Supporting Statement.

3(d) Effects Of Less Frequent Collection

This ICR asks for information to be collected just once per MVAC retrofit.

3(e) General Guidelines

This ICR follows all of OMB’s general guidelines for information collections.

3(f) Confidentiality

This ICR does not ask for any information that would be considered confidential.

3(g) Sensitive Questions

This ICR does not ask any questions concerning sexuality, religious beliefs, or other matters 

usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and SIC Codes

The following is a list of Standard Industrial Classification (SIC) codes and associated industries 

that may retrofit a MVAC and therefore may be affected by information collection requirements 

covered under this ICR. Also listed are the corresponding North American Industry 

Classification System (NAICS) codes available at http://www.census.gov/epcd/www/naics.html.

SIC code: Type of Industry and NAICS code: 

551 New and used car dealers (NAICS code 441110)

554 Gas service stations (NAICS codes 447110 and 447190)
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7532 Top and body repair shops (NAICS code 811121)

7538 General automotive repair shops (NAICS code 811111)

7539 Automotive repair shops not elsewhere classified, including air conditioning and 

radiator specialty shops (NAICS code 811198)

4(b) Information Requested

The Agency will not standardize the label, but rather allow the industry to devise a format that 

accommodates information about the refrigerants on the market. Unique fittings are necessary 

for different refrigerants in order to avoid cross contamination, as is the use of different colored 

labels for each refrigerant. EPA works with refrigerant developers to eliminate the risk of 

duplication. The person conducting the retrofit must apply a label that contains the following 

information to the MVAC in the engine compartment:

• The name and address of the technician and the company performing the retrofit,

• The date of the retrofit,

• The trade name, charge amount, and, when applicable, the numerical designation of the 

refrigerant as determined under the latest version of Standard 34 of the American Society 

of Heating, Refrigerating, and Air-conditioning Engineers (ASHRAE), Inc.,

• The type, manufacturer, and amount of lubricant used,

• If the refrigerant is or contains an ozone-depleting substance, the phrase "ozone depleter",

• If the refrigerant displays flammability limits as measured according to latest version of 

Standard E681 of the American Society for Testing and Materials (ASTM) International, 

the statement "This refrigerant is FLAMMABLE. Take appropriate precautions."

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

The Agency has not developed a format for the label and does not collect and compile the 

information provided on the label.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

EPA has not developed a standard label, but rather the manufacturers have the opportunity to 

produce unique labels to accompany their refrigerant. Much of the information required on the 

labels can be printed with the labels, thereby lessening the burden on the individual service shops, 

many of which are small businesses. These labels may also contain information about the 

specific fittings the service technician should use, with the subject refrigerant, to minimize the 

potential for cross-contamination due to several alternative refrigerant products on the market.

EPA works closely with industry in carrying out these labeling requirements. Proper labeling 

results in considerable savings to industry and the public, since it greatly reduces the chance of 
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refrigerant contamination. There are now 16 alternative refrigerants on the market listed under 

the SNAP program as acceptable replacements for CFC-12 for MVAC. However, only 13 of 

these alternative refrigerants are acceptable for retrofitting MVACs. Considerable costs would 

accrue if refrigerants were contaminated (mixed), including the costs to repair systems which 

failed as a result and the costs to recover, separate, reclaim and/or dispose of contaminated 

refrigerant.

To estimate the total number of retrofits to occur by October 30, 2016, the date this ICR will 

expire, the Agency analyzed publicly available data from the U.S. Department of Transportation, 

Bureau of Transportation Statistics, regarding vehicle sales per year. EPA assumed that the 

penetration of air conditioning in these vehicles rose linearly from 70% in 1970 to 98% in 1998 

and remained at 98% thereafter. EPA assumed that 100% of the MVACs were designed for 

CFC-12 for years 1970 through 1991, 67% for 1992, 33% for 1993, and 0% thereafter. EPA 

assumed the lifetime of service of an air conditioner follows a Poisson distribution with an 

average lifetime of 12 years. Using this method, EPA estimates that there are currently 

approximately 330,000 MVACs, originally designed to use CFC-12, operating in the U.S. EPA 

estimates that in 2014, 2015 and 2016 the number of cars originally designed to use CFC-12 will 

decrease to 170,000, 84,000 and 40,000, respectively. Of these, EPA estimates that 0.1% will be 

retrofitted annually to use alternative refrigerants between October 2013 and September 2016.

Therefore, EPA estimates that in 2014, 2015 and 2016 the numbers of MVACs to be retrofitted 

are 170, 84 and 40, respectively; resulting in a total of 294 MVAC retrofits between October 31, 

2013 and October 30, 2016 (the term after this ICR). The remaining MVACs either (1) will 

continue to operate without service, (2) will continue to operate with minor service including 

refilling with available supplies of CFC-12, (3) will be disposed or recycled along with the entire 

motor vehicle, (4) will cease to function but will not be retrofitted due to economic reasons, or 

(5) have already been retrofitted to an alternative refrigerant and will not be retrofitted again.

EPA estimates the time to complete and apply the required label at 5 minutes per MVAC.

6(b) Estimating Respondent Costs

EPA estimates the cost per label to be $0.10.

EPA estimates the time to complete and apply the label at 5 minutes per MVAC. Based on recent 

consultation with the industry, EPA uses an estimate of $70 per hour loaded labor rate (includes: 

wages paid to the technician, benefits including paid leave, health insurance, retirement savings 

and legally required benefits, and overhead, including office space, furniture, equipment and 

computers, supplies and other business expenses). Thus the loaded labor cost per response is 

approximately $5.83.

6(c) Estimating Agency Burden And Cost

The data required on the label is not submitted to the EPA; therefore, the Agency burden and 

cost is zero.
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6(d) Estimating the Respondent Universe and Total Burden and Costs

The U.S. Department of Labor statistics indicate there will be an average total of 787,000 

automotive service technicians and mechanics (SOC Code Number 49-3023) in the U.S. during 

the years this ICR will be active. EPA estimates that no more technicians than the total number 

of MVACs retrofitted over the 3 years of this ICR will be responsible for retrofitting. If each of 

the 294 MVACs is retrofitted by a different technician, then approximately .037% of technicians 

will be responsible for retrofitting over the three-year term of this ICR.

EPA estimates the time to complete and apply the label at 5 minutes per MVAC, making the 

total burden 24.5 hours (8 hours per year). At an estimated average labor rate of $70 per hour, 

the overall cost associated with the burden hours is $1,715 ($560 per year). The cost for 

designing, typesetting, printing and distributing 294 labels is estimated at $0.10 per label for a 

total of about $30 ($10 per year). Adding the labor and capital costs together yields a total cost 

burden of $1,745.00 ($570 per year).

6(e) Bottom Line Burden Hours And Cost Tables

As indicated in 6(c), there is no burden or cost to the Agency; therefore, the bottom-line burden 

hours and costs are equivalent to the respondent burden hours and costs:

burden hours: 8 hours per year

burden costs: direct: $10 per year

labor: $570 per year

6(f) Reasons for Change in Burden

Based on the decline of CFC-12 MVACs in service today, EPA estimates a continued reduction 

in the number of CFC-12 MVACs retrofits will occur during the next three years. After 1994, 

new cars in the US were no longer sold with CFC-12 MVACs. Thus, the number of operating 

cars with CFC-12 MVACs has decreased since the last ICR renewal. With fewer cars with CFC12 MVACs, there will be fewer retrofits with substitute refrigerants and subject to this ICR.

6(g) Burden Statement

The annual public reporting and record keeping burden for this collection of information is 

estimated to average 5 minutes per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 
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the information. An agency may not conduct or sponsor, and a person is not required to respond 

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

OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

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

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

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

ID No. EPA-HQ-OAR-2013-0402, which is available for online viewing at www.regulations.gov, 

or in person viewing at the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is 

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

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

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

available at www.regulations.gov. This site can be used to submit or view public comments, 

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

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

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

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OAR-2013-0402 and OMB Control Number 2060-0350 in any 

correspondence.