STANDARD
FORM
83
SUPPORTING
STATEMENT
FOR
ICR
1750.02
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
NATIONAL
VOC
EMISSION
STANDARDS
FOR
ARCHITECTURAL
COATINGS
Emission
Standards
Division
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
North
Carolina
27711
November
1,
2001
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
National
VOC
Emission
Standards
for
Architectural
Coatings."
The
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
information
collection
request
(
ICR)
is
1750.02.
This
is
a
renewal
of
a
continuing
ICR,
OMB
No.
2060­
0393,
expiration
date
January
31,
2002.

(
b)
Short
Characterization/
Abstract
Compliance
with
the
architectural
coatings
rule
is
required
by
September
1999.
The
regulation
requires
that
manufacturers
and
importers
of
architectural
coatings
adhere
to
volatile
organic
compound
(
VOC)
content
limits
in
the
regulation.

Information
collection
requirements
for
manufacturers
and
importers
complying
with
the
VOC
content
limits
consist
of
product
labeling;
an
initial
notification
report,
which
includes
an
explanation
of
any
date
code
used;
and
subsequent
explanations
of
any
date
codes
revised
after
submittal
of
the
initial
report.

The
regulation
does
not
contain
any
additional
reporting
or
recordkeeping
requirements
unless
a
manufacturer
or
importer
chooses
to
comply
through
one
of
the
optional
provisions
in
lieu
of
meeting
the
VOC
content
limits
(
i.
e.,
the
tonnage
exemption,

exceedance
fee,
or
recycled
coating
credit
provisions).

Under
the
terms
of
Clearance
for
the
curent
ICR,
1750.02,

assumptions
are
based
on
respondent
and
agency
experience
for
the
first
three
years
the
rule
was
in
effect.
Adjustments
were
made
to
reflect
the
lower
than
anticipated
numbers
of
manufacturers
choosing
to
use
the
more
burdensome
tonnage
exemption,
exceedance
fee
and
recycled
coating
options.

The
rule
contains
an
optional
tonnage
exemption
that
allows
each
manufacturer
and
importer
to
exempt
a
specified
total
mass
of
VOC
in
architectural
coatings.
The
tonnage
exemption
would
be
used
for
products
that
do
not
comply
with
the
VOC
content
limits
and
for
which
no
exceedance
fee
is
paid.
Additional
information
collection
requirements
for
the
tonnage
exemption
include
2
records
of
VOC
calculations
and
volumes
of
coating
manufactured
or
imported
and
an
annual
report.

The
rule
includes
an
exceedance
fee
alternative
compliance
option
to
provide
additional
compliance
flexibility.
This
is
an
economic
incentive
approach
whereby
manufacturers
and
importers
may
choose
to
comply
with
the
VOC
requirements
in
the
rule
by
paying
a
fee
in
lieu
of
meeting
the
VOC
content
limits.
The
per
product
exceedance
fee
is
calculated
based
on
both
the
volume
of
product
manufactured
or
imported
and
the
amount
of
VOC
above
the
VOC
content
limit
for
that
product.
Additional
information
collection
requirements
for
the
exceedance
fee
option
include
records
of
fee
calculations
and
inputs
and
an
annual
report.

Manufacturers
and
importers
of
recycled
coatings
have
the
option
to
take
credit
for
the
post­
consumer
coating
content
when
determining
the
VOC
content
of
the
coating,
which
results
in
a
less
stringent
control
requirement.
Additional
information
collection
requirements
for
the
recycled
coating
option
include
records
of
VOC
calculations,
additional
labeling,
and
an
annual
report.

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

The
rule
requires
that
the
labels
or
lids
of
all
subject
architectural
coatings
display
the
date
of
manufacture,
the
manufacturer's
recommended
thinning,
and
the
VOC
content
of
the
coating.
Many
manufacturers
already
include
this
information
on
their
coating
labels
as
a
part
of
normal
and
usual
practice.
For
additional
flexibility,
the
date
of
manufacture
can
be
expressed
as
a
code
and
can
be
located
either
on
the
label,
lid,
or
bottom
of
the
container.
The
rule
also
requires
that
the
labels
or
lids
of
all
subject
industrial
maintenance
coatings
display
a
statement
indicating
that
industrial
maintenance
coatings
are
primarily
intended
for
industrial
and
professional
use.
In
addition,
each
manufacturer
and
importer
using
the
adjusted
VOC
content
for
a
recycled
coating
is
required
to
include
a
statement
indicating
the
post­
consumer
coating
content
on
the
coating
container
label
or
lid.

2.
Need
for
and
Use
of
the
Collection
3
(
a)
Need/
Authority
for
the
Collection
Section
183(
e)
of
the
Clean
Air
Act
(
Act)
requires
the
EPA
to
regulate
categories
of
consumer
and
commercial
products
that
account
for
at
least
80
percent
of
the
VOC
emissions,
on
a
reactivity­
adjusted
basis,
in
areas
that
violate
the
National
Ambient
Air
Quality
Standards
(
NAAQS)
for
ozone.
The
EPA
determined
that
the
architectural
coating
category
is
one
of
the
largest
VOC
emission
sources
among
the
consumer
and
commercial
products
categories,
in
many
States
represents
a
significant
source
of
unregulated
VOC
emissions,
and
that
VOC
emissions
from
the
use
of
architectural
coatings
contribute
to
ground­
level
ozone
formation
in
ozone
nonattainment
areas.
Therefore,
the
EPA
published
standards
regulating
VOC
emissions
from
architectural
coatings
under
section
183(
e)
of
the
Act
on
September
11,
1998
(
40
CFR
part
59,
subpart
D).

The
reporting,
labeling,
and
recordkeeping
activities
required
under
the
architectural
coatings
rule
enable
the
EPA
to
determine
whether
or
not
coatings
manufactured
or
imported
for
sale
or
distribution
in
the
U.
S.
are
in
compliance
with
the
requirements
in
the
rule.
Reports
and
records
are
used
to
determine
whether
exceedance
fees
(
if
applicable)
are
paid
for
coatings
for
which
the
manufacturer
or
importer
has
chosen
the
exceedance
fee
option.
For
the
tonnage
exemption,
the
reports
and
records
are
used
to
ensure
that
the
allowed
exemption
levels
are
not
exceeded.
Reports,
records,
and
product
labels
associated
with
the
recycled
coatings
provision
are
used
to
ensure
that
the
adjusted
VOC
content
is
calculated
properly.

(
b)
Practical
Utility/
Users
of
the
Data
The
data
collected
under
this
ICR
are
essential
to
ensure
compliance
with
the
rule
and
to
evaluate
its
effectiveness.

Specifically,
Agency
enforcement
personnel
use
the
information
collected
to:
(
1)
identify
manufacturers
and
importers
subject
to
the
rule;
(
2)
ensure
that
architectural
coatings
comply
with
VOC
content
standards,
including
accounting
for
recycled
coating
content;
(
3)
verify
that
exceedance
fees
are
calculated
properly
and
paid
in
the
correct
amounts;
(
4)
determine
the
volume
of
coating
manufactured
or
imported
for
which
fees
are
paid;
4
(
5)
determine
the
total
revenues
paid
in
exceedance
fees;
and
(
6)

verify
that
the
VOC
content
of
the
coatings
is
calculated
properly
for
the
tonnage
exemption
and
that
the
exemption
levels
are
not
exceeded.
The
reported
information
assists
EPA
in
deciding
which
architectural
coating
manufacturers
or
importers
should
be
inspected.
The
requirement
for
date
of
manufacture
(
or
date
code)
to
be
placed
on
coating
containers
is
useful
to
EPA
for
comparison
to
manufacturers'
records
and
reports
to
determine
compliance
with
VOC
content
limits,
and
with
the
exceedance
fee
and
tonnage
exemption
requirements.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
The
information
collected
pursuant
to
the
regulation
consists
primarily
of
the
VOC
content
information
for
architectural
coating
products,
the
calculation
of
exceedance
fees
due,
the
calculation
of
total
VOC
emissions
from
particular
products
claimed
under
the
tonnage
exemption,
and
the
calculation
of
the
post­
consumer
coating
content
of
recycled
coatings.
This
information
is
not
collected
by
any
other
Federal
agency.

(
b)
Consultations
Significant
input
and
information
was
received
from
the
affected
industry,
State
and
local
governments,
environmental
groups,
and
coating
users
during
development
of
the
rule,

including
regulatory
negotiation
meetings.
Table
1
shows
a
list
of
the
participants
in
the
regulatory
negotiations.
In
addition,

EPA
held
a
public
hearing
in
July
1996
and
a
public
meeting
in
August
1996.
The
public
meeting
was
specifically
designed
to
obtain
input
from
small
businesses.
The
EPA
considered
numerous
public
comments
in
the
development
of
this
rule.
The
public
comments
are
located
in
the
docket
for
this
rulemaking
(
Docket
A­
92­
18).
The
Federal
Register
document
required
under
5
CFR
1320.8(
d),
soliciting
comments
on
this
collection
of
information
was
published
on
August
17,
2001
(
66
FR
43253);
no
comments
were
received.
5
(
c)
Effects
of
Less
Frequent
Collection
This
ICR
includes
a
one­
time
initial
notification
report
for
all
manufacturers
and
importers.
For
those
reporting
VOC
content
adjusted
for
post­
consumer
coating
content,
an
annual
report
is
required.
For
those
using
the
tonnage
exemption
option,
an
annual
report
is
required.
For
those
using
the
exceedance
fee
option,
an
annual
report
is
required.
Less
frequent
reporting
would
not
allow
for
effective
or
timely
compliance
determination.

The
EPA
believes
annual
reporting
is
frequent
enough
to
provide
the
information
needed
for
compliance
tracking
without
being
too
burdensome
on
the
industry
or
the
Agency.
6
Table
1.
Consultations
Consumer
Representatives
Bernie
Appleman,
Steel
Structures
Painting
Council
Charles
Field,
Staff
Vice
President,
National
Association
of
Home
Builders
G.
Lawrence
Gettier,
Traffic
Control
Project
Engineer,

North
Carolina
Department
of
Transportation,
Century
Center
­
Traffic
Engineering
Branch
John
Peart,
Research
Chemist,
Federal
Highway
Administration
Tim
Race,
Chemist,
U.
S.
Army
Corps
of
Engineers
Vincent
R.
Sandusky,
Executive
Vice­
President,
Painting
and
Decorating
Contractors
of
America
John
Stone,
Chemist,
G.
S.
A.
Paint
and
Chemicals
Commodity
Center
R.
Sam
Williams,
Forest
Products
Laboratory
Environmental
Representatives
David
Hawkins,
Senior
Attorney,
Natural
Resources
Defense
Council
Joel
Schwartz,
Staff
Scientist,
Coalition
for
Clean
Air
Ronald
White,
Deputy
Director,
National
Programs,
American
Lung
Association
Industry
Representatives
Earle
K.
Borman,
Jr.,
Senior
Vice
President,
L&
F
Products
Jack
J.
Bracco,
Manager,
Market
Development,
Architecture
and
Industrial
Maintenance
Coatings,
Miles,
Inc.

J.
Andrew
Doyle,
Executive
Director,
National
Paint
and
Coatings
Association
Marcel
Gaschke,
Group
Marketing
Manager,
Polymers
Division,

CIBA­
GEIGY
Corporation
Madelyn
Harding,
Administrator,
Product
Compliance
and
Registrations,
The
Sherwin­
Williams
Company
Robert
J.
Klepser,
Laboratory
Manager,
Carboline
Company
James
F.
Lawrence,
Senior
Vice
President,
Cargill
Inc.
7
Carl
Minchew,
Assistant
to
the
Technical
Director,
Benjamin
Moore
&
Co.

Kenneth
J.
Murray,
Environmental
Affairs
Manager,
Exxon
Chemical
Pete
Nicholson,
Market
Manager,
Industrial
Finishes,
Rohm
and
Haas
Co.

John
Prinz,
Vice
President
Research,
Development,
and
Quality,
Sinclair
Paint
Company,
Division
of
Insilco
Corp.

Jim
Sainsbury,
Manager,
Product
Regulation,
The
Glidden
Company
Christine
Stanley,
Product
Development
Manager,
Ameron
Protective
Coatings
William
Stewart,
Director,
Regulatory
Affairs,
The
Valspar
Corporation
Small
Business
Representatives
Jay
Haines,
Attorney
at
Law,
Haines
&
Riley
Ned
B.
Kisner,
President,
Triangle
Coatings,
Inc.

Robert
Wendoll,
Chairman,
Environmental,
Legislative,
and
Regulatory
Advocacy
Program
Richard
Williamson,
Executive
Vice
President,
Trinity
Coatings
Company
Labor
Representative
Mike
Andrews,
Representative
of
the
Health
and
Safety
Department,
International
Brotherhood
of
Painters
and
Allied
Trades
State
Representatives
S.
William
Becker,
Executive
Director,
STAPPA/
ALAPCO
Dan
Belik,
Enforcement
Program
Supervisor,
Rule
Development,

BAAQMD
Robert
Irvine,
Senior
Environmental
Engineer,
SIP
Revision
Unit,
State
of
Michigan­
Department
of
Natural
Resources,

Air
Quality
Division
Peggy
Taricco,
Manager
of
Solvent
Control
Section,
California
Air
Resources
Board
8
Bob
Warland,
Regional
Air
Pollution
Control
Engineer,

Region
IV,
New
York
State
Department
of
Environmental
Control
Regional
Headquarters
Environmental
Protection
Agency
Bruce
Jordan,
Director,
Emission
Standard
Division,
Office
of
Air
Quality
Planning
and
Standards,
U.
S.
Environmental
Protection
Agency
Federal
Government
Observer
Chris
Kirtz,
Director,
Consensus
and
Dispute
Resolution
Program,
U.
S.
Environmental
Protection
Agency
9
9
(
d)
General
Guidelines
This
ICR
adheres
to
the
guidelines
for
Federal
data
requestors,
as
provided
at
5
CFR
1320.5(
d)(
2).

(
e)
Confidentiality
(
i)
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
36902,

September
1,
1976;
amended
by
43
FR
39999,
September
28,
1978;

43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

(
ii)
Sensitive
questions.
This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Codes
Respondents
to
this
information
collection
are
manufacturers
and
importers
of
architectural
coatings.
Manufacturers
of
architectural
coatings
fall
within
standard
industrial
classification
(
SIC)
2851,
"
Paints,
Varnishes,
Lacquers,
Enamels,

and
Allied
Products."
Importers
of
architectural
coatings
fall
within
SIC
5198,
"
Wholesale
Trade:
Paints,
Varnishes,
and
Supplies."

(
b)
Information
Requested
(
i)
Data
items,
including
recordkeeping
requirements.

Attachment
1,
Source
Data
and
Information
Requirements,

summarizes
the
labeling,
recordkeeping
and
reporting
requirements.
All
records
required
under
the
rule
must
be
retained
for
3
years.

(
ii)
Respondent
activities.
Table
2
presents
the
labeling,

recordkeeping
and
reporting
activities
and
burdens
for
the
rule.

The
respondent
activities
required
by
the
standards
are
listed
in
the
first
column
of
table
2.

Several
States
regulate
architectural
coatings
and
require
certain
labeling,
recordkeeping
and
reporting
activities.
The
regulation
includes
similar
requirements
to
the
extent
practical
in
order
to
minimize
the
cumulative
burden
to
the
industry.
10
TABLE
2.
AVERAGE
ANNUAL
INDUSTRY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
OVER
THE
THREE­
YEAR
PERIOD
BEGINNING
FEBRUARY
1,
2001,
FOR
MANUFACTURERS
COMPLYING
WITH
THE
STANDARDS
FOR
ARCHITECTURAL
COATINGS
Burden
Item
(
A)

Person
Hours
Per
Occurrence
(
hrs/
manufacturer)
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Person
Hours
Per
Respondent
Per
Year
(
a)

(
C=
AxB)
Dollars
Per
Houra
(
D)
Respondents
per
Year
(
E)

Total
Hours
Per
Year
(
E=
CxD)
(
F)

Total
Cost
Per
Yearb
1.
Applications
Not
applicable
2.
Surveys
and
Studies
Not
applicable
3.
Reporting
Requirements
A.
Read
Instructions
2
1
2
$
52
5c
10
$
520
B.
Gathering
Existing
Information
Included
in
3.
C
C.
Write
Report
Initial
Report
2
1
2
$
74
5c
10
$
740
Date
Code
Explanation
1
1
1
$
52
5c
5
$
260
Update
Date
Codes
2
1
2
$
52
50d
100
$
5,200
Recycled
Coatings
Report
­
Mass
Balance
6
1
6
$
74
12.5e
75
$
5,550
Recycled
Coatings
Report
­
Formulation
4
1
4
$
74
12.5e
50
$
3,700
Exceedance
Fee
Annual
Report
64
1
64
$
74
120f
7,680
$
568,320
Tonnage
Exemption
Annual
Report
16
1
16
$
74
100g
1,600
$
118,400
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3.
A
B.
Plan
Activities
8
1
8
$
74
5c
40
$
2,960
C.
Implement
Activities
Calculate
VOC
content
for
Each
Product
336h
1
336
$
52
5c
1,680
$
87,360
Calculate
Adjusted
VOC
for
Recycled
Coatings
20
1
20
$
52
25i
500
$
26,000
Exceedance
Fee
­

Calculations
12.83
1
12.83
$
52
120f
1,540
$
80,080
11
TABLE
2.
AVERAGE
ANNUAL
INDUSTRY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
OVER
THE
THREE­
YEAR
PERIOD
BEGINNING
FEBRUARY
1.2002
FOR
MANUFACTURERS
COMPLYING
WITH
THE
STANDARDS
FOR
ARCHITECTURAL
COATINGS
(
CONTINUED)

Burden
Item
(
A)

Person
Hours
Per
Occurrence
(
hrs/
manufacturer)
(
B)
Number
of
Occurrences
Per
Respondent
Per
Year
(
C)
Person
Hours
Per
Respondent
Per
Year
(
a)

(
C=
AxB)
Dollars
Per
Houra
(
D)
Respondents
per
Year
(
E)

Total
Hours
Per
Year
(
E=
CxD)
(
F)

Total
Cost
Per
Yearb
11
Tonnage
Exemption
Calculations
8
1
8
$
52
100g
800
$
41,600
D.
Record
Data
Recycling
Volumes
8
12
96
$
52
25i
2,400
$
124,800
Exceedance
Fee
8
1
8
$
52
120f
960
$
49,920
Tonnage
Exemption
4
1
4
$
52
100g
400
$
20,800
E.
Time
to
Train
Personnel
Not
applicable
5.
Labeling
67j
1
67
$
52
83k
5,561
$
289,172
Total
23,411
$
1,425.382
a
All
tasks
are
assumed
to
be
performed
by
a
technical
person
($
52/
hr)
unless
otherwise
noted.

Activities
planning
is
assumed
to
be
performed
by
a
manager
($
74/
hr).

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

c
Total
number
of
manufacturers
is
estimated
to
be
500;
1
percent
or
5
per
year
new
respondents
per
year
are
assumed.

d
Assumed
that
10
percent
of
manufacturers
update
some
date
codes
each
year.
(
500
manufacturers)(
0.10)

=
50
manufacturers.

e
Assumed
that
5
percent
of
manufacturers
recycle
coatings.
(
500
manufacturers)(
0.05)
=

25
manufacturers.
Of
the
25
manufacturers,
assumed
half
of
the
recycle
coating
manufacturers
would
demonstrate
compliance
using
mass
balance
and
the
other
half
using
formulations.

f
Economic
model
estimates
a
total
of
958
fee
paying
products,
at
an
average
of
8
products
per
manufacturer;
958
products
÷
8
products
per
manufacturers
=
120
manufacturers.

g
Assumed
that
100
manufacturers
will
use
tonnage
exemption
option.

h
Based
on
a
time
estimate
of
8
hours
per
coating
product.
(
8
hours/
product)(
42
products/
manufacturer)

=
336
hours/
manufacturer.
12
TABLE
2.
AVERAGE
ANNUAL
INDUSTRY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
OVER
THE
THREE­
YEAR
PERIOD
BEGINNING
FEBRUARY
1.2002
FOR
MANUFACTURERS
COMPLYING
WITH
THE
STANDARDS
FOR
ARCHITECTURAL
COATINGS
(
CONTINUED)

12
i
Assumed
that
5
percent
of
manufacturers
recycle
coatings.
(
500
manufacturers)(
0.05)
=
25
manufacturers.

j
Based
on
an
industry
estimate
of
320
hours
needed
to
modify
labels
for
a
company
with
200
paint
products,
or
1.6
hours
per
product.

(
1.6
hours/
product)(
42
products/
manufacturer)
=
67
hours/
manufacturer.

k
Assumed
that
half
of
the
manufacturers
would
have
to
modify
their
labels.

(
500
manufacturers)(
0.5)/
3
years
=
83
manufacturers
per
year.
13
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
3.

(
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.
The
rule
specifically
allows
for
the
maintenance
of
records
in
either
written
or
electronic
form.

(
c)
Small
Entity
Flexibility
Although
the
rule
does
not
contain
any
specific
small
entity
provisions,
the
rule
contains
two
provisions
that
may
reduce
the
burden
of
this
rule
on
small
entities.
These
provisions
are
the
exceedance
fee
provision
and
the
tonnage
exemption.

(
d)
Collection
Schedule
The
rule
requires
all
manufacturers
and
importers
of
subject
coatings
to
submit
an
initial
notification
report
no
later
than
September
13,
1999
(
March
13,
2000
for
products
registered
under
FIFRA),
or
within
180
days
after
becoming
subject
to
the
rule,

whichever
is
later.
All
manufacturers
and
importers
of
subject
coatings
must
submit
an
explanation
of
any
new
date
code
no
later
than
30
days
after
the
new
date
code
is
first
used.

Manufacturers
and
importers
choosing
the
recycled
coating
provision
must
submit
an
annual
report
by
March
1
following
the
year
in
which
the
recycled
coating
provision
is
used.

Manufacturers
and
importers
choosing
the
exceedance
fee
provision
must
submit
an
annual
report
by
March
1
following
the
calendar
year
in
which
the
coatings
for
which
the
fee
provision
is
used
are
manufactured
or
imported.
Manufacturers
and
importers
choosing
the
tonnage
exemption
must
submit
an
annual
report
by
March
1
of
the
year
following
the
calendar
year
in
which
the
exemption
was
claimed.
14
TABLE
3.
AGENCY
BURDEN
FOR
THE
ARCHITECTURAL
COATINGS
RULE
A
B
C
D
E
F
Reports
EPA
Hours
Per
Occurrence
Occurrences
Per
Year
Person
Hours
Per
Year
(
Technical)

C
=
A
x
B
Person
Hours
Per
Year
(
Management)

D
=
C
x
0.05
Person
Hours
Per
Year
(
Clerical)

E
=
C
x
0.1
Total
Cost
Per
Yeara
Initial
Reportb
1.0
5
5
0.3
0.5
$
299
Annual
Report:

Manufacture
of
Recycled
Coatings
­
Mass
Balancec
1.0
12.5
12.5
0.6
1.3
$
739
Annual
Report:

Manufacture
of
Recycled
Coatings
­
Formulationc
0.5
12.5
6.3
0.3
0.6
$
370
Date
Code
Reportsb
0.5
5
2.5
0.1
0.3
$
148
Date
Code
Updatesd
0.5
50
25
1.3
2.5
$
1,481
Annual
Report:

Exceedance
Feee
4.0
120
480
24
48
$
28,368
Annual
Report:

Tonnage
Exemptionf
2.0
100
200
10
20
$
11,820
Maintenance
of
implementation
database
60
1
60
3
6
$
3,546
Totals
306
791.3
39.6
179.2
$
46,771
a
Total
cost
per
year
=
(
column
C)($
52/
hr)
+
(
column
D)($
74/
hr)
+
(
column
E)($
34/
hr).

b
Total
number
of
manufacturers
is
estimated
to
be
500;
1
percent
or
5
new
respondents
per
year
are
assumed.

c
Assumed
25
recycled
coating
manufacturers;
assumed
half
use
mass
balance
option
and
half
use
formulation
option.

d
Assumed
10
percent
of
all
manufacturers
update
some
date
codes
each
year.
(
500
manufacturers)(
0.10)
=

50
manufacturers.

e
Assumed
120
manufacturers
will
pay
fees
on
some
coatings
(
see
footnote
f
in
table
2).

f
Assumed
100
manufacturers
will
use
tonnage
exemption
option.
15
6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
average
annual
burden
estimates
for
reporting,

recordkeeping,
and
labeling
requirements
are
presented
in
table
2
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
1.
Because
this
is
a
renewal
of
an
existing
ICR,
these
estimates
represent
the
average
annual
burden
that
will
be
incurred
by
the
affected
industry
in
the
3­
year
period
beginning
February
1,
2002.
The
hours
shown
in
column
A
of
table
2
are
the
burden
estimate
per
manufacturer.

(
b)
Estimating
Respondent
Cost
Table
2
also
presents
the
estimated
costs
for
the
required
recordkeeping,
reporting,
and
labeling
activities.
Labor
rates,

on
a
per
hour
basis,
are
based
on
those
posted
on
the
Bureau
of
Labor
Statistics
(
BLS)
web
site
(
http://
www.
bls.
gov/
news.
release)

in
May
2001
on
Table
2
of
the
BLS
Employment
Cost
Trends.
The
total
compensation
rates
were
increased
by
100
percent
for
overhead,
resulting
in
the
following
labor
rates:
$
34
for
clerical
personnel,
$
52
for
technical
personnel,
and
$
74
for
management
personnel.
There
are
no
capital
or
operating
and
maintenance
costs
required
by
this
collection.

(
c)
Estimating
Agency
Burden
and
Cost
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
3.
Labor
rates
and
associated
costs
are
based
on
the
same
estimated
industry
hourly
rates
as
follows:
management
at
$
74,
technical
at
$
52,
and
clerical
at
$
34.
16
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
respondent
universe
consists
of
500
architectural
coating
manufacturers.
Of
these,
75
are
considered
large
manufacturers
and
425
are
considered
small
manufacturers.
Due
to
importers'
small
market
presence
(
less
than
1
percent
of
total
coating
sales
volume
in
1990)
and
the
lack
of
detailed
product
data
on
imported
coatings,
importers
have
not
been
included
in
this
burden
estimate.

The
annual
respondent
burden
will
vary
depending
on
the
actual
compliance
choices
that
are
made
by
the
manufacturer
or
importer.
Specifically,
the
burden
will
vary
depending
on
whether
the
recycled
coating,
exceedance
fee,
or
tonnage
exemption
provisions
are
chosen.

In
order
to
estimate
the
industry
burden,
assumptions
were
made
about
the
number
of
manufacturers
that
would
choose
each
of
the
optional
provisions
(
see
appropriate
footnotes
in
table
2).

Other
assumptions
were
that
the
number
of
new
respondents
submitting
the
one­
time
Initial
Notification
Report
and
date
code
explanations
will
be
1
percent
of
the
total
respondent
universe
of
500,
or
about
5
per
year.

(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables
(
i)
Respondent
tally.
The
bottom
line
industry
burden
hours
and
costs,
presented
in
table
2,
are
calculated
by
summing
the
total
hours
per
year
column
(
column
E)
and
by
summing
the
total
cost
per
year
column
(
column
F).
The
annual
burden
and
cost
to
the
industry
averaged
over
the
3­
year
period
beginning
February
1,
2002,
is
23,411
hours
and
$
1,425,382.

The
average
annual
base
reporting,
recordkeeping,
and
labeling
burden
per
manufacturer
for
this
information
collection
request
is
47
hours
(
23,411
hours/
500
manufacturers
=
47
hours
per
manufacturer).
The
actual
burden
for
each
manufacturer
will
vary
depending
on
the
compliance
choices
that
they
make.

Manufacturers
that
meet
all
of
the
mandatory
requirements
and
do
not
select
any
of
the
optional
requirements
will
have
an
annual
17
reporting,
recordkeeping,
and
labeling
burden
of
approximately
15
hours
(
7,406
hours/
500
manufacturers
=
15
hours
per
manufacturer).

Manufacturers
that
choose
the
recycled
coating
provision
will
have
an
annual
reporting,
recordkeeping,
and
labeling
burden
of
approximately
136
hours
[
3,025
hours/
25
manufacturers
=

121
hours
per
manufacturer;
15
hours
+
121
hours
=
136
hours
per
manufacturer].
Manufacturers
that
choose
the
exceedance
fee
provision
will
have
an
annual
reporting,
recordkeeping,
and
labeling
burden
of
approximately
100
hours
[
10,180
hours/
120
manufacturers
=
85
hours
per
manufacturer;
85
hours
+
15
hours
=

100
hours
per
manufacturer].
Manufacturers
that
choose
the
tonnage
exemption
will
have
an
annual
reporting,
recordkeeping,

and
labeling
burden
of
approximately
43
hours
[
2,800
hours/
100
manufacturers
=
28
hours
per
manufacturer;
28
hours
+
15
hours
=

43
hours
per
manufacturer].

The
total
per
manufacturer
reporting,
recordkeeping,
and
labeling
burden
is
the
lowest
for
manufacturers
that
meet
the
VOC
content
limits,
and
would
be
higher
for
those
that
choose
the
optional
tonnage
exemption,
exceedance
fee
provision,
or
recycled
coating
provision.

(
ii)
Agency
tally.
The
bottom
line
Agency
burden
and
cost,

presented
in
table
3
is
calculated
in
the
same
manner
as
the
industry
burden
and
cost.
The
estimated
annual
burden
and
cost
averaged
over
the
3­
year
period
beginning
February
1,
2002,
are
1,010
hours
and
$
46,771.

(
iii)
The
complex
collection.
This
ICR
is
a
simple
collection;
therefore
this
section
does
not
apply.

(
iv)
Variations
in
the
annual
bottom
line.
No
significant
variations
in
the
annual
respondent
burden
or
cost
are
expected
over
the
3­
year
period
beginning
on
February
1,
2002.
18
(
f)
Reasons
for
Change
in
Burden
This
renewal
of
a
continuing
ICR
includes
the
following
onetime
burden
and
cost
items:
reading
instructions,
the
initial
report,
the
explanation
of
date
codes,
planning
activities,
and
calculating
VOC
content.
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
more
than
2
years.
Therefore,
the
EPA
assumes
that
the
vast
majority
of
one­
time
initial
reports
already
will
have
been
submitted
by
February
2002
and
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
(
see
footnotes
in
table
2).

(
g)
Burden
Statement
The
total
reporting
and
recordkeeping
burden
for
this
information
collection
averaged
over
the
3­
year
period
beginning
on
February
1,
2002,
is
estimated
to
be
23,411
hours
per
year.

The
total
annualized
recordkeeping
and
reporting
costs
for
this
rule
are
estimated
to
be
$
1,425,382.
This
is
the
estimated
burden
for
the
estimated
500
respondents
(
i.
e.,
architectural
coating
manufacturers).

The
average
estimated
burden,
per
respondent,
is
47
hours
per
year.
The
total
reporting
and
recordkeeping
burden
for
an
individual
respondent
will
vary
depending
on
the
compliance
option(
s)
chosen.
Respondents
meeting
the
VOC
content
limits
will
have
the
lowest
reporting
and
recordkeeping
burden.

Manufacturers
and
importers
that
choose
the
option
of
calculating
an
adjusted
VOC
content
for
recycled
coatings,
paying
an
exceedance
fee,
or
exercising
the
tonnage
exemption
will
have
a
higher
reporting
and
recordkeeping
burden.
The
final
rule
requires
an
initial
one­
time
notification
from
each
respondent.

Respondents
whose
coating
products
have
a
VOC
content
that
is
less
than
or
equal
to
the
VOC
content
limits
have
no
periodic
requirements.
Respondents
using
the
recycled
coatings
provision
must
keep
records
and
submit
annual
reports.
Respondents
taking
19
advantage
of
the
tonnage
exemption
must
file
an
annual
report
and
must
maintain
records
for
the
coatings
being
claimed
under
the
exemption.
Respondents
paying
an
exceedance
fee
must
keep
records
for
each
coating
product
on
which
fees
are
paid
and
submit
an
annual
report.

Burden
in
this
context
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,

retain,
disclose,
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to:
(
1)
review
instructions;
(
2)
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,

validating,
and
verifying
information,
and
disclosing
and
providing
information;
(
3)
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
(
4)

train
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
5)
search
data
sources;
(
6)
complete
and
review
the
collection
of
information;
and
(
7)
transmit
or
otherwise
disclose
the
information.
A­
1
Attachment
1
Source
Data
and
Information
Requirements
Requirement
Regulation
Reference
LABELING

Date
of
Manufacture
59.405(
a)(
1)


Recommendation
for
thinning
59.405(
a)(
2)


VOC
content
59.405(
a)(
3)

In
addition,
for
each
industrial
maintenance
coating:


One
of
the
following
statements
of
use
59.405(
b)

For
industrial
use
only.

For
professional
use
only.

Not
for
residential
use.
or
Not
intended
for
residential
use.
or,

This
coating
is
intended
for
use
under
the
following
condition(
s):
(
Include
each
condition
that
applies
to
the
coating.)

Immersion
in
water,
wastewater,
or
chemical
solutions
(
aqueous
and
nonaqueous
solutions),
or
chronic
exposure
of
interior
surfaces
to
moisture
condensation;

Acute
or
chronic
exposure
to
corrosive,
caustic,
or
acidic
agents,
or
to
chemicals,
chemical
fumes,
or
chemical
mixtures
or
solutions;

Repeated
exposure
to
temperatures
above
120
oC
(
250
oF);

Repeated
(
frequent)
heavy
abrasion,
including
mechanical
wear
and
repeated
(
frequent)
scrubbing
with
industrial
solvents,
cleansers,
or
scouring
agents;
or,

Exterior
exposure
of
metal
structures
and
structural
components
In
addition,
for
each
coating
using
the
optional
recycled
coating
credit:
Attachment
1
(
continued)

Requirement
Regulation
Reference
A­
2

The
statement
"
Contains
not
less
than
X
percent
by
volume
post­
consumer
coating."
Where
"
X"
is
replaced
with
the
percent,
by
volume,
of
postconsumer
coating
59.405(
c)

RECORDKEEPING
For
each
coating
for
which
the
optional
recycled
coating
credit
is
applied:


Minimum
volume
percent
post­
consumer
coating
content
59.407(
a)(
1)


Volume
of
post­
consumer
coating
received
for
recycling
59.407(
a)(
2)


Volume
of
post­
consumer
coating
received
that
was
unusable
59.407(
a)(
3)


Volume
of
virgin
materials
59.407(
a)(
4)


Volume
of
final
recycled
coating
59.407(
a)(
5)


Calculation
of
adjusted
VOC
content
59.407(
a)(
6)

For
each
manufacturer
and
importer
using
the
optional
exceedance
fee
provision:


A
list
of
the
coatings
and
the
associated
coating
categories
in
table
1
of
the
regulation
for
which
the
exceedance
fee
is
used
59.407(
b)(
1)


Calculation
of
the
annual
fee
for
each
coating
and
the
total
annual
fee
for
all
coatings
59.407(
b)(
2)


The
VOC
content
of
each
coating
59.407(
b)(
3)


The
excess
VOC
content
of
each
coating
59.407(
b)(
4)


The
total
volume
manufactured
or
imported
per
period
for
each
coating
59.407(
b)(
5)


The
annual
fee
for
each
coating
59.407(
b)(
6)


The
total
annual
fee
for
all
coatings
59.407(
b)(
7)

For
each
manufacturer
or
importer
using
the
optional
tonnage
exemption:
Attachment
1
(
continued)

Requirement
Regulation
Reference
A­
3

A
list
of
all
coatings
and
the
associated
coating
categories
in
table
1
of
the
regulation
for
which
the
tonnage
exemption
is
claimed
59.407(
c)(
1)


The
VOC
content
of
each
coating
for
which
the
exemption
is
claimed
59.407(
c)(
2)


The
annual
sales
for
each
coating
for
which
the
exemption
is
claimed
59.407(
c)(
3)


The
megagrams
of
VOC
contained
in
each
coating
for
which
the
exemption
is
claimed,
and
for
all
coatings
combined
for
which
the
exemption
is
claimed,
for
the
time
period
the
exemption
is
claimed
59.407(
c)(
4)

REPORTS
Initial
report
for
all
manufacturers
and
importers:


Name
and
mailing
address
of
the
manufacturer
or
importer
59.408(
b)(
1)


The
street
address
of
each
one
of
the
manufacturer's
or
importer's
facilities
in
the
U.
S.
producing,
packaging,
or
repackaging
any
architectural
coating
subject
to
this
subpart.
59.408(
b)(
2)


List
of
categories
of
coatings
in
table
1
of
the
regulation
for
which
the
manufacturer's
or
importer's
coatings
meet
the
definition
59.408(
b)(
3)


Explanation
of
date
code,
if
applicable
59.408(
b)(
4)

Annual
report
for
coatings
for
which
the
optional
recycled
coating
credit
is
applied:


Minimum
post­
consumer
content
of
coatings
59.408(
c)(
1)


Volume
of
post­
consumer
coating
received
for
recycling
59.408(
c)(
2)


Volume
of
post­
consumer
coating
received
that
was
unusable
59.408(
c)(
3)


Volume
of
virgin
materials
used
59.408(
c)(
4)


Volume
of
recycled
coating
manufactured
or
imported
59.408(
c)(
5)
Attachment
1
(
continued)

Requirement
Regulation
Reference
A­
4
Annual
report
for
manufacturers
and
importers
using
the
optional
exceedance
fee:


Name
and
address
59.408(
d)(
1)


A
list
of
all
coatings
and
the
associated
coating
categories
for
which
the
exceedance
fee
is
being
used
59.408(
d)(
2)


VOC
content
of
each
coating
that
exceeds
the
applicable
VOC
content
limit
in
table
1
of
the
regulation
59.408(
d)(
3)


Excess
VOC
content
of
each
coating
product
for
which
a
fee
is
paid
59.408(
d)(
4)


Total
annual
volume
of
all
coatings
for
which
a
fee
is
paid
59.408(
d)(
5)


The
annual
fee
for
each
coating
59.408(
d)(
6)


The
total
annual
fee
for
all
coatings
59.408(
d)(
7)

Annual
report
for
manufacturers
and
importers
using
the
optional
tonnage
exemption:


A
list
of
all
coatings
and
the
associated
coating
categories
in
table
1
of
the
regulation
for
which
the
tonnage
exemption
was
claimed
59.408(
e)(
1)


The
VOC
content
of
each
coating
for
which
the
exemption
was
claimed
59.408(
e)(
2)


The
actual
sales
for
each
coating
for
which
the
exemption
was
claimed
59.408(
e)(
3)


The
total
megagrams
of
VOC
contained
in
all
the
coatings
for
which
the
exemption
was
claimed
59.408(
e)(
4)
