SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
STRATOSPHERIC
OZONE
PROTECTION,
SERVICING
OF
MOTOR
VEHICLE
AIR
CONDITIONERS
A.
JUSTIFICATION
1.
Identification
of
Information
Collection
a)
Title:
"
Servicing
of
Motor
Vehicle
Air
Conditioners"

OMB
Control
Number:
2060­
0247
EPA
Number:
1617.04
b)
Short
Characterization/
Abstract
History.
In
1992,
EPA
developed
regulations
under
section
609
of
the
Clean
Air
Act
Amendments
of
1990
(
Act)
for
the
recycling
of
chlorofluorocarbons
in
motor
vehicle
air
conditioners.
These
regulations
were
published
in
57
FR
31240,
and
are
codified
at
40
CFR
Subpart
B
(
§
82.30
et
seq.).
The
information
required
to
be
collected
under
the
Section
609
regulations
is
described
below.
This
information
is
currently
approved
for
use
through
May
31,
2002.
This
supporting
statement
is
submitted
to
justify
an
extension
of
the
approval
of
use
of
this
information.
Pursuant
to
new
requirements
under
the
Paperwork
Reduction
Act,
a
notice
was
published
in
the
Federal
Register
on
December
20,
2001,
announcing
the
intent
to
extend
the
renewal
of
this
Information
Collection
Request
and
requesting
comment
on
the
renewal.
Descriptions
of
the
type
of
recordkeeping
and
reporting
requirements
mandated
by
section
609
are
summarized
below
in
this
section.
The
chart
located
at
the
end
of
this
document
displays
the
cost
of
each
of
these
requirements

Technician
training
and
certification.
According
to
Section
609(
b)(
4)
of
the
Act,
automotive
technicians
are
required
to
be
certified
in
the
proper
use
of
recycling
equipment
for
servicing
motor
vehicle
air
conditioners.
Certification
programs
must
meet
EPA
standards.
The
Global
Programs
Division
(
GPD)
requires
that
certification
programs
send
full
sets
of
their
training
materials
to
EPA
for
approval.
The
information
requested
is
used
by
the
GPD
to
guarantee
a
degree
of
uniformity
in
the
testing
programs
for
motor
vehicle
service
technicians.
The
technician
certification
program
must
provide
the
GPD
with
a
copy
of
their
testing
program,
including
test
procedures
for
grading,
the
score
required
to
pass,
and
any
training
tools
or
visual
aides
provided.
Due
to
rapid
developments
in
technology,
the
Agency
requires
that
each
approved
technician
certification
program
will
review
and
update
their
program
every
two
years.
A
summary
of
the
review
report
is
required
to
be
submitted
to
EPA.
After
the
test
has
been
approved
by
EPA,
a
­
2
B
hard
copy
remains
on
file
in
the
GPD.
Currently,
about
25
testing
programs
have
been
approved
by
EPA
to
train
technicians
in
the
proper
use
of
recycling
equipment.

Approved
independent
standards
testing
organizations.
In
addition,
Section
609(
b)(
2)(
A)
of
the
Act
requires
independent
laboratory
testing
of
recycling
equipment
to
be
certified
by
EPA.
The
GPD
requires
independent
laboratories
to
submit
an
application
that
proves
their
general
capacity
to
certify
equipment
to
meet
the
Society
of
Automotive
Engineers
(
SAE)
J
standards
for
recycled
refrigerant.
The
information
requested
is
used
by
the
GPD
to
approve
independent
laboratories
that
can
assure
an
industry
accepted
standard
of
quality
in
recycling
and
recovery
equipment.
An
independent
laboratory
that
is
interested
in
testing
recycling
and
recovery
equipment
must
submit
an
application
to
the
GPD
that
includes
a
list
of
testing
procedures
and
equipment
that
will
be
used
in
testing.
Once
an
independent
laboratory
has
been
approved
by
EPA,
the
application
is
kept
on
file
in
the
GPD.
Two
laboratories,
Underwriters
Laboratories
Inc.
and
ETL
Testing
Laboratories,
are
currently
approved
to
test
recycling
equipment.
Note
that
EPA
does
not
anticipate
that
any
organizations
will
apply
to
EPA
in
the
future
to
become
approved
independent
standards
testing
organizations.
Therefore,
annual
hours
and
costs
related
to
information
submitted
by
these
organizations
have
been
eliminated.

Substantially
identical
equipment.
Finally,
Section
609(
b)(
2)(
B)
of
the
Act
allows
equipment
that
was
purchased
before
the
proposal
of
the
regulations
to
be
approved
by
EPA
if
it
is
substantially
identical
to
equipment
that
has
been
certified
by
an
EPA
approved
independent
laboratory.
This
measure
is
designed
to
incorporate
or
"
grandfather"
older
equipment
that
has
not
been
submitted
to
an
independent
laboratory
for
testing.
The
equipment
manufacturer
or
owners
may
submit
the
following
to
the
GPD:
an
application
and
supporting
documents
that
includes
process
flow
sheets,
a
list
of
equipment
components
and
any
other
information
which
would
indicate
that
the
equipment
is
capable
of
cleaning
the
refrigerant
to
standards
set
forth
in
Appendix
A
to
the
regulations
or
recovering
refrigerant
to
standards
set
forth
in
Appendix
B
to
the
regulations.
The
information
provided
allows
EPA
to
determine
if
the
equipment
is
substantially
identical
to
certified
equipment
and
is
kept
on
file
at
the
GPD.

Certification,
reporting
and
recordkeeping.
To
facilitate
enforcement
under
Section
609,
EPA
has
developed
several
recordkeeping
requirements.

First,
Section
609(
d)(
3)­(
4)
of
the
Act
requires
that
by
January
1,
1992,
all
entities
that
service
motor
vehicle
air
conditioners
for
consideration
must
have
acquired
approved
refrigerant
recycling
equipment.
The
establishment
must
have
submitted
to
the
Administrator
on
a
one­
time
basis
a
certificate
that
provides
the
following
information:
the
name
of
the
equipment
owner,
the
address
of
the
service
establishment
where
the
equipment
will
be
used,
and
the
make,
model,
year,
and
serial
number
of
the
equipment.
The
certification
should
have
been
submitted
on
or
before
January
1,
1993.
The
information
is
used
by
the
GPD
to
verify
compliance
with
Section
609
of
the
Act.
­
3
B
Second,
establishments
that
own
recover­
only
equipment
must
maintain
records
of
the
name
and
address
of
the
facility
that
is
reclaiming
their
refrigerant.

Third,
any
person
who
owns
approved
refrigerant
recovery
or
recycling
equipment
must
retain
records
demonstrating
that
all
persons
authorized
to
operate
the
equipment
are
currently
certified
technicians.

Fourth,
any
person
who
sells
or
distributes
refrigerant
that
is
in
a
container
of
less
than
20
pounds
must
verify
that
the
purchaser
is
a
certified
technician,
unless
the
purchase
of
small
containers
is
for
resale
only.
In
that
case,
the
seller
must
obtain
a
written
statement
from
the
purchaser
that
the
containers
are
for
resale
only,
and
must
indicate
the
purchaser's
name
and
business
address.
In
the
case
of
certified
technicians
purchasing
small
containers
of
refrigerant
for
servicing
motor
vehicles,
the
submission
of
a
written
statement
is
not
required
and
there
are
no
recordkeeping
requirements.
Technicians
must
be
prepared
to
show
proof
of
technician
certification
when
purchasing
small
containers.
These
records
must
be
kept
by
the
establishment
for
a
period
of
up
to
three
years.

2.
Need
for
and
Use
of
the
Collection
a)
Authority
for
the
Collection
The
information
requested
for
all
entities
that
service
motor
vehicle
air
conditioning
is
required
by
Section
609(
d)
of
the
Act.
Proposed
automotive
technician
certification
programs
are
required
to
be
approved
by
EPA
in
Section
609(
b)(
4).
Section
609(
b)(
2)(
A)
requires
the
approval
of
independent
laboratories
by
EPA.
The
submission
of
data
for
EPA
determination
of
substantially
identical
equipment
is
addressed
by
Section
609(
b)(
2)(
B).
The
recordkeeping
requirements
for
the
motor
vehicle
recycling
program
are
derived
from
Section
114
of
the
Act.
b)
Practical
Utility/
Users
of
the
Data
Motor
vehicle
air
conditioning
service
establishments
are
required
by
Section
609
of
the
Act
to
certify
that
they
have
purchased
recycling
and
recovery
equipment
by
January
1,
1992.
The
GPD
uses
the
certificates
to
confirm
compliance
with
Section
609.

In
order
for
technicians
to
use
recycling
and
recovery
equipment,
they
must
pass
a
certification
test
as
stipulated
in
Section
609.
In
order
reduce
ozone
depletion
the
Agency
has
therefore
established
minimum,
national
standards
for
technician
certification
of
the
Clean
Air
Act.
The
GCD
uses
the
information
submitted
by
technician
certification
programs
to
determine
if
the
programs
meet
the
standards
established
by
the
Agency.
In
addition,
the
GCD
uses
certification
program
information
to
ensure
that
Agency
are
at
least
as
stringent
as
the
SAE
J
standards
of
the
Society
of
Automotive
Engineers,
or
the
current
national
standard.

Because
of
the
rapidly
changing
nature
of
the
motor
vehicle
air
conditioning
market,
EPA
requires
that
technician
certification
programs
conduct
internal
reviews
and
update
their
program
­
4
B
every
two
years.
By
requiring
a
summary
of
the
review
to
be
reported
to
EPA,
the
Agency
can
assure
the
accuracy
of
the
information
and
maintain
parity
among
testing
programs.

The
Agency
is
required
to
either
test
refrigerant
recycling
equipment
itself
or
approve
independent
laboratories
to
test
equipment.
In
order
to
protect
the
purity
of
the
pool
of
recycled
refrigerant
for
use
in
the
motor
vehicles,
the
Agency
is
required
to
guarantee
that
all
recycling
and
recovery
equipment
meets
minimum
national
standards.
Since
EPA
does
not
have
the
capabilities
to
test
recycling
or
recovery
equipment
on
a
national
scale,
the
Agency
relies
on
private
laboratories
to
test
equipment.
Currently,
Underwriters
Laboratories
(
UL)
and
ETL
Testing
Laboratories
(
ETL)
certify
equipment
on
a
voluntary
basis.
The
Agency
established
a
program
to
evaluate
and
approve
UL
and
ETL
procedures
in
addition
to
other
laboratories
that
may
request
approval.
The
Stratospheric
Protection
Division
uses
the
information
provided
by
independent
laboratories
to
evaluate
their
capability
to
test
recycling
and
recovery
equipment.
The
Agency
has
required
the
submission
of
information
that
will
enable
it
to
insure
that
all
approved
laboratories
can
test
equipment
under
Agency
standards
and
the
accepted
SAE
J
standards.
EPA
has
only
requested
information
which
will
verify
whether
or
not
a
laboratory
is
capable
of
testing
equipment
to
these
minimum
national
standards.

EPA
may
certify
recycling
or
recovery
equipment
that
was
not
tested
by
an
independent
laboratory
In
order
for
EPA
to
certify
equipment,
the
Agency
must
be
provided
with
information
that
proves
the
ability
of
the
equipment
to
recycle
or
recover
refrigerant
according
to
the
SAE
J
standards.
The
GPD
uses
the
information
submitted
by
an
equipment
owner
or
an
equipment
manufacturer
to
determine
if
their
equipment
is
substantially
identical
to
equipment
certified
by
an
EPA
approved
independent
laboratory.

EPA
requires
service
establishments
to
record
the
name
and
address
of
any
off
site
facility
which
is
reclaiming
their
refrigerant.
Inspectors
from
the
Office
of
Enforcement
and
Compliance
Assurance
use
the
information
maintained
by
service
establishments
to
verify
their
compliance
with
the
motor
vehicle
air
conditioning
recycling
program.

When
distributors
purchase
small
containers
of
refrigerant,
the
seller
must
be
provided
with
a
written
statement
attesting
to
the
fact
that
the
small
containers
were
purchased
for
resale
only.
The
seller
may
keep
the
initial
statement
from
a
distributor
and
update
the
file
with
the
amounts
of
refrigerant
purchased
in
the
form
of
small
containers.
These
records
are
used
by
inspectors
from
the
Office
of
Enforcement
and
Compliance
Assurance
to
insure
that
small
containers
of
refrigerant
are
not
available
for
non­
certified
technicians.
By
requiring
only
minor
additions
to
the
existing
invoice
procedures,
the
Agency
has
insured
total
compliance
with
Section
609.

3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
a)
Non­
duplication
­
5
B
The
specific
information
requested
by
this
notice
is
not
currently
collected
by
any
other
office
within
EPA
or
any
other
government
agency.

b)
Consultations
In
developing
the
regulations
under
the
Act,
EPA
established
an
advisory
council
for
issues
relating
to
stratospheric
ozone.
The
Stratospheric
Ozone
Protection
Advisory
Council
(
STOPAC)
membership
included
representatives
from
affected
industries,
environmental
interest
groups,
and
academics
in
related
fields.
Within
STOPAC,
subcommittees
were
formed
to
look
at
the
more
detailed
issues.
The
subcommittee
on
motor
vehicle
air
conditioning
met
several
times
and
discussed
all
aspects
of
the
proposed
regulations
for
Section
609
of
the
Act.
The
Federal
Register
Notice
required
under
5
CFR
1320.8(
d),
soliciting
comments
on
this
collection
of
information
was
published
on
12/
20/
2001
no
comments
were
received.

c)
Effects
of
Less
Frequent
Collection
The
equipment
certification
time
table
was
established
by
Congress
in
Section
609.
Since
the
certification
submission
is
a
one
time
occurrence,
a
less
frequent
collection
of
this
information
would
make
it
impossible
to
comply
with
Section
609.

Again,
both
technician
certification
programs
and
independent
laboratory
equipment
testing
programs
are
required
to
be
submitted
to
EPA
under
Section
609
of
the
Act.
The
review
is
a
one
time
occurrence
and
must
take
place
to
allow
the
Agency
to
approve
programs
under
the
Act.

d)
General
Guidelines
This
rule
does
not
exceed
any
of
the
guidelines.

e)
Confidentiality
and
Sensitive
Questions
i)
Confidentiality
This
section
does
not
apply
because
this
ICR
does
not
request
information
of
confidential
nature.

ii)
Sensitive
Questions
This
section
does
not
apply
because
this
ICR
does
not
request
information
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
­
6
B
a)
Respondents
/
SIC
Codes
The
following
is
a
list
of
SIC
codes
affected
by
the
manifest
information
requirements
covered
under
this
ICR:

5511
­
New
and
Used
Motor
Vehicle
Dealers
5541
­
Gasoline
Service
Stations
7513
­
Truck
Rental
and
Leasing
Without
Drivers
7414
­
Passenger
Car
Rental
7532
­
Top,
Body,
Upholstery
Repair
and
Paint
Shops
7538
­
General
Automotive
Repair
Shops
7539
­
Automotive
Repair
Shops
not
Elsewhere
Classified
b)
Information
Requested
i)
Data
Items,
including
Recordkeeping
Requirements:
All
entities
that
service
motor
vehicle
air
conditioners
must
send
to
EPA
on
a
one­
time
basis
a
motor
vehicle
air
conditioner
recover/
recycle
equipment
certification.
This
certification
must
include
the
name
of
the
establishment
address
where
the
equipment
will
be
used,
telephone
number,
name
of
equipment
manufacturer
model
number,
date
of
manufacture
serial
number
and
the
signature
of
the
owner/
operator
of
the
equipment.

Technician
certification
programs
interested
in
certifying
technicians
are
required
to
send
a
copy
of
their
program
to
EPA
for
approval.
A
successful
test
includes
the
following
components:
all
relevant
SAE
standards
dealing
with
the
servicing
and
repair
of
motor
vehicle
air
conditioners;
likely
future
technological
developments;
the
general
regulatory
requirements
imposed
by
EPA
under
Section
609
of
the
Act;
the
environmental
consequences
of
the
release
of
refrigerant
during
the
servicing
and
repair
of
motor
vehicle
air
conditioners;
and
the
adverse
effects
of
stratospheric
ozone
depletion.
Certification
programs
are
required
to
conduct
a
periodic
review
and
provide
EPA
with
a
written
assurance
that
they
have
taken
the
necessary
steps
to
update
their
tests.
At
a
minimum,
the
Agency
requires
that
this
review
be
conducted
every
two
years
and
that
the
Agency
be
provided
with
a
program
review
summary
report.

In
addition
to
including
copies
of
the
proposed
tests,
the
testing
authorities
must
provide
information
concerning
the
authority
that
will
grade
the
test,
the
score
required
to
pass
the
exam,
the
means
of
identifying
the
individual
taking
the
test,
and
the
measures
taken
at
the
test
site
to
ensure
that
the
tests
are
completed
honesty
by
each
technician.
Once
the
technician
has
successfully
completed
a
certification
test,
the
testing
authority
must
provide
individual
proof
of
certification.
Potential
certification
programs
must
furnish
a
sample
of
their
proof
of
certification
for
EPA.

Independent
laboratory
testing
of
recycling
and
recovery
equipment
is
designed
to
ensure
the
equipment
is
capable
of
safely
meeting
the
standards
established
by
EPA
in
appendices
to
the
­
7
B
regulation.
To
ensure
a
degree
of
uniformity
to
the
equipment
certification
programs,
independent
laboratories
are
required
to
submit
an
application
to
EPA
that
includes
the
procedures
used
to
test
recycling
equipment
for
its
ability
to
remove
moisture,
oil,
and
noncondensable
gas
from
refrigerant.
For
each
test
the
laboratory
must
include
a
list
of
equipment
used
and
the
temperature
parameters
for
the
tests.

Equipment
owners
or
manufacturers
who
request
an
EPA
certification
of
their
equipment
as
substantially
identical
must
submit
an
application
and
supporting
documents
to
the
Agency.
Among
the
supporting
documents,
there
must
be
included
process
flow
sheets,
and
a
list
of
equipment
components.
The
applicant
is
free
to
submit
other
information
they
feel
would
assist
EPA
in
identifying
the
equipment
as
substantially
identical
to
certified
equipment.

Service
establishments
must
record
the
facility
name
and
address
to
which
any
refrigerant
is
sent
to
for
off­
site
reclamation
or
recycling.
If
the
purchaser
of
small
containers
intends
to
resell
them,
the
seller
must
be
provided
with
a
written
statement
that
the
containers
are
for
resale
only.
The
statement
must
also
contain
the
purchaser's
name
and
address
and
must
be
kept
for
three
years.
In
addition,
any
person
who
owns
approved
recycling
equipment
and
sends
used
refrigerant
off­
site
for
reclamation
must
keep
records
for
three
years
of
the
name
and
address
of
the
facility
to
which
the
refrigerant
is
sent.
Finally,
any
person
who
owns
equipment
must
retain
records
for
three
years
demonstrating
that
all
technicians
authorized
to
operate
the
equipment
are
certified
pursuant
to
the
Clean
Air
Act.

ii)
Respondent
Activities:

A.
All
Entities
That
Service
Motor
Vehicle
Air
Conditioners
­
Compile
a
certification
that
states
the
following:
name
of
the
establishment,
mailing
address
where
equipment
will
be
located,
telephone
number,
name
of
equipment
manufacturer
of
the
installed
recycling
or
recovery
machine,
equipment
model
number,
the
date
of
manufacture,
and
serial
number.
The
owner
of
the
equipment
must
sign
the
certification
stating
that
the
equipment
will
be
properly
used
in
servicing
motor
vehicle
air
conditioners
and
that
each
individual
authorized
by
the
purchaser
to
perform
service
is
property
trained
and
certified.
In
many
cases
a
form
is
provided
by
the
manufacturer
of
the
equipment.
Once
the
form
is
complete,
it
must
be
sent
to
EPA.

B.
Technician
Certification
Programs
­
Submit
a
copy
of
the
training
program
to
EPA.
­
Conduct
a
program
review
every
two
years
and
send
the
summary
to
the
EPA.

C.
Independent
Laboratories
­
8
B
­
Research
SAE
J
standards
on
motor
vehicle
air
conditioning
recycling
and
recovery
equipment.

­
Compile
test
procedures
to
insure
that
the
testing
program
fulfills
the
SAE
J­
1990
standards
for
recycling
and
recovery
equipment.

­
Assemble
test
methodology,
a
list
of
equipment
required
and
the
temperature
parameters
for
the
report
to
EPA.

D.
Substantially
Identical
Equipment
Owners
or
Manufacturers
­
Locate
information
that
will
verify
that
the
equipment
can
perform
to
the
SAE
J
standards,
including
process
flow
sheets
and
a
list
of
components.

­
Compile
supporting
information
and
submit
it
to
EPA.

E.
Recordkeeping
­
Record
the
facility
address
to
which
any
refrigerant
is
sent
for
off­
site
reclamation
or
recycling.

­
Compile
and
file
written
statements
to
verify
that
purchasers
intend
to
only
resell
the
small
containers
of
refrigerant.

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

a)
Agency
Activities
­
Enter
and
store
certifications
from
all
entities
that
have
purchased
approved
recycling
equipment.

­
Store
certifications
from
small
entities
that
want
to
claim
a
year
exemption
to
purchasing
approved
equipment.

­
Review
test
materials
for
technician
certification
programs.

­
Review
summaries
of
program
updates
every
two
years.

­
Review
applications
from
independent
labs
that
certify
recycling
and
recovery
equipment
­
9
B
­
Review
application
and
supporting
documents
from
recycling
or
recovery
equipment
manufactures
or
owners
for
EPA
equipment
certification.

­
Inspect
records
maintained
by
service
establishments
and
establishments
that
sell
small
containers
of
refrigerant
to
distributors.

b)
Collection
Methodology
and
Management
The
GPD
and
the
EPA
regional
offices
have
planned
and
allocated
resources
for
the
efficient
and
effective
management
and
use
of
this
information.
The
Agency
has
developed
a
sample
form
that
manufacturers
may
distribute
to
service
establishments
that
have
purchased
approved
recycling
equipment.
An
establishment
may
submit
the
form
provided
by
the
manufacturer
of
the
recycling
equipment.
Entities
are
not
required
to
use
the
manufacturer's
form,
but
they
must
submit
the
required
information.
The
information
submitted
by
each
service
establishment
is
maintained
by
the
EPA
regional
offices.

Technician
certification
programs
must
be
submitted
to
the
Agency
for
review
and
approval
by
the
GPD.
Program
materials
include,
but
are
not
limited
to:
video
tapes,
scripts,
manuals,
booklets,
and
software
or
other
forms
of
electronic
information.
Testing
of
technicians
may
be
performed
either
manually
or
electronically.
The
certification
programs
and
their
review
reports
are
kept
on
file
at
EPA
for
reference.

Independent
laboratories
must
submit
an
outline
of
their
test
procedures
for
testing
recycling
and
recovery
equipment
to
the
Agency.
The
Agency
compares
the
procedures
submitted
for
their
ability
to
meet
the
SAE
standards
as
specified
in
Section
609
of
the
Act.
These
outlines
may
be
submitted
manually
or
electronically,
as
long
as
they
are
made
available
for
Agency
review.

Equipment
manufacturers
or
equipment
owners
that
are
interested
in
having
their
equipment
determined
substantially
identical
must
submit
information
to
the
Agency
for
an
evaluation
of
the
equipment.
The
information
provided
is
kept
on
file
at
EPA
for
reference.

The
Agency
has
determined
that
periodic
on­
site
inspection
is
the
most
effective
method
to
insure
compliance
with
section
609.
The
records
should
be
kept
at
the
location
where
service
involving
refrigerant
is
performed
or
where
small
containers
of
refrigerant
are
distributed
for
resale.

c)
Small
Entity
Flexibility
Section
609
contains
a
provision
which
allowed
small
entities
(
i.
e.,
those
which
performed
service
on
fewer
than
100
motor
vehicle
air
conditioners
during
the
calendar
year
1990)
an
extra
year
to
comply
with
the
provisions
of
Section
609.
­
10
B
EPA
expects
a
small
number
of
technician
certification
programs
and
independent
laboratory
equipment
testing
programs
to
apply
for
approval.
The
requirement
to
submit
the
program
for
Agency
approval
is
not
burdensome
and
is
not
expected
to
prevent
small
entities
from
developing
programs.
The
Act
does
not
require
programs
to
be
developed,
only
that
once
developed
they
be
submitted
to
EPA.

The
substantially
identical
determination
is
designed
to
examine
equipment
sold
before
the
regulations
was
proposed
and
that
had
not
been
certified
by
an
approved
independent
laboratory.
This
provision
will
benefit
small
entities
who
may
have
purchased
recycling
or
recover
equipment
in
a
good
faith
effort
to
recover
refrigerant
prior
to
the
regulatory
mandate.
The
information
requested
is
available
in
an
equipment
owners
manual.

The
name
and
address
of
the
reclamation
or
recycling
facility
to
which
refrigerant
is
sent
by
an
establishment
with
recover
only
capabilities
is
a
normal
part
of
existing
recordkeeping
procedures
for
business
transactions.
The
records
maintained
by
persons
who
sell
small
containers
of
refrigerant
require
only
that
the
resale
only
statement
be
added
into
invoicing
procedures.

d)
Collection
Schedule
All
entities
were
required
to
submit
certification
forms
to
EPA
by
January
1,
1993.
The
certification
for
recycling
and
recovery
equipment
is
intended
as
a
one­
time
information
request
for
the
life
of
the
equipment.

After
the
initial
EPA
approval,
technician
training
programs
must
review
their
programs
every
two
years
to
account
for
technological
developments.
A
summary
of
the
program
review
must
be
submitted
to
EPA.

The
submission
of
information
for
the
grandfathering
of
equipment
is
a
one­
time
information
request.
The
records
required
by
EPA
must
be
maintained
for
a
three
year
period
in
case
of
a
periodic
inspection.

6a.
Estimating
the
Burden
and
Cost
of
the
Collection
The
Agency
estimates
that
there
are
no
capital/
start­
up
costs
associated
with
the
requirements
of
section
609
and
therefore
with
the
renewal
of
this
information
collection
request.

i)
A)
Certification
by
Service
Facilities
The
burden
was
estimated
to
be
a
quarter
hour
based
on
the
limited
nature
of
the
information
requested,
and
the
ease
of
obtaining
the
information.
An
hour
of
industry
time
was
valued
at
$
50
which
represents
an
average
hourly
rate
of
pay
for
a
private
firm.
The
number
of
respondents
under
the
previous
information
collection
was
previously
estimated
at
10,000,
but
based
on
the
­
11
B
response
from
service
stations,
we
adjusted
our
estimate
down
to
2,000
service
stations
per
year,
which
is
more
appropriate.
The
quarter
burden
hour
per
service
station
at
a
cost
of
$
12.50
per
hour
is
the
cost
upon
which
this
estimate
is
predicated.
See
the
attached
table
for
aggregate
costs
and
burden
hours.

i)
B)
Equipment
Certification
for
Service
Stations
that
will
Change
Ownership
or
New
Firms
Entering
the
Market
The
burden
was
estimated
to
be
a
quarter
hour
based
on
the
limited
nature
of
the
information
requested,
and
the
ease
of
obtaining
the
information.
EPA
estimated
that
EPA
would
receive
an
additional
4,000
certification
forms
from
either
service
establishments
that
had
changed
ownership
after
January
1,
1993
or
new
service
establishments
that
will
start
business
after
January
1,
1993.
EPA
estimated
that
2,000
certification
forms
would
be
received
per
year.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

ii)
Technician
Certification
Programs
The
burden
of
submitting
the
training
program
to
EPA
can
easily
be
incorporated
into
an
establishment's
mailing
system.
The
burden
of
summarizing
the
program
review
was
estimated
at
two
hours
because
of
the
brief
nature
of
the
document.
Each
hour
of
private
industry
time
has
been
valued
at
$
50.00.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

iii)
Substantially
Identical
Equipment
Submission
The
burden
was
estimated
to
be
one
hour
based
on
the
ease
of
obtaining
the
information
from
a
standard
equipment
owners
manual.
Routine
engineering
and
testing
information
is
adequate
for
supporting
documentation
from
an
equipment
manufacturer
in
a
substantially
identical
claim.
An
hour
of
industry
time
was
valued
at
$
50.00
which
represents
an
average
hourly
rate
of
pay
for
a
private
firm.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

iv)
Small
Container
Purchased
for
Resale
Only
Recordkeeping
The
recordkeeping
requirements
for
the
purchase
of
small
containers
of
refrigerant
for
resale
only
entails
the
minimal
extension
of
the
normal
invoicing
procedures.
The
number
of
distributors
was
derived
from
a
discussion
with
a
representative
from
the
Automotive
Refrigeration
Products
Institute.
Whenever
the
purchase
of
refrigerant
is
made
for
resale
only,
the
seller
must
be
provided
with
a
written
statement
that
the
refrigerant
purchased
is
for
resale
only.
This
statement
must
be
kept
on
file
and
updated
with
additional
purchases
of
refrigerant.
It
was
estimated
that
purchasers
of
refrigerant
who
intend
to
resell
it
will
buy
the
small
containers
in
bulk,
making
recordkeeping
a
very
minimal
task
for
the
sellers.
It
was
estimated
that
distributors
would
buy
in
bulk
twice
a
year
(.
25
hrs
per
occurrence).
An
hour
of
industry
time
was
valued
at
$
50
per
hour,
­
12
B
which
represents
an
average
hourly
rate
of
pay
a
private
firm.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

v)
Recordkeeping
for
Off­
site
Reclamation
or
Recycling
The
time
burden
was
estimated
at
five
minutes
based
on
the
limited
nature
of
the
information
requested
and
the
ease
of
obtaining
the
information.
Recover/
recycle
equipment
manufacturers
have
estimated
that
already
150,000
pieces
of
recycling
equipment
have
been
sold
and
therefore
the
refrigerant
is
assumed
to
be
recycled
on­
site.
The
removal
of
35,000
service
establishments
from
the
total
number
of
establishments
and
concluded
that
the
estimated
number
of
establishments
expected
to
use
off­
site
facilities
is
5,000.
This
number
was
based
on
our
view
of
the
continued
trend
at
service
establishments
to
recycle
on­
site
therefore
reducing
the
burden
in
this
category.
An
hour
of
industry
time
was
valued
at
$
50.00
which
represents
an
average
hourly
rate
for
a
private
firm.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

vi)
All
Equipment
Operators
are
Certified
Technicians
Recordkeeping
The
time
burden
was
estimated
at
five
minutes
based
on
the
limited
nature
of
the
information
requested
and
the
ease
of
obtaining
the
information.
An
hour
of
industry
time
was
valued
at
$
50.00
per
which
represents
an
average
hourly
rate
for
a
private
firm.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

6b.
Estimating
Agency
Burden
and
Cost
The
hours
for
data
entry
of
the
equipment
certifications
were
calculated
at
an
entry
rate
of
30
certification
cards
per
hour.
It
is
expected
that
no
more
independent
laboratories
will
apply
for
EPA
approval.
The
two­
year
review
of
training
programs
will
be
undertaken
by
one
EPA
analyst
and
take
two
hours
per
program.
The
applications
for
the
equipment
to
be
certified
by
EPA
as
substantially
identical
will
be
reviewed
by
EPA
and
take
approximate
five
hours
per
application.
All
labor
rates
were
calculated
at
a
$
40
per
hour
figure,
an
average
rate
for
EPA
personnel.
This
includes
an
increase
of
$
5.00
an
hour
for
cost
of
living
increases.

6c.
Bottom
Line
Burden
Hours
and
Cost
Tables
i)
Respondent
Tally
Annual
Burden
Hours:
6882
Annual
Costs:
$
129,631
­
13
B
ii)
Agency
Tally
Annual
Burden
Hours:
325
Annual
costs:
$
13,000
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
results
from
the
fact
that
the
number
of
service
facilities
entering
the
market
and
changing
ownership
was
overstated
in
previous
ICRs,
and
is
being
adjusted
downward.
The
estimate
for
equipment
certification
of
service
stations
that
newly
enter
the
market
or
that
change
ownership
is
now
1,000.
The
estimated
number
of
certifications
from
facilities
purchasing
MVAC
recovery
equipment
is
2,000.
EPA
does
not
anticipate
that
any
organizations
will
apply
to
EPA
in
the
future
to
become
EPA­
approved
technician
certification
programs,
and
EPA
does
not
anticipate
that
any
organizations
will
apply
to
EPA
in
the
future
to
become
approved
independent
standards
testing
organizations.
The
annual
hours
and
costs
related
to
initial
submissions
by
these
organizations
have
therefore
been
eliminated.

This
revision
to
the
burden
also
reflects
a
significant
reduction
in
the
number
of
off­
site
reclamation
or
recycling
respondents
to
5,000.

g)
Burden
Statement
The
industry
reporting
burden
for
this
collection
is
estimated
in
the
following
tables.
It
includes
the
time
needed
to
comply
with
EPA's
certification
requirements
and
Agency
reviews.

Equipment
Certification
Burden
per
Occurrence
Respondent
Activities
Service
Entity
hrs.

Complete
certification
and
submit
it
to
EPA
.25
Technician
Certification
Program
Respondent
Activities
Training
Program
Companies
hrs.

2
year
review
of
training
program,
with
a
summary
being
submit
to
EPA
2
­
14
B
Substantially
Identical
Equipment
Response
Activities
Applicant
hrs.

Compile
information
on
equipment
and
submit
to
EPA
1
Small
Containers
Purchased
for
Resale
Only
Recordkeeping
Requirements
Response
Activities
Sellers
of
Small
Containers
hrs.

Compile
and
file
information
.5
Recordkeeping
for
Off
Site
Reclamation
or
Recycling
Response
Activities
Service
Establishment
hrs.

Recording
the
name
and
address
of
the
off
site
facility
.08
All
Equipment
Operators
are
Certified
Technicians
Response
activities
Service
Establishment
hrs.

Filing
certification
cards
.08
TOTAL
3.81
hours
For
the
total
reporting
burden,
total
recordkeeping
burden,
and
grand
total
public
burden,
see
the
information
located
behind
the
attached
chart.

Source
data
and
informational
requirements
for
statospheric
ozone
protection:

Equipment
Certification
Burden
­­
Complete
certification
and
submit
it
to
EPA:
CAA
Section
609(
d)
and
40
CFR
82.42(
a).
­
15
B
Technician
Certification
Program
­­
2
year
review
of
training
program:
40
CFR
82.40(
c).

Substantially
Identical
Equipment
­­
Compile
information
on
equipment
and
submit
to
EPA:
40
CFR
82.36(
b).

Small
Containers
Purchased
for
Resale
Only
Recordkeeping
Requirements
­­
Compile
and
file
information:
40
CFR
82.42(
b)(
3).

Recordkeeping
for
Off
Site
Reclamation
or
Recycling
­­
Recording
the
name
and
address
of
the
off
site
facility:
40
CFR
82.42(
b)(
1).

All
Equipment
Operators
are
Certified
Technicians
Recordkeeping
­­
Filing
the
certificates
in
service
facility
files:
40
CFR
82.42(
b)(
2).

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
purpose
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
regarding
burden
estimates
or
any
other
aspect
of
this
collection
of
information,
including
suggestions
for
reducing
the
burden,
to
Director,
OEI,
Collections
Strategies
Division,
MC
2822T,
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue
N.
W.,
Washington
D.
C.
20460,
and
to
Paperwork
Reduction
Project,
EPA
Desk
Officer,
Office
of
Information
and
Regulatory
Affairs,
Room
10202,
Office
of
Management
and
Budget,
Washington,
D.
C.
20503.
Reference
EPA
Number
1617.04
and
OMB
Number
2060­
0247
in
all
correspondence.
­
16
B
ACTIVITY
CAPITAL/
START
UP
BURDEN
HOURS
CAPITAL/
START
UP
COSTS
ANNUAL
BURDEN
HOURS
ANNUAL
COSTS
REPORTING
Certification
by
Service
Facilities
0
0
.25
$
12.50
x
#
respondents
(
2,000)
0
0
500
hrs.
$
6,250
Equipment
Certification
for
Service
Stations
that
will
Change
Ownership
or
New
Firms
Entering
the
Market
0
0
.25
$
12.50
x
#
respondents
(
1,000)
0
0
250
hrs.
$
781
Substantially
Identical
Equipment
Submission
0
0
1
$
50
x
#
respondents
(
12)
0
0
12
hrs.
$
600
RECORDKEEPING
Small
Container
Purchased
for
Resale
Only
Recordkeeping
0
0
.5
$
25
x
#
respondents
(
2000)
0
0
1,000
hrs.
$
50,000
Recordkeeping
for
off
site
Reclamation
or
Recycling
0
0
.08
$
4
x
#
respondents
(
5,000)
0
0
4,000
hrs.
$
16000
All
Equipment
Operators
are
Certified
Technicians
Recordkeeping
0
0
.08
$
4
x
#
respondents
(
14,000)
0
0
1,120
hrs.
$
56,000
TOTALS
0
hrs.
$
0
6,882
hrs.
$
129,631
_________________________________________________________________________________________________________________

NUMBER
OF
RESPONDENTS
EXISTING
SERVICE
FACILITIES
ENTERING
MARKET
2,000
NEW
FACILITIES
ENTERING
MARKET
1,000
FACILITIES
THAT
SEND
REFRIGERANT
OFF­
SITE
5,000
SUBMITTERS
OF
SUBSTANTIALLY
IDENTICAL
EQUIPMENT
12
WHOLESALERS
KEEPING
RECORDS
OF
SALES
OF
SMALL
CONTAINERS
FOR
RESALE
2,000
RECORDKEEPING
BY
CERTIFIED
TECHNICIANS
14,000
TOTAL
24,012
RECORDKEEPING:
­
17
B
TOTAL
RECORDKEEPING
CAPITAL/
START
UP
BURDEN
HOURS:
0
TOTAL
RECORDKEEPING
ANNUAL
BURDEN
HOURS:
762
HOURS
TOTAL
RECORDKEEPING
CAPITAL/
START
UP
COSTS:
0
TOTAL
RECORDKEEPING
ANNUAL
COSTS:
$
7,631
REPORTING:

TOTAL
REPORTING
CAPITAL/
START
UP
BURDEN
HOURS:
0
HOURS
TOTAL
REPORTING
ANNUAL
BURDEN
HOURS:
6120
HOURS
TOTAL
REPORTING
CAPITAL/
START
UP
COSTS:
$
0
TOTAL
REPORTING
ANNUAL
COSTS:
$
122,000
TOTAL
PUBLIC
BURDEN:

SUM
OF
TOTAL
CAPITAL/
START
UP
BURDEN
HOURS
AND
TOTAL
ANNUAL
BURDEN
HOURS:
6882
HRS.

SUM
OF
TOTAL
CAPITAL/
START
UP
COSTS
AND
TOTAL
ANNUAL
COSTS:
$
129,631
