SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
RENEWAL:

"
INFORMATION
COLLECTION
ACTIVITIES
ASSOCIATED
WITH
EPA'S
MOBILE
AIR
CONDITIONER
RETROFITTING
PROGRAM"

EPA
ICR
No.
1774.02
Page
2
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
ICR
is
entitled
"
Information
Collection
Activities
Associated
with
EPA's
Mobile
Air
Conditioner
Retrofitting
Program,"
EPA
ICR
No.
1774.02,
and
OMB
No.
2060­
0350.

1(
b)
Short
Characterization
In
1994,
the
Significant
New
Alternatives
Policy
(
SNAP)
Program
was
enacted,
enabling
the
Agency
to
review
available
substitutes
for
ozone
depleting
substances
(
ODS)
and
determine
their
acceptability.
The
Stratospheric
Protection
Division
is
responsible
for
phasing
out
chemicals
which
damage
the
stratosphere
and
therefore
pose
a
threat
to
human
health
and
the
environment.
Depletion
of
the
stratosphere
has
resulted
in
sharp
increases
in
melanoma,
and
non­
melanoma
cancers
due
to
increased
exposure
to
UBA
and
UVB
Radiation,
and
a
higher
incidence
of
cataracts
(
the
leading
cause
of
blindness).
Under
the
SNAP
program,
companies
submit
applications
for
review
by
the
Stratospheric
Protection
Division
(
SPD).
SPD
has
90
days
to
review
the
product
data
submitted,
and
determine
if
the
substitute
is
acceptable,
unacceptable,
or
if
its
use
must
be
restricted.
SPD
is
reviewing
these
substitutes
for
their
impact
on
human
health
and
the
environment,
ozone
depleting
potential,
atmospheric
lifetime,
global
warming
potential,
and
flammability.
Many
substitutes
are
produced
for
multiple
uses,
and
SPD
must
determine
what
uses
are
appropriate,
and
under
what
conditions.
EPA
does
not
evaluate
the
efficacy
of
the
product
to
achieve
the
results
the
manufacturer
intended.
When
SPD
makes
a
decision
that
substitutes
are
acceptable,
a
Notice
is
published
in
the
Federal
Register
listing
them.
If
the
substitute
is
found
unacceptable
or
use
restrictions
are
necessary,
a
notice­
and­
comment
rulemaking
is
necessary
to
impose
those
restrictions.
The
list
of
substitutes
is
cumulative,
with
revisions
to
the
list
made
quarterly.
A
comprehensive
list
of
substitutes,
their
uses,
and
any
relevant
restrictions
is
maintained
for
distribution
to
interested
parties.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
The
SNAP
program
includes
review
of
potential
alternatives
to
ozone­
depleting
refrigerants
used
for
air
conditioning
motor
vehicles.
With
the
phase
out
of
chlorofluorocarbons
(
CFCs),
and
specifically
CFC­
12,
SPD
faces
the
challenge
of
identifying
alternative
refrigerants
to
keep
approximately
40
million
cars
cool.
Out
of
these
40
million,
EPA
estimates
that
15
million
will
be
retrofitted
to
use
non­
ozone­
depleting
alternative
refrigerants
between
2000
and
2002
(
the
term
of
this
ICR).
The
purpose
of
this
Information
Collection
Request
(
ICR)
is
to
estimate
the
burden
associated
with
the
40
Code
of
Federal
Regulations
Part
82
requirement
that
service
technicians
label
mobile
air
conditioners
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,
sign,
date,
and
place
the
label
on
the
retrofitted
air
conditioner.
This
label
will
acknowledge
that
Page
3
the
retrofitting
has
been
completed,
and
that
the
mobile
air
conditioner
cannot
accept
CFC
refrigerant.

Section
612
of
the
Clean
Air
Act
(
CAA)
requires
EPA
to
promulgate
rules
making
it
unlawful
to
replace
any
ozone­
depleting
substance
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
crosscontamination
and
potential
failure
of
both
air
conditioning
systems
and
recovery/
recycling
equipment.
In
addition,
a
smooth
transition
to
the
use
of
substitutes
strongly
depends
on
the
continued
purity
of
the
recycled
CFC­
12
supply.

b)
Use
and
Users
of
the
Data
The
purpose
of
the
label
is
to
alert
service
technicians
and
car
owners
that
the
car
has
been
retrofitted
to
use
non­
CFC
refrigerant.
The
label
will
provide
essential
information
to
technicians
about
the
specific
refrigerant
used
in
the
air
conditioning
system.
This
information
will
assist
the
technician
in
avoiding
service
practices
that
might
result
in
cross­
contamination
and
system
failure.
As
the
stores
of
CFC
refrigerant
and
recycled
CFC
refrigerant
are
depleted,
increasing
numbers
of
vehicles
are
being
retrofitted
to
use
alternative
refrigerants.

3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
Respondents
and
SIC
Codes
The
following
is
a
list
of
Standard
Industrial
Classification
(
SIC)
codes
and
associated
industries
that
may
be
affected
by
information
collection
requirements
covered
under
this
ICR:

551
New
and
used
car
dealers
554
Gas
service
stations
7532PT
Top
and
body
repair
shops
7538
General
automotive
repair
shops
7539
Automotive
repair
shops
not
elsewhere
classified,
including
air
conditioning
and
radiator
specialty
shops
3(
b)
Information
Requested
The
Agency
will
not
standardize
the
label,
but
rather
allow
the
industry
to
devise
a
format
Page
4
that
accommodates
information
about
the
refrigerants
on
the
market.
Unique
fittings
and
labels
will
be
necessary
for
different
refrigerants
in
order
to
avoid
cross
contamination.
We
recommend
using
different
colored
labels
for
each
refrigerant.
EPA
will
work
closely
with
refrigerant
developers
to
eliminate
the
risk
of
duplication.
The
person
conducting
the
retrofit
must
apply
a
label
to
the
air
conditioning
system
in
the
engine
compartment
that
contains
the
following
information:

o
the
name
and
address
of
the
technician
and
the
company
performing
the
retrofit
o
the
date
of
the
retrofit
o
the
trade
name,
charge
amount,
and
when
applicable,
the
American
Society
of
Heating,
Refrigeration
and
Air­
conditioning
Engineers
(
ASHRAE)
refrigerant
numerical
designation
of
the
refrigerant
o
the
type,
manufacturer,
and
amount
of
lubricant
used
o
if
the
refrigerant
is
or
contains
an
ozone­
depleting
substance,
the
label
must
state
"
ozone
depleter"
o
if
the
refrigerant
displays
flammability
limits
as
measured
according
to
the
American
Society
for
Testing
and
Materials
(
ASTM)
Standard
E681,
the
statement
"
This
refrigerant
is
FLAMMABLE.
Take
appropriate
precautions."

4.
THE
INFORMATION
COLLECTED­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
(
Not
applicable)

5.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
A
Federal
Register
Notice
making
this
supporting
statement
available
for
public
comment
was
published
on
November
10,
1999.
No
comments
were
received.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
EPA
will
not
develop
a
standard
label,
but
rather
the
manufacturers
will
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
when
the
system
is
serviced
at
a
later
date.
We
will
work
closely
with
industry
in
carrying
out
these
labeling
requirements,
because
there
are
several
manufacturers
who
will
have
alternative
refrigerant
products
on
the
Page
5
market.
Proper
labeling
will
result
in
considerable
savings
to
industry
and
the
public,
since
it
will
greatly
reduce
the
chance
of
refrigerant
contamination.
There
are
now
10
alternative
refrigerants
on
the
market
listed
under
the
SNAP
program
as
acceptable
replacements
for
CFC­
12
for
mobile
air
conditioning.
Considerable
costs
would
accrue
if
refrigerants
were
contaminated
(
mixed),
specifically:
costs
to
repair
systems
which
failed
as
a
result;
costs
to
recover,
separate,
and
dispose
of
contaminated
refrigerant.

EPA
estimates
that
there
are
approximately
140,000
service
technicians,
who
will
be
responsible
for
retrofitting
some
15,000,000
cars
by
the
year
2002
(
5,000,000
cars
retrofitted
per
year).
EPA
estimates
the
time
to
complete
and
apply
the
label
at
5
minutes
per
car,
making
the
total
burden
416,667
hours
per
year.
At
$
50
per
hour,
the
overall
cost
associated
with
the
burden
hours
is
$
20,833,333
per
year.
The
cost
for
designing,
typesetting,
printing
and
distributing
5,000,000
labels
is
$
500,000
($
.10
per
label)
per
year.
Adding
the
labor
and
operation
and
maintenance
costs
together
yields
a
total
cost
burden
of
$
21,333,333
per
year.

6(
b)
Burden
Statement
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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
