Supporting Statement for Reporting and Recordkeeping Requirements for
National Volatile Organic Compound Emission Standards for Automobile
Refinish Coatings

1.  Identification of the Information Collection

1(a)  Title of Information Collection.

	National Volatile Organic Compound Emission Standards for Automobile
Refinish Coatings.  The information collection request (ICR) number is
1765.06.  The OMB control number is 2060-0353.  This is a renewal ICR.

2(b)  Short Characterization/Abstract.

	All manufacturers and importers of coatings and coating components
subject to 40 CFR Part 59 Subpart B--National Volatile Organic Compound
Emission Standards for Consumer and Commercial Products must submit an
initial report.  The initial report must include the name and mailing
address of the manufacturer or importer.  The rule requires that
containers of all subject automobile refinish coatings and coating
components display the date of manufacture or a code indicating the date
of manufacture.  All manufacturers and importers of subject coatings and
coating components must submit an explanation of all date codes used on
automobile refinish coating and coating component containers.  Date code
explanations can be submitted with the initial report.  Thereafter,
respondents must submit explanations of any new date codes within
30 days of their first use.

	The information collection includes initial and periodic reporting
necessary for the EPA to ensure compliance with the promulgated federal
rule for automobile refinish coatings.  The rule will be enforced
through random sampling of coatings to determine VOC content. 
Respondents are manufacturers and importers of automobile refinish
coatings and coating components.

2.  Need for and Use of the Collection

2(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 (60
FR 15264).  Automobile refinish coatings were included in Group 1 of the
list.  The standards for such coatings were promulgated on September 11,
1998 (63 FR 48806) and are codified at 40 CFR part 59, subpart B.

	The reports required under the rule enable the EPA to identify all
coating and coating component manufacturers and importers in the United
States, and to determine which coatings and coating components are
subject to the rule based on dates of manufacture.

2(b)  Practical Utility/Users of the Data.

	Agency enforcement personnel will use the information collected
to identify 

manufacturers and importers subject to the rule and to determine which
coatings and coating components are subject to the rule by dates of
manufacture.

3.  Nonduplication, Consultations, and Other Collection Criteria

	3(a)  Nonduplication.

	The information collected pursuant to the rule is not collected by any
other Federal agency.  Several States regulate automobile refinish
coatings and require certain recordkeeping and reporting activities. 
These State rules generally affect body shops; the federal rule affects
coating and coating component manufacturers and importers.  There is
much more recordkeeping associated with the State rules because of the
large number of body shops in the country.  The federal rule affects
approximately 30 manufacturers and importers, and contains reporting
requirements different from those of the State rules.



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

	Notice of this ICR appeared in the March 23, 2010, Federal Register 75
FR 13759.  The notice contained a 60-day public comment period, which
ended on May 24, 2010.  The EPA received no comments.

3(c)  Consultations.

	Input and information was solicited from the affected industry and
State and local governments during the renewal process, some of whom are
listed in table 3.



3(d) Effects of Less Frequent Collection.

	Less frequent information collection would decrease the margin of
assurance that manufacturers are continuing to meet the standards.  This
ICR includes one-time initial reports.  After the initial report, the
only reports required are those explaining any new date codes.  To
determine whether a coating is subject to the rule, explanations of date
codes are necessary.

	3(e)  General Guidelines.

	This ICR adheres to the guidelines for Federal data requestors, as
provided at 5 CFR 1320.6.

	3(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).

3(g)  Sensitive Questions.

	None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/NAICS Codes.

	Respondents to this information collection are manufacturers and
importers of automobile refinish coatings and coating components. 
Manufacturers of automobile refinish coatings and coating components
fall within standard industrial classification (SIC) 2851, "Paints,
Varnishes, Lacquers, Enamels, and Allied Products" and North American
Industry Classification System (NAICS) code 325510, “Paint and Coating
Manufacturing.”  Importers of automobile refinish coatings and coating
components fall within SIC 5198, "Wholesale Trade:  Paints, Varnishes,
and Supplies," NAICS code 422950, “Paint, Varnish and Supplies
Wholesalers,” and NAICS code 444120, “Paint and Wallpaper Stores.”


4(b)  Information Requested.

		(i)  Data items.

  

The reporting requirements of the rule are listed below.

		Reports					Regulation Reference

		Initial report						59.426(a)

		Explanation of date codes				59.426(a)

		(ii)  Respondent Activities.  

The respondent activities required are listed in the first column of
table 1.



5.  The Information Collected--Agency Activities, Collection
Methodology, and Information Management.



5(a)  Agency Activities.

	A list of activities required of the EPA is provided in table 2.  

	5(b)  Collection Methodology and Managements

	The information collected under this rule will not warrant being
maintained on a computerized database since the reports are so few in
number.  Also, since the reported information is simple and
straightforward, no standardized reporting forms will be developed.

	5(c)  Small Entity Flexibility.

	Since the reporting requirements of the rule are minimal, no
alternative reporting requirements are instituted for small entities.

	5(d)  Collection Schedule.

	All subject manufacturers and importers must submit to the EPA an
explanation of all date codes displayed on containers of automobile
refinish coatings and coating components within 30 days of first use,
or within 180 days of becoming subject to the rule, whichever is later.
 All manufacturers and importers of subject coatings and coating
components must submit an initial report within 180 days of becoming
subject to the rule.

6.  Estimating the Burden and Cost of the Collection

	6(a)  Estimating Respondent Burden.

	The average annual burden estimates for reporting requirements are
presented in table 1 for all manufacturers.  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 3.  These estimates represent the average annual burden that will
be incurred by the affected industry over a 3-year period.  The hours
shown in column A of table 1 are the burden estimate per manufacturer. 


	6(b)  Estimating Respondent Costs.

		(i)  Estimating Labor Costs.

	Table 1 also presents estimated costs for the required reporting
activities.  Labor rates and associated overhead costs are based on
hourly rates of $99 for management personnel, $70 for technical
personnel, and $44 for clerical personnel.  These rates were estimated
using a March 2010 civilian wage table from the Bureau of Labor
Statistics, multiplied by 1.6 to account for benefits and overhead.

		(ii)  Estimating Capital and Operations and Maintenance Costs.

There are no capital or operations and maintenance costs associated with
these reporting activities.

	6(c)  Estimating Agency Burden and Cost.

	Because reporting requirements on the part of respondents are required
under section 112 of the Act, no operational costs will be incurred by
the Federal government.  The only costs that the Federal government will
incur are costs associated with the review of reported information, as
presented in table 2.  Hourly labor rates are estimated at $99 for
management personnel, $71 for technical personnel, and $34 for clerical
personnel.  These rates were determined by multiplying the hourly rates
from the 2010 General Schedule (GS) Locality Pay Tables (tenth step) for
GS-15 (management), GS-13 (technical), and GS-7 (clerical), by a factor
of 1.6 to account for benefits and overhead.

6(d)  Estimating Respondent Universe and Total Burden Costs

	The EPA estimates that there are approximately 30 automobile refinish
coating and coating component manufacturers and importers.  Two
requirements in the rule create a burden on respondents: submitting an
initial report, and submitting an explanation of date codes used on
coating and coating component containers.  The EPA estimates that one
new coating or coating component manufacturer or importer will become
affected by the rule each year.  A new regulated entity must submit an
initial report and provide an explanation of any dates codes that are
used to indicate the manufacture date of its products.  The EPA also
estimates that 10 percent (3) of the existing regulated entities will
change their date coding system each year and will have to submit an
explanation of the new system.

	6(e)  Bottom Line Burden Hours and Costs/Master Tables.

		(i)  Respondent Tally.

The bottom line respondent burden hours and costs, presented in table 1,
are calculated by summing the person-hours column and by summing the
cost column.  The annual burden and cost averaged over 3 years is 14
hours and $1,038. 

		(ii)  The Agency Tally.

The bottom line Agency burden and cost, presented in table 2 is
calculated in the same manner as the respondent burden and cost.  The
estimated annual burden and cost averaged over 3 years is 4 hours and
$232.

		(iii)  Variations in the annual bottom line.  

This ICR includes reading the rule, the initial report, and date code
explanations as one-time burden and cost items.  To develop the
estimates of annual average burden, these one-time activities were
averaged over 3 years.  The only other activity is reporting of any new
date code explanations.

6(f)  Reasons for Change in Burden.

	There are no changes to the burden estimates.  

6(g)  Burden Statement.

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 4 hours per response
per year.  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.
EPA-HQ-OAR-2003-0120, which is available for public 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 and Radiation Docket and Information Center
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, DC 20503,
Attention: Desk Office for EPA.  Please include the EPA Docket ID No. 
EPA-HQ-OAR-2003-0120 and OMB control number 2060-0353.Table 1.  AVERAGE
ANNUAL RESPONDENT BURDEN AND COST OF REPORTING OVER THREE YEARS 

	A	B	C

D	E	F

Burden Item	

Person Hours

Per Occurrence

(hrs/man.)	

Number of

Occurrences

Per Respondent

Per Year	

Person Hours

Per Respondent

Per Year (a)

(C=AxB)	

Dollars

Per Hour

(a)	

Respondents

Per Year (b)	

Total Hours

Per Year

(E=CxD)	

Total Cost

Per Year (c)

1. Applications	Not Applicable







2. Surveys and Studies	Not Applicable







3. Reporting Requirements







	     A. Read Instructions	2	1	2	70	1	2	$140

     B. Gather Existing Information	Included in 3.C







     C. Write Report







	          Initial Report	2	1	2	99	1	2   (d)	$198

          Date Code Explanation	4	1	4	70	1	4   (d)	$280

          Update Date Codes	2	1	2	70	3	6   (e)	$420

4. Recordkeeping Requirements	Not Applicable







5. Labeling (f)	Not Applicable







Total





14	$1038



a All tasks are assumed to be performed by a technical person ($70/hr)
unless otherwise noted.

b Total number of manufacturers was estimated to be 30.

c Costs were calculated by multiplying the total number of hours by the
hourly wages.

d This assumes there is one new regulated entity every year.

e Assumed that 10% of manufacturers will update their codes each year.

f Although the rule requires the date (or code) to appear on the label,
such labeling is already performed. 

Table 2.  AGENCY BURDEN AND COSTS

	A	B	C	D	E	F

Reports	EPA Hours Per 

Occurrence	Occurrences

Per Year	Person Hours

Per Year

(Technicall)

C=AxB	Person Hours

Per Year

(Management)

D=Cx0.05	Person Hours

Per Year

(Clericall)

E=Cx0.1	Total Cost

Per Year (a)

Initial Report	1	1	1	0.05	.1	$79

Date Code Report	0.5	1	0.5	0.03	0.05	$40

Date Code Updates	0.5	3	1.5	0.08	0.15	$113

Total

	3	0.16	0.3	$232



a Labor rates: technical, $71/hr; management, $99/hr; clerical, $34/hr.

Table 3.  Consultations

Industry Representatives						Email

Robert Redding, Automotive Service Association			b.redding@att.net

Jim Sell, National Paint and Coatings Association			JSell@paint.org

State Representatives

Dave Nordberg, Oregon Department of Environmental Quality
nordberg.dave@deq.state.or.us

Ed Wong, California Air Resources Board				ewong@arb.ca.gov

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