1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
Information
Collection.

"
National
Volatile
Organic
Compound
Emission
Standards
for
Consumer
Products."
The
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
information
collection
request
(
ICR)
is
1764.03.
This
is
a
renewal
of
a
continuing
ICR,
OMB
No.
2060­
0348,
expiration
date
September
30,
2003.

(
b)
Short
Characterization.

(
i)
Type
of
collection.

The
information
collection
includes
initial
reports
and
periodic
recordkeeping
necessary
for
the
EPA
to
ensure
compliance
with
the
federal
standards
for
consumer
products.
Respondents
are
manufacturers
and
importers
of
consumer
products.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
previous
ICR
1764.02
with
the
following
terms
of
clearance:
"
Before
resubmission
of
this
ICR
for
extension,
the
Agency
should
confirm
estimates
of
the
number
of
affected
sources,
taking
into
account
Agency
experience
with
these
reporting
requirements."
The
EPA
has
consulted
with
the
affected
industry
to
obtain
information
on
the
current
universe
of
affected
sources
and
to
confirm
that
the
burden
estimates
are
reasonable
and
has
determined
that
the
estimated
number
of
respondents
is
correct.

(
ii)
Content
of
reports.

All
manufacturers
and
importers
of
consumer
products
subject
to
this
rule
must
submit
an
initial
report
by
the
compliance
date
of
the
rule.
The
"
Initial
Notification
Report"
must
include
(
1)
company
name;
(
2)
list
of
affected
product
categories;
(
3)
location
of
corporate
headquarters;
(
4)
location
where
formulation
and
batch
records
are
maintained;
(
5)
description
of
any
date
codes
used
on
product
labeling;
and
(
6)
name,
title,
and
signature
of
the
certifying
company
official.

Respondents
have
no
periodic
reporting
requirements.
Another
reporting
requirement,
in
addition
to
the
initial
report,
is
to
provide
an
updated
description
of
any
date
codes
that
may
have
been
revised
subsequent
to
submittal
of
the
initial
report.

Respondents
seeking
a
variance
must
submit
an
application
which
provides
information
to
EPA
necessary
in
determining
whether
to
grant
the
variance.
The
application
would
include
the
specific
grounds
on
which
the
variance
is
sought,
proposed
date
by
which
the
requirements
of
the
rule
will
be
met,
and
a
plan
for
achieving
compliance.
2
Supporting
documentation
is
required
of
companies
who
wish
to
market
a
product
subject
to
the
"
innovative
products"
provisions
of
the
rule.
This
documentation
includes
information
on
VOC
emissions
from
the
use
of
the
product
as
compared
to
emissions
from
a
product
formulated
in
compliance
with
the
table
of
standards.

The
rule
requires
that
the
labels
of
all
subject
consumer
products
display
the
date
of
manufacture.
However,
there
should
be
no
additional
burden
imposed
due
to
this
labeling
requirement
because
manufacturers
routinely
date­
code
their
products.
The
date
can
be
in
coded
form.
All
manufacturers
and
importers
of
subject
products
must
submit
an
explanation
of
all
date
codes
used.
Date
code
explanations
must
be
submitted
with
the
initial
report.
Thereafter,
respondents
must
submit
explanations
of
any
new
date
code
within
30
days
of
its
first
use.

(
iii)
Recordkeeping
requirements.

All
manufacturers
and
importers
of
subject
consumer
products
are
required
to
maintain
records
of
formulations
and
actual
batch
records
for
all
consumer
products
covered
by
the
rule.
If
requested
by
EPA,
the
manufacturer
or
importer
must
demonstrate
to
EPA's
satisfaction
that
actual
product
content
adheres
to
the
formulation(
s)
on
record.

All
information
is
routinely
kept
by
companies
and
consists
of
formulation
data
and
information
on
ingredients
used
in
each
batch.
There
are
no
testing
or
calculations
required
to
create
this
data,
except
for
one­
time
emission
testing
of
charcoal
lighter
materials
formulations.

All
records
required
under
the
rule
must
be
retained
for
3
years.

2.
Need
for
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

The
EPA
is
required
under
Section
183(
e)
of
the
Clean
Air
Act
(
Act)
to
regulate
VOC
emissions
from
the
use
of
consumer
and
commercial
products.
Pursuant
to
Section
183(
e)(
3),
the
EPA
published
a
list
of
consumer
and
commercial
products
and
a
schedule
for
their
regulation
on
March
23,
1995
(
60
FR
15264).
Consumer
products
were
included
in
Group
I
of
the
list,
and
standards
were
promulgated
on
September
11,
1998.
In
the
Administrator's
judgment,
VOC
emissions
from
the
use
of
consumer
products
contribute
to
ground­
level
ozone
formation
in
ozone
nonattainment
areas.

The
reports
and
recordkeeping
activities
required
under
the
rule
enable
the
EPA
to
determine
whether
or
not
consumer
products
manufactured
or
imported
for
use
in
the
U.
S.
meet
the
VOC
content
limits.
Minimal
reporting
is
required.
Initial
reporting
consists
of
information
needed
by
EPA
to
(
1)
identify
the
universe
of
manufacturers
and
importers
subject
to
the
rule;
(
2)
determine
the
date
of
manufacture
of
products;
(
3)
ascertain
the
location
of
formulation
and
batch
records
for
purposes
of
compliance
assurance;
and
(
4)
have
on
record
a
responsible
company
official
as
a
primary
contact.
Notification
of
the
use
of
revised
date
codes
enable
EPA
to
have
access
to
the
most
current
codes.
3
Respondents
seeking
a
variance
are
required
to
submit
an
application
which
includes
the
grounds
upon
which
the
variance
is
being
sought,
the
proposed
date
for
coming
into
compliance,
and
a
plan
for
achieving
compliance.

Companies
desiring
to
market
a
product
under
the
"
innovative
products"
provisions
are
required
to
submit
documentation
of
the
VOC
emissions
from
the
use
of
the
product
as
compared
to
emissions
from
a
product
formulated
in
compliance
with
the
table
of
standards.

Recordkeeping,
consisting
of
maintenance
of
formulation
data
and
batch
records,
enable
EPA
to
determine
whether
a
product
offered
for
sale
was,
in
fact,
manufactured
with
a
VOC
content
in
compliance
with
the
limits.
There
are
no
required
testing
or
calculations
except
for
one­
time
emission
testing
of
charcoal
lighter
fluid
formulations.

(
b)
Use/
Users
of
the
Information.

Agency
enforcement
personnel
will
use
the
information
collected
to
(
1)
identify
manufacturers
and
importers
subject
to
the
rule;
and
(
2)
ensure
that
consumer
products
comply
with
the
VOC
content
standards.
These
activities
are
essential
to
compliance
assurance.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

The
information
collected
pursuant
to
the
regulation
consists
primarily
of
the
VOC
content
for
specific
categories
of
consumer
products.
Several
States
regulate
consumer
products
and
require
certain
recordkeeping
and
reporting
activities.
The
rule
includes
requirements
consistent
with
State
rules
to
the
extent
practical
in
order
to
minimize
the
cumulative
burden
to
the
industry.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
On
June
5,
2003,
EPA
published
a
notice
in
the
Federal
Register
(
68
FR
33688)
entitled,
Agency
Information
Collection
Activities:
Proposed
Collection;
Comment
Request;
National
Volatile
Organic
Compound
Emission
Standards
for
Consumer
Products.
The
purpose
of
the
notice
was
to
announce
that
EPA
was
planning
to
submit
this
continuing
ICR
to
OMB
for
review
and
approval,
and
to
solicit
comments
on
the
proposed
continued
collection.
No
comments
were
received.

(
c)
Consultations
Significant
input
and
information
was
received
from
the
affected
industry,
State
and
local
governments,
and
environmental
groups
during
development
of
the
rule.
In
addition,
in
preparing
to
submit
this
ICR
to
OMB
for
renewal,
EPA
contacted
parties
within
the
affected
industry
to
obtain
information
on
the
universe
of
affected
sources
and
feedback
on
accuracy
of
the
burden
estimates.
4
TABLE
1
CONSULTATIONS
Douglas
Fratz
Consumer
Specialty
Products
Association
Joyce
Graf
The
Cosmetic,
Toiletry,
and
Fragrance
Association
Douglas
Raymond
Sherwin
Williams
Company
F.
H.
Brewer
S.
C.
Johnson
&
Son
Eileen
Moyer
Reckitt­
Benckiser
(
d)
Effects
of
Less
Frequent
Collection.

This
ICR
includes
one­
time
initial
reports
by
all
manufacturers
and
importers
of
subject
consumer
products.
Periodic
reporting
is
not
required.
Consequently,
less
frequent
reporting
is
not
an
issue.

Formulation
and
batch
records
are
required
to
be
kept
on
a
per­
product
basis.
This
information
is
normally
maintained
by
consumer
product
manufacturers.
Because
there
is
no
analytical
test
method
for
determining
the
VOC
content
of
consumer
products,
maintaining
records
of
each
batch
is
essential
for
compliance
assurance.
Accordingly,
lesser
degrees
of
recordkeeping
would
make
compliance
determination
difficult
if
not
impossible.

(
e)
General
Guidelines.

This
ICR
adheres
to
the
guidelines
for
Federal
data
requesters,
as
provided
at
5
CFR
1320.6.
The
regulation
requires
that
records
be
maintained
for
3
years.
This
period
of
record
retention
is
consistent
with
other
ongoing
similar
programs
and
allows
enough
record
history
for
inspectors
to
adequately
monitor
compliance.

(
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
36092,
September
1,
1976;
amended
by
43
FR
39999,
September
8,
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.
5
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes.

Respondents
to
this
information
collection
are
manufacturers
and
importers
of
consumer
products.
Manufacturers
of
consumer
products
fall
within
standard
industrial
classification
(
SIC)
284,
including
"
Soap,
Detergents,
Cleaning
Preparations"
and
"
Perfumes,
Cosmetics,
and
Other
Toilet
Preparations;"
SIC
287,
"
Agricultural
Chemicals;"
and
SIC
289,
"
Miscellaneous
Chemical
Products."
The
appropriate
North
American
Industrial
Classification
System
(
NAICS)
codes
are
3256,
"
Soap,
Cleaning
Compounds,
and
Toilet
Preparations;"
and
3259,
"
Other
Chemical
Products
and
Preparations."

(
b)
Information
Requested.

(
i)
Data
items.

Table
2,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements.

TABLE
2
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
Recordkeeping
°
Records
of
formulations
in
use
59.209(
a)
°
Records
of
composition
of
each
batch
of
production
59.209(
a)
°
Records
of
charcoal
lighter
materials
testing
59.209(
c)

Reporting
°
Initial
report
59.209(
d)
°
Report
of
change
of
date
coding
system
59.209(
e)
°
Application
for
variance
59.206(
a)
°
Documentation
of
"
innovative
products"
59.204(
d)

(
ii)
Respondent
Activities.

The
respondent
activities
required
for
all
manufacturers
and
importers
of
regulated
products
are
listed
in
Table
3.
6
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management.

(
a)
Agency
Activities.

A
list
of
activities
required
of
the
EPA
is
provided
in
Table
4.

(
b)
Collection
Methodology
and
Management
The
information
collected
under
this
rule
will
be
maintained
in
a
computerized
database.
As
noted
in
section
2(
b)
of
this
ICR,
the
information
collected
is
a
necessary
part
of
compliance
determination.

(
c)
Small
Entity
Flexibility.

Under
the
rule,
there
are
no
specific
provisions
for
small
entity
flexibility.
However,
companies
subject
to
the
rule
can
apply
for
variances
in
cases
where
the
company,
because
of
extraordinary
reasons
beyond
reasonable
control,
cannot
comply
with
the
rule.
While
all
variance
applications
will
receive
close
scrutiny,
EPA
will
give
full
consideration
to
the
special
needs
of
small
manufacturers
and
importers.

(
d)
Collection
Schedule.

By
December
10,
1998
[
December
10,
1999
for
consumer
products
that
are
also
regulated
under
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)],
or
within
30
days
of
becoming
subject
to
the
rule,
manufacturers
and
importers
of
regulated
products
must
submit
to
EPA
an
Initial
Notification
Report.
The
content
of
this
report
is
outlined
in
section
1(
b)(
ii)
of
this
ICR.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Because
this
is
a
renewal
of
an
existing
ICR,
these
estimates
represent
the
average
annual
burden
that
will
be
incurred
by
the
affected
industry
during
the
3­
year
period
beginning
in
October
2003.
Consequently,
the
requirement
for
each
regulated
entity
to
submit
an
initial
notification
report
during
the
first
year
the
rule
was
effective
will
have
already
been
met
and
is
not
considered
here.

(
a)
Estimating
Respondent
Burden.

The
average
annual
burden
estimates
for
reporting
and
recordkeeping
requirements
for
all
manufacturers
and
importers
of
subject
products
are
presented
in
Table
3.
These
numbers
were
derived
from
estimates
based
on
the
EPA's
experience
with
other
standards,
and
from
information
obtained
from
the
industry
representatives
listed
in
Table
1.
These
estimates
represent
the
average
annual
burden
that
will
be
incurred
by
the
affected
industry
for
the
3
years
beginning
in
October
2003.
The
following
assumptions
were
used
to
estimate
the
respondent
burden:
7

Only
incremental
burden
imposed
by
this
rule
was
considered.
Recordkeeping
activities
already
performed
by
sources
regardless
of
the
existence
of
this
rule
are
not
included
in
the
burden
calculation.


The
burden
of
planning
for
recordkeeping
will
be
2
hours
per
year.


The
burden
of
maintaining
batch
records
will
be
8
hours
per
month.


The
burden
of
maintaining
records
of
charcoal
lighter
material
test
results
will
be
1
hour
per
year
(
b)
Estimating
Respondent
Costs.

Table
3
also
presents
estimated
costs
for
the
required
recordkeeping
and
reporting
activities.
Industry
labor
rates
are
based
on
Table
2
of
Bureau
of
Labor
Statistics
Employment
Cost
Trends.
Overhead
of
100
percent
was
added,
resulting
in
the
following
labor
rates:
management
($
85);
technical
($
59);
and
clerical
($
37).

There
are
no
capital
costs
associated
with
the
rule.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
estimated
as
an
incidental
part
of
the
standard
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
respondents
are
required
under
section
183(
e)
of
the
Act,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
a
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and
is
not
attributable
to
this
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
costs
associated
with
the
review
of
reported
information,
as
presented
in
Table
4.

Labor
rates
and
associated
costs
are
based
on
Office
of
Personnel
Management
Table
2003­
RUS.
Overhead
of
60
per
cent
was
added,
resulting
in
the
following
labor
rates:
management
(
GS15
­
$
72);
technical
(
GS13
­
$
51);
and
clerical
(
GS7
­
$
24).
The
number
of
management
hours
is
assumed
to
equal
5
percent
of
the
number
of
technical
hours;
the
number
of
clerical
hours
is
assumed
to
equal
1
percent
of
the
number
of
technical
hours
(
see
Table
4).
8
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
following
assumptions
were
used
to
estimate
the
respondent
universe
and
total
burden
and
costs
for
industry
to
comply
with
the
various
requirements
of
the
rule:


Total
number
of
affected
sources
is
3000.


Total
number
of
respondents
will
be
367
as
follows:


Number
of
respondents
performing
"
new"
recordkeeping
because
of
this
rule
will
be
10
percent
of
the
total
number
of
affected
sources,
or
about
300
per
year.


Number
of
"
new"
respondents
submitting
the
one­
time
Initial
Notification
Reports
will
be
1
percent
of
the
total
number
of
affected
sources,
or
about
30
per
year
(
one­
time
Initial
Notification
Reports
already
will
have
been
submitted
by
existing
sources
subject
to
the
December
10,
1998
and
December
10,
1999
compliance
dates).


Number
of
respondents
submitting
notifications
of
change
of
date
code
system
will
be
1
percent
of
the
affected
sources,
or
about
30
per
year.


Number
of
respondents
submitting
variance
applications
will
be
5
per
year.


Number
of
respondents
submitting
innovative
products
documentation
will
be
2
per
year.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables.

(
i)
Respondent
Tally
The
bottom
line
respondent
burden
hours
and
cost,
presented
in
Table
3,
are
calculated
by
summing
the
person­
hours
column
and
by
summing
the
cost
column.
The
annual
burden
and
cost
averaged
over
the
3
years
beginning
in
October
2003
are
29,613
hours
and
$
1,104,057.
The
average
burden
equals
the
total
burden
(
29,613
hours)
divided
by
the
number
of
respondents
(
367
respondents),
or
about
81
hours
per
respondent.

(
ii)
Agency
Tally
The
bottom
line
Agency
burden
and
cost
are
presented
in
Table
4.
The
number
of
management
hours
is
assumed
to
equal
5
percent
of
the
number
of
technical
hours;
the
number
of
clerical
hours
is
assumed
to
equal
1
percent
of
the
number
of
technical
hours.
Agency
cost
for
each
activity
is
calculated
by
summing
the
technical,
management,
and
clerical
costs
for
each
burden
item.
The
estimated
annual
burden
and
cost
averaged
over
the
3
years
beginning
in
October
2003
are
123
hours
and
$
6,391.

(
iii)
Variations
in
the
annual
bottom
line.

The
EPA
does
not
anticipate
any
significant
annual
variations
in
the
bottom
line
after
the
first
year
the
rule
is
in
effect.
9
(
f)
Reasons
for
Change
in
Burden.

This
renewal
of
a
continuing
ICR
includes
the
following
one­
time
burden
and
cost
items:
reading
the
rule,
the
initial
report,
the
explanation
of
date
codes,
planning
activities,
and
modifying
product
labels.
To
develop
the
estimates
of
annual
average
burden,
these
one­
time
activities
were
averaged
over
3
years,
beginning
after
the
rule
has
been
effective
for
over
a
year.
Therefore,
the
EPA
assumes
that
the
vast
majority
of
one­
time
Initial
Notification
Reports
already
will
have
been
submitted
by
October
2003.
Consequently,
only
"
new"
notifications
will
be
submitted
during
the
period
covered
by
this
ICR
renewal.
The
assumptions
used
as
a
basis
for
the
burden
calculations
more
fully
explain
this
concept.
In
addition,
EPA's
experience
since
the
effective
date
of
the
rule
indicates
that
the
anticipated
number
of
variances
and
innovative
product
exemptions
sought
will
be
lower
than
originally
estimated.

(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
81
hours
per
respondent.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0087,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
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,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0087)
and
OMB
control
number
(
2060­
0348)
in
any
correspondence.
10
TABLE
3
INDUSTRY
BURDEN
FOR
THE
CONSUMER
PRODUCTS
RULE
Burden
Item
(
A)
Person
Hours
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
(
C)

Person
Hours
per
Respondent
per
Year
(
C=
AxB)
Dollars
per
Hour
(
D)
Respondents
per
Year
(
E)
Total
Hours
per
Year
(
E=
CxD)
Total
Cost
per
Year
($)

Reporting
Read
instructions
2
1
2
85
30
60
5,100
Gather
information
1
1
1
59
30
30
1,770
Initial
report
1
1
1
37
30
30
1,110
Update
date
code
1
1
1
37
30
30
1,110
Variance
application
2
1
2
85
5
10
850
Innovative
products
appl.
24
1
24
59
2
48
2,832
Recordkeeping
Read
instructions
(
above)

Plan
activities
2
1
2
85
300
600
25,500
Implementation
8
12
96
37
300
28,800
1,065,600
Charcoal
lighter
results
1
1
1
37
5
5
185
Total
Industry
Burden
29613
$
1,104,057
11
TABLE
4
AGENCY
BURDEN
FOR
THE
CONSUMER
PRODUCTS
RULE
Burden
Item
(
A)
Person
Hours
per
Occurrence
(
B)
Occurrences
per
Year
(
C)

Person
Hours
per
Year
@
$
51
(
Technical)

C
=
A
x
B)
(
D)

Person
Hours
per
Year
@
$
72
(
Management)

(
D
=
C
x
0.05)
(
E)

Person
Hours
per
Year
@
$
24
(
Clerical)

(
E
=
C
x
0.01)
(
F)
Total
Person
Hours
per
Year
(
C+
D+
E)
(
G)
Total
Cost
per
Year
($)

Initial
report
1.0
30
30
1.5
0.3
31.8
1660
Revise
date
code
1.0
30
30
1.5
0.3
31.8
1660
Variance
applic.
8.0
5
40
2.0
0.4
42.4
2194
Innovative
prod.
8.0
2
16
0.8
0.16
16.96
877
Total
Burden
67
116
5.8
1.16
122.96
$
6391
