1
INFORMATION
COLLECTION
REQUEST
(
ICR)
Part
A
of
the
Supporting
Statement
(
May
2004)
­
DRAFT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title:
Detergent
Gasoline:
Certification
Requirements
for
Manufacturers
of
Detergent
Additives;
Requirements
for
Transferors
and
Transferees
of
Detergent
Additives;
Requirements
for
Blenders
of
Detergents
into
Gasoline
or
Post­
refinery
Component;
Requirements
for
Manufacturers,
Transferors,
and
Transferees
of
Gasoline
or
Post­
refinery
Component
(
40
CFR
80
­
Subpart
G)
EPA
ICR
No.
1655.05,
OMB
Control
No.
2060­
0275
1(
b)
Abstract
Gasoline
combustion
results
in
the
formation
of
engine
deposits.
The
accumulation
of
deposits,
particularly
in
the
orifices
of
fuel
injectors
and
on
intake
valves,
typically
results
in
increased
emissions
and
reduced
engine
performance.
As
fuel
injectors
replaced
carburetors
in
the
1980'
s,
a
number
of
vehicle
manufacturers
experienced
problems
with
deposit
formation.
Detergent
additives,
which
had
been
available
for
years
to
control
deposits
in
carbureted
vehicles,
were
improved
to
accommodate
the
new
technology.
However,
their
use
was
voluntary
and
there
were
no
regulatory
standards
by
which
to
gauge
their
effectiveness.
Congress
recognized
the
importance
of
effective
detergent
additives
in
minimizing
vehicle
emissions,
and
added
Section
211(
1)
in
the
Clean
Air
Act
Amendments
of
1990.
It
required
gasoline
to
contain
detergent
additives,
effective
January
1,
1995,
and
provided
the
Environmental
Protection
Agency
(
EPA)
with
the
authority
to
establish
specifications
for
such
additives.
The
regulations
at
40
CFR
80
­
Subpart
G
implemented
certification
requirements
for
detergents
and
imposed
a
variety
of
recordkeeping
and
reporting
requirements
for
certain
parties
involved
with
detergents,
gasoline,
or
post­
refinery
component
(
any
gasoline
blending
stock
or
any
oxygenate
which
is
blended
with
gasoline
subsequent
to
the
gasoline
refining
process
(
PRC)).
All
gasolines
must
contain
certified
detergents,
with
the
exception
of
research,
racing,
and
aviation
gasolines.

The
EPA
maintains
a
list
of
certified
gasoline
detergents
at
www.
epa.
gov/
otaq/
regs/
fuels.
As
of
May
2004
there
were
323
certified
detergents
and
18
detergent
manufacturers.
Most
of
the
certification
activity
occurred
during
the
early
years
of
the
program.
In
2003
only
28
detergents
were
certified.
During
January­
April
2004,
11
detergents
were
certified.

There
are
approximately
250
refiners
and
importers
of
gasoline,
1350
blenders
of
detergent
into
gasoline
or
PRC,
8000
carriers
of
gasoline
or
PRC,
200,000
gasoline
retail
outlets,
and
100,000
fleet
facilities
which
handle
gasoline.
The
program
is
run
by
the
Transportation
and
Regional
Programs
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation,
EPA,
in
Washington,
DC.
2
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Motor
vehicles
comprise
the
major
source
of
air
pollution
in
most
urban
areas,
and
account
for
about
half
of
the
toxic
air
emissions
in
the
United
States.
Gasoline
detergents
help
to
minimize
emissions.
Detergents
are
typically
added
to
gasoline
as
it
is
loaded
into
tank
trucks
at
terminals.
Section
211(
l)
of
the
Clean
Air
Act
(
Act)
requires
that
all
gasoline
contain
effective
detergent
additives.
Section
114
of
the
Act
provides
EPA
with
the
authority
to
impose
recordkeeping
and
reporting
requirements
if
necessary
for
enforcement
of
statutory
requirements.
The
recordkeeping
and
reporting
requirements
for
this
program,
at
40
CFR
80
­
Subpart
G,
are
necessary
in
order
for
EPA
to
certify
detergents,
to
demonstrate
that
certified
detergents
are
effective,
to
assure
that
gasoline
contains
certified
detergents
at
the
minimum
concentration
(
also
known
as
the
lowest
additive
concentration(
LAC))
necessary
to
be
effective,
and
to
deter
violations.
There
is
no
standard
test
procedure
for
testing
qualitatively
and
quantitatively
for
specific
detergents
in
gasoline,
thus
necessitating
reliance
on
recordkeeping
and
reporting
as
detergents,
gasoline,
and
PRC
pass
through
the
distribution
system.
Blenders
of
detergent
into
gasoline
or
PRC
are
required
to
maintain
records
that
demonstrate
that
the
LAC
is
met,
on
average,
each
month
at
each
automated
blending
facility,
and
by
batch
at
non­
automated
facilities.
These
records
are
known
as
volumetric
additive
reconciliation
(
VAR)
records.
There
is
economic
incentive
to
violate
because
uncertified
detergents
are
typically
less
expensive,
and
blending
a
certified
detergent
at
less
than
the
minimum
specified
concentration
will
also
same
money.

A
detergent
manufacturer
has
a
variety
of
options
under
which
it
may
certify
a
detergent.
The
primary
option
is
"
National
Generic
Certification,"
which
allows
the
detergent
to
be
used
in
any
gasoline.
Nine
out
of
ten
detergents
have
been
certified
under
this
option.
Other
options
include
limiting
a
detergent
to
a
Petroleum
Administrative
Defense
District
(
PADD
Certification),
a
specific
gasoline
pool
(
Fuel­
specific
Certification),
or
California
gasoline,
under
California's
detergent
certification
rule.
All
the
options
may
be
found
at
40
CFR
80.163.

REPORTING
REQUIREMENTS
Detergent
Manufacturers
For
each
detergent,
the
detergent
manufacturer
(
includes
an
importer
or
a
party
which
is
not
the
manufacturer
but
is
requesting
certification
as
a
detergent
for
a
product
manufactured
by
another
party)
is
required
to:

(
1)
submit
a
certification
letter
to
EPA
containing
a
variety
of
information
concerning
the
3
certification
testing
and
options
for
which
certification
is
requested
(
80.161(
b)(
3),
80.163(
c)(
1)(
iii),
80.164(
a));

(
2)
submit
certification
test
data,
and/
or
the
acceptance
criteria
a
supplier
must
meet
for
detergent
reactant
materials,
upon
EPA
request
(
80.165,
80.162(
b)(
1));

(
3)
submit
a
detailed
description
of
the
detergent's
composition
to
EPA
pursuant
to
the
registration
requirements
for
fuel
additives
at
40
CFR
79,
addressing
specific
compositional
descriptions
identified
in
40
CFR
80
and
the
LAC
for
each
certification
option
(
80.161(
b)(
1)(
i),(
ii),(
ii)(
A),
80.162);

(
4)
ship
a
sample
of
the
detergent
and
certain
information
concerning
the
sample
to
EPA,
and
if
requested
by
EPA,
ship
an
additional
sample
(
80.161(
b)(
2),
80.167(
d));

(
5)
notify
EPA
in
writing,
with
supporting
data,
if
there
is
a
change
in
the
LAC
for
which
the
additive
is
effective
(
80.161(
b)(
1)(
ii)(
C));

(
6)
notify,
in
writing,
gasoline
manufacturers
(
includes
importers),
detergent
blenders,
and
all
others
who
purchase
the
detergent,
of
the
LAC
and
any
use
restrictions
(
80.161(
c));

(
7)
submit
certain
information
annually
for
each
fuel­
specific
certification
option
(
80.164(
c)(
3));

(
8)
notify
customers
if
a
fuel­
specific
certification
is
no
longer
valid
(
80.164(
c)(
3)(
iii));

(
9)
if,
upon
receipt
from
EPA
of
a
notice
of
intent
of
detergent
disqualification,
wishing
to
respond,
submit
written
comments
in
an
attempt
to
demonstrate
compliance
(
80.161(
e)(
3),
(
4);
and
(
10)
submit
a
list
of
customers
to
EPA
if
EPA
should
issue
a
final
decision
to
disqualify
a
certified
detergent
(
80.161(
e)(
6)).

Detergent
Blenders
A
blender
of
detergent
into
gasoline
or
PRC:

(
1)
is
required
to
notify
EPA
in
writing
if
it
intends
to
use
a
detergent
at
lower
than
its
LAC,
and,
if
requested
by
EPA,
must
submit
the
data
supporting
the
use
of
the
lower
concentration
(
80.161(
d)(
1),
(
2),
(
3));

(
2)
who
has
certified
under
a
fuel­
specific
option,
is
required
to
supply,
upon
request,
EPA
with
a
sample
of
the
test
fuel
or
with
blendstocks
with
which
to
formulate
the
test
fuel
(
80.167(
d));
and
4
(
3)
is
required
to
generate
VAR
records
(
80.170),
and,
upon
request,
to
provide
EPA
with
VAR
records
and
supporting
documentation
(
80.170(
g)).

Transferors
and
Transferees
A
transferor
of
gasoline,
detergent,
or
PRC,
including
any
gasoline
refiner,
importer,
reseller,
distributor,
carrier,
retailer,
wholesale
purchaser­
consumer
(
WPC),
oxygenate
blender,
detergent
manufacturer,
distributor,
carrier,
or
blender,
shall:

(
1)
generate
or
obtain
documentation
for
each
shipment
and
provide
this
documentation
(
product
transfer
document
(
PTD))
to
the
transferee
(
with
exception
of
delivery
of
detergent­
additized
gasoline
to
motorists
and
small
volumes
to
fleets)
identifying
the
product,
its
detergent
status
if
gasoline
or
PRC,
and
certain
additional
information
(
80.171);
and
(
2)
as
a
defense
against
liability,
along
with
transferees,
may
establish
quality
assurance
(
QA)
procedures
that
involve
the
development
of
records
in
addition
to
those
required
by
the
rules
(
80.169).

Researchers
A
party
conducting
research
on
gasoline
that
does
not
contain
a
certified
detergent
is
required
to
notify
EPA
annually,
in
writing
(
80.173(
a)(
3)).

Racing
Gasoline/
Aviation
Gasoline
Parties
handling
racing
gasoline
or
aviation
gasoline
are
required
to
generate
or
transfer
PTD's
indicating
that
these
products
are
limited
to
those
uses
(
80.173(
b)(
1)).
Pump
stands
for
racing
gasoline
or
aviation
gasoline
must
be
appropriately
labeled
if
located
at
a
facility
that
dispenses
gasoline
to
motor
vehicles
(
80.173(
b)(
2)).

RECORDKEEPING
REQUIREMENTS
Most
records
are
required
to
be
kept
for
five
years,
with
exceptions
for
certain
small
businesses
and
California
gasoline
(
80.164(
c)(
4),
80.169(
c)(
8),
80.170(
g),
80.171(
d)).
This
retention
period
is
necessary
in
order
to
provide
EPA
with
adequate
time
for
inspection,
is
consistent
with
the
relevant
civil
statute
of
limitations,
and
is
consistent
with
the
retention
period
for
PTD's
under
the
reformulated
gasoline/
anti­
dumping
rules
at
40
CFR
80
­
Subpart
D
(
except
for
retailers
in
anti­
dumping
areas).
There
is
no
regulatory
burden
because
businesses
retain
such
records
as
a
customary
business
practice.
5
Detergent
Manufacturers
For
each
detergent,
the
detergent
manufacturer
is
required
to
maintain
records
for:

(
1)
the
acceptance
criteria
for
suppliers
of
detergent
reactive
materials
(
80.162(
b)(
1));

(
2)
the
test
data
for
fuel
parameters
supporting
a
fuel­
specific
certification
(
80.164(
c)(
1));

(
3)
the
fuel
composition
survey
results,
and
documentation
on
test
methods
and
statistical
procedures,
used
to
support
a
fuel­
specific
certification
(
80.164(
c)(
4));

(
4)
the
certification
test
(
80.165);
and
(
5)
in
order
to
have
an
affirmative
defense
for
a
potential
violation
the
certification
program
controls
and
prohibitions,
the
fourier
transform
infrared
spectroscopy
(
FTIR)
and
related
data
for
each
detergent
batch
(
80.169(
c)(
4)(
i)(
C),(
D)).

Detergent
Blenders
A
blender
of
detergent
into
gasoline
or
PRC
is
required
to
maintain
the
VAR
records
on
the
use
of
the
detergent
(
80.170).
Gasoline
or
PRC
additized
in
California
is
exempt,
provided
the
records
required
by
California
are
maintained
(
80.173(
c)).

Transferors
and
Transferees
Transferors
and
transferees
of
gasoline,
detergent,
or
PRC:

(
1)
are
required
to
maintain
the
PTDs
for
each
shipment
(
80.171);
and
(
2)
as
a
defense
against
liability,
may
establish
QA
procedures
that
involve
retaining
records
in
addition
to
those
required
to
be
retained
by
the
rules
(
80.169).

Researchers
A
party
conducting
research
on
gasoline
that
does
not
contain
a
certified
detergent
is
required
to
maintain
documentation
demonstrating
that
the
gasoline
has
been
used
only
for
research
(
80.173(
a)(
1)).
6
Racing
Gasoline/
Aviation
Gasoline
Parties
handling
racing
gasoline
or
aviation
gasoline
are
required
to
maintain
the
PTDs
for
each
shipment
(
80.173(
b)(
1)).

2(
b)
Practical
Utility/
Users
of
the
Data
The
list
of
certified
detergents
is
publicly
available.
The
fuel,
additive,
and
motor
vehicle
industries
are
well
aware
that
gasoline
must
contain
certified
detergents.
The
list
is
monitored
by
the
additive
manufacturers
in
order
to
maintain
an
awareness
of
competitors.
Manufacturers
and
distributors
of
gasoline,
and
blenders
of
detergent
into
gasoline,
monitor
the
list
to
ensure
that
gasoline
contains
certified
detergents
and
that
the
documentation
accompanying
gasoline
indicates
such.

Most
of
the
data
submitted
by
the
detergent
manufacturers
are
confidential.
Thus
access
is
restricted
to
authorized
EPA
personnel
and
authorized
contractors.
Review
of
the
data
is
necessary
to
determine
if
the
detergent
manufacturer
has
met
the
certification
requirements
for
a
specific
detergent
and
can
be
certified
by
EPA.
The
documentation
accompanying
the
detergent,
with
the
LAC
and
any
use
restrictions,
is
used
by
the
detergent
blender
to
ensure
proper
additization.
PTDs
are
monitored
by
transferors
and
transferees
to
ensure
that
they
are
handling
legal
detergents
and
gasolines.
VARs
are
necessary
for
detergent
blenders
to
demonstrate
that
they
have
additized
properly.

As
mentioned
above,
there
is
not
a
method
of
analyzing
gasoline
for
the
proper
level
of
a
certified
detergent.
Thus,
the
records
required
by
this
rule,
particularly
the
VAR
and
certification
records,
are
essential
in
EPA's
monitoring
for
compliance.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
records
required
here
are
not
available
elsewhere.
In
many
instances
the
records
are
7
already
produced
as
a
customary
business
practice.

3(
b)
Public
Notice
This
draft
ICR
was
announced
in
the
Federal
Register.

3(
c)
Consultations
Certification
by
the
detergent
manufacturers,
and
the
development
of
VAR
and
QA
records
by
blenders
of
detergent
into
gasoline
or
PRC,
account
for
the
regulatory
burden.
The
other
burdens
discussed
above
are
minor
or
customary
business
practices
upon
which
the
regulations
did
not
impose
significant
additional
burdens.

As
this
program
has
matured,
just
about
all
of
the
applications
for
detergent
certification
now
rely
on
previous
vehicle
testing.
Three
years
ago
it
was
nine
out
of
ten
applications.
Now,
it's
29
out
of
30
applications
that
rely
on
previous
vehicle
testing.
Thus,
since
about
30
applications
are
now
received
annually,
only
one
application
annually
is
based
on
new
testing.

Consultations
with
detergent
manufacturers
indicate
that
they
have
become
quite
familiar
with
submitting
applications
based
on
previous
testing,
with
burden
estimates
ranging
from
two
to
six
hours
for
preparation
and
submittal
of
the
application.
For
an
application
based
on
new
testing,
however,
there
was
a
broad
range
of
estimates,
from
80
hours
to
1000
hours.
We
believe
that,
as
with
the
previous
ICR,
a
reasonable
average
continues
to
be
60
hours
for
a
detergent
certification.

Consultations
with
detergent
blenders
which
use
automated
blending
equipment
(
the
vast
majority
of
blenders)
also
indicates
a
range
of
estimated
VAR/
QA
burden,
from
about
30
to
260
hours
per
year
per
facility.
This
is
to
be
expected
since
there
is
a
wide
range
in
the
size
of
these
facilities
and
a
wide
range
in
the
degree
of
sophistication
utilized
in
implementing
the
VAR
requirements
and
voluntary
QA
procedures.
The
estimate
for
a
detergent
blender
which
does
not
use
automated
equipment
is
480
hours
per
year.
A
major
reason
for
the
difference
in
burden
between
automated
and
non­
automated
equipment
is
the
VAR
period,
which
may
be
up
to
30
days
for
automated
equipment,
but
is
by
batch
for
non­
automated
equipment
and
calculated
manually.

3(
d)
Effects
of
Less
Frequent
Collection
Certification
of
an
additive
is
one­
time,
with
the
exception
of
an
annual
fuel­
property
report
in
the
case
of
a
fuel­
specific
certification.
(
As
of
March
2000,
there
were
no
fuel­
specific
certifications,
and
no
indication
that
any
would
be
forthcoming.)
VAR
records
and
PTDs
are
8
ongoing
and
necessary
for
enforcement.
The
generation
and
transfer
of
PTDs
are
customary
business
practices.
Researchers
using
gasoline
without
a
certified
detergent
are
required
to
submit
a
brief
annual
report
on
their
activities.
EPA
believes
that
the
annual
reporting
requirements
are
reasonable
and
that
a
less
frequent
collection
would
hamper
enforcement.
Thus,
less
frequent
collection
is
not
a
practicable
alternative.

3(
e)
General
Guidelines
All
Office
of
Management
and
Budget
(
OMB)
guidelines
are
met.

3(
f)
Confidentiality
Most
of
the
information
reported
to
EPA
is
business
confidential
and
is
governed
by
the
Freedom
of
Information
Act
regulations
for
EPA
at
40
CFR
2.

3(
g)
Sensitive
Questions
There
are
none.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
4(
a)
Respondents/
SIC/
NAICS
Codes
The
respondents
are
related
to
the
following
major
group
Standard
Industrialization
Classification
(
SIC)
codes:

5172
­
Petroleum
Products
2911
­
Petroleum
Refining
The
respondents
are
related
to
the
following
major
group
NAICS
codes:

324110
­
Petroleum
Refineries
324199
­
All
Other
Petroleum
and
Coal
Products
Manufacturing
325110
­
Petrochemical
Manufacturing
325199
­
All
Other
Basic
Organic
Chemical
Manufacturing
9
424710
­
Petroleum
Bulk
Stations
and
Terminals
424720
­
Petroleum
and
Petroleum
Products
Merchant
Wholesalers
(
except
Bulk
Stations
and
Terminals)

4(
b)
Information
Requested
(
i)
Data
Items
The
information
to
be
reported
to
EPA
and
the
information
to
the
retained
by
the
respondents
was
identified
by
category
and
regulatory
cite
in
section
2
above.
The
regulations
are
in
Attachment
1.
Please
refer
to
the
regulations
for
a
detailed
description
of
the
information
requested.

(
ii)
Respondent
Activities
The
following
are
required:

1.
Read
and
comprehend
the
regulatory
requirements
(
Task
1
(
T1)).
2.
Train
personnel
to
meet
the
requirements,
employing
new
technology
and
procedures
as
necessary
(
Task
2
(
T2)).
3.
Develop
the
information
that
is
not
already
available
(
Task
3(
T3)).
4.
Gather
and
organize
the
information
(
Task
4
(
T4)).
5.
Review
the
information
and,
if
necessary,
take
corrective
action
such
that
it
can
be
concluded
that
the
regulatory
requirements
have
been
met
(
Task
5
(
T5)).
6.
Report
the
information
to
EPA
and/
or
retain
the
information
in
storage,
as
specified
in
the
regulations
(
Task
6(
T6)).

5.
THE
INFORMATION
COLLECTED
B
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
following
are
required:

1.
Develop
a
thorough
understanding
of
the
regulatory
requirements.
2.
Develop
the
skills
necessary
to
convey
the
requirements
to
the
respondents
and
others
such
that
it
can
be
comprehended
easily.
3.
Respond
to
inquiries
on
the
requirements.
10
4.
Provide
access
to
the
regulations
and
the
list
of
certified
detergents..
5.
Review
the
reported
information.
6.
Contact
the
respondent
when
the
information
has
not
been
submitted
properly
and
discuss
how
the
deficiency
can
be
corrected.
7.
Store
the
information.
8.
Enter
the
information
into
the
database.
9.
Upon
concluding
that
all
requirements
have
been
met,
issue
a
letter
to
the
manufacturer
indicating
that
the
detergent
has
been
certified,
and
update
the
list
of
certified
detergents.
10.
Maintain
rigorous
security
for
the
protection
of
confidential
business
information.
11.
Maintain
computer
hardware
and
software.
12.
Monitor
compliance
via
on­
site
inspections.

5(
b)
Collection
Methodology
and
Management
The
EPA
has
not
issued
forms.
The
respondents
may
submit
and
store
the
information
in
the
format
of
their
choice,
including
electronically.
Because
most
of
the
information
reported
to
EPA
is
confidential,
it
is
housed
in
an
office
with
an
advanced
security
system.
The
computers
on
which
the
data
are
handled
have
no
linkage
outside
this
office.

5(
c)
Small
Entity
Flexibility
The
reporting
requirements
have
been
made
as
simple
as
practical
in
order
to
minimize
the
burden
on
all
parties,
large
and
small.
For
small
businesses
subject
to
this
rule,
the
vast
majority
are
merely
transporters
or
retailers
of
gasoline.
Their
only
burden
is
the
transfer
and
storage
of
PTD's,
which
is
a
customary
business
practice.
Transfers
of
small
volumes
of
additized
gasoline
to
WPC's
and
other
ultimate
consumers
are
exempt
from
the
PTD
requirements
(
80.171(
c)).

6.
ESTIMATING
THE
BURDEN
AND
THE
COST
OF
THE
COLLECTION
6(
a)
and
(
b)
Estimating
Respondent
Burden
and
Costs
Estimating
the
burden
is
straightforward.
Capital/
start­
up
costs
were
incurred
by
industry
in
1995.
Third
party
activity,
the
transmittal
or
storage
of
PTDs,
is
a
customary
business
practice.
Operating
and
maintenance
(
O&
M)
costs
are
in
three
categories.
First,
the
on­
road
engine
testing
to
demonstrate
that
the
detergent
meets
the
deposit­
control
standards
is
performed
at
contractor
facilities.
The
cost
of
this
testing
is
about
$
70,000.
As
discussed
above,
this
testing
is
being
performed
for
only
one
new
certified
detergent
each
year,
with
the
other
certifications
based
on
previous
testing.
(
In
the
previous
ICR,
the
estimate
for
this
testing
was
$
400,000.)
The
second
O&
M
cost
is
for
copying
and
postage
for
the
estimated
30
submissions
annually
for
detergent
certification
and
eight
submissions
annually
for
research
notification.
At
an
estimated
$
10
per
submission,
the
annual
cost
is
$
380.
The
third
O&
M
cost
is
for
the
storage
of
the
VAR
records
at
11
the
1300
automated
detergent
blending
facilities
and
50
non­
automated
detergent
blending
facilities.
The
estimated
annual
cost
per
facility
is
$
100,
for
a
total
of
$
135,000.
Thus,
the
total
annual
O&
M
cost
is
$
70,000
+
$
380
+
$
135,000
=
$
205,380.

Three
labor
categories
are
involved:
managerial
(
includes
legal
and
professional
review),
technical,
and
clerical.
According
to
the
Bureau
of
Labor
Statistics,
Employer
Costs
for
Employee
Compensation,
"
Table
12
­
Private
industry,
manufacturing
and
non­
manufacturing
industries
by
occupational
group
(
December
2003),"
(
http://
stats.
bls.
gov/
news.
release/
ecet.
t12.
htm),
the
following
wages
and
benefits
apply
by
cagegory:

Wages
and
Benefits
Managerial
$
49.30
per
hour
Technical
$
32.31
per
hour
Clerical
$
22.42
per
hour
Doubling
for
company
overhead
beyond
wages
and
benefits,
and
for
convenience,
rounding
up
to
the
even
dollar,
gives
the
following
rates
that
will
be
used
in
this
ICR:

Total
Employer
Cost
Managerial
$
100
per
hour
Technical
$
66
per
hour
Clerical
$
46
per
hour
Worksheet
1:
Detergent
Manufacturer
Submissions
for
Certification
Our
review
of
the
submissions
indicates
a
fairly
wide
range
of
burden.
Many
submissions
are
minor
changes
to
existing
certified
detergents
and
are
able
to
rely
on
previously
submitted
data.
We
estimate
that
they
require
about
4
hours
to
prepare.
About
one
out
of
30
undergoes
the
complete
development
cycle
with
estimates
of
80
to
1000
hours
of
burden.
Thus,
we
continue
to
believe
that
the
average
burden
per
detergent
is
estimated
at
about
60
hours,
with
the
hours
and
costs
allocated
as
follows
(
we
estimate
30
submissions
annually
(
18
manufacturers)
for
the
next
three
years):
12
Activity
Management
Technical
Clerical
Read
2
hours/$
200
4
hours/$
264
1
hour/$
46
Train
2
hours/$
200
2
hours/$
132
1
hour/$
46
Develop
data
2
hours/$
200
20
hours/$
1320
1
hour/$
46
Organize
data
2
hours/$
200
4
hours/$
264
1
hour/$
46
Review
2
hours/$
200
10
hours/$
660
1
hour/$
46
Report
or
retain
2
hours/$
200
1
hour/$
66
2
hours/$
92
TOTALS
12
hours/$
1200
41
hours/$
2706
7
hours/$
322
GRAND
TOTAL
60
hours/$
4228
Worksheet
2:
VAR
and
QA
by
Detergent
Blenders
with
Automated
Equipment
As
noted
above,
respondents
indicated
a
fairly
wide
range
of
burden,
from
30
to
260
hours
per
year
per
blending
facility,
for
the
1300
facilities
nationwide.
The
VAR
period
may
be
as
long
as
30
days,
but
can
be
shorter
due
to
changes
in
detergents,
maintenance
downtime,
etc.
We
believe
that
a
reasonable
average
burden
is
150
hours
per
year
per
facility,
representing
15
VAR
periods,
for
a
total
of
1300
x
15
=
19,500
responses
annually.
Thus,
the
estimated
hours
and
costs
per
VAR
period
are:
13
Activity
Management
Technical
Clerical
Read
0.1
hour/$
10.00
0.8
hour/$
52.80
0.4
hour/$
18.40
Train
0.1
hour/$
10.00
0.8
hour/$
52.80
0.4
hour/$
18.40
Develop
data
0.1
hour/$
10.00
1.4
hour/$
92.40
1.33
hour/$
61.18
Organize
data
0.1
hour/$
10.00
0.8
hour/$
52.80
1.33
hour/$
61.18
Review
0.1
hour/$
10.00
0.8
hour/$
52.80
0.73
hour/$
33.58
Retain
0.1
hour/$
10.00
0.2
hour/$
13.20
0.4
hour/$
18.40
TOTALS
0.6
hour/$
60.00
4.8
hours/$
316.80
4.6
hours/$
211.60
GRAND
TOTAL
10
hours/$
588.40
Worksheet
3:
VAR
and
QA
by
Detergent
Blenders
with
Non­
automated
Equipment
There
appears
to
be
little
blending
occurring
with
non­
automated
equipment.
However,
since
it
is
done
manually,
and
the
VAR
is
done
per
batch,
the
one
estimate
we
received
of
480
hours
per
year
appears
reasonable.
It
is
estimated
that
a
blender
of
this
type
will
do
about
a
thousand
batches
per
year,
or
a
burden
of
0.5
hour
per
batch
by
rounding
to
500
hours
per
year.
Using
the
same
labor
mix
as
Worksheet
2
gives
a
per
batch
cost
of
$
29.42.
We
estimate
that
there
are
50
blenders
in
this
category,
for
a
total
of
50,000
responses
annually.

Worksheet
4:
Notification
by
Researchers
In
2003
EPA
received
eight
letters
from
researchers
notifying
us
that
a
gasoline
without
a
certified
detergent
was
being
used
for
research
purposes.
Assuming
a
management
official
spent
one­
half
hour
on
each
letter
and
a
clerical
person
also
spent
one­
half
hour,
gives
a
burden
of
one
hour
and
$
73
per
letter.

6(
c)
Estimating
Agency
Burden
and
Cost
The
Agency
activities
described
in
section
5(
a)
are
handled
by
engineers
and
scientists
at
the
GS­
13
level
($
80
per
hour,
including
overhead).
The
program
is
running
smoothly
and,
as
noted
above,
the
number
of
requests
for
certification
has
decreased
somewhat
from
the
previous
ICR.
It
is
estimated
that
400
hours
are
spent
annually,
for
a
cost
to
the
government
of
$
32,000.
14
Lease,
computer,
and
security
costs
are
covered
in
the
ICR
for
the
Fuel
and
Fuel
Additive
Registration
requirements
at
40
CFR
79
(
EPA
ICR
Number
309.11,
OMB
Control
Number
2060­
1050),
with
which
this
program
is
closely
integrated.

6(
d)
and
(
e)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs,
and
Bottom
Line
Burden
and
Costs
The
following
worksheet
is
based
on
the
above
discussions.

Worksheet
5:
Annual
Industry
Burden
Activity
Responses
Hours/
Cost
Total
Hours/
Cost
Detergent
Certification
30
60/$
4228
1800/$
126,840
(
18
respondents)

Automated
VAR/
QA
19,500
10/$
588.40
195,000/$
11,473,800
(
1300
respondents)

Non­
automated
VAR/
QA
50,000
0.5/$
29.42
25,000/$
1,471,000
(
50
respondents)

Researcher
Letters
8
1.0/$
73.00
8/$
584.00
(
8
respondents)

TOTALS
69,538
221,808/$
13,072,224
(
1376
respondents)

Thus,
the
net
annual
burden
to
industry
is
221,808
hours
and
$
13,072,224,
plus
$
205,380
in
O&
M
costs.

6(
f)
Reasons
for
Change
in
Burden
The
previous
clearance
consisted
of
69,558
responses,
223,008
hours,
and
$
13,010,117
in
total
costs.
The
small
changes
are
due
to
a
decrease
in
annual
certification
applications,
from
50
to
30,
and
an
update
in
labor
costs.

6(
g)
Burden
Statements
15
There
are
no
forms
on
which
to
place
statements.

Part
B
­
Collection
of
Information
Involving
Statistical
Methods
Not
Applicable
