SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STRATOSPHERIC
OZONE
PROTECTION
A.
JUSTIFICATION
1.
Identification
of
Information
Collection
a)
Title:
"
Servicing
of
Motor
Vehicle
Air
Conditioners"

OMB
Control
Number:
2060­
0247
EPA
Number:
1617.05
b)
Short
Characterization/
Abstract
History.
In
1992,
the
Environmental
Protection
Agency
(
EPA)
developed
regulations
under
section
609
of
the
Clean
Air
Act
Amendments
of
1990
(
Act)
for
the
recycling
of
chlorofluorocarbons
(
CFCs)
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
September
30,
2005.
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
April
11,
2005,
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
Stratospheric
Protection
Division
(
SPD)
requires
that
certification
programs
send
full
sets
of
their
training
and
testing
materials
to
EPA
for
initial
approval.
The
information
requested
is
used
by
the
SPD
to
guarantee
a
degree
of
uniformity
in
the
testing
programs
for
motor
vehicle
service
technicians.
The
technician
certification
program
must
provide
SPD
with
a
copy
of
its
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
review
and
update
its
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
hard
copy
remains
on
file
in
the
SPD.
Currently,
24
certification
programs
are
authorized
to
train
technicians
in
the
proper
use
of
approved
refrigerant
recycling
equipment
and
give
the
EPA
certification
test.
Approved
independent
standards
testing
organizations.
In
addition,
Section
609(
b)(
2)(
A)
of
the
Act
allows
independent
laboratory
testing
of
refrigerant
recycling
equipment
in
order
to
be
considered
certified
by
EPA.
SPD
requires
independent
laboratories
to
submit
an
application
that
proves
their
general
capacity
to
certify
equipment
to
meet
the
Society
of
Automotive
Engineers
(
SAE)
standards
for
refrigerant
recovery
and
recycling
equipment.
The
requested
information
assures
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
SPD
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
SPD.
Two
laboratories,
Underwriters
Laboratories
Inc.(
UL)
and
Engineering
Testing
Laboratories
(
ETL),
are
currently
approved
to
test
recycling
equipment.
EPA
does
not
anticipate
that
any
additional
organizations
will
apply
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.
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
was
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
SPD:
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
SPD.

§
82.42(
b)
Recordkeeping
requirements.

§
82.42(
b)(
1)
Any
person
who
owns
approved
refrigerant
recycling
equipment
certified
under
§
82.36(
a)(
2)
must
maintain
records
of
the
name
and
address
of
any
facility
to
which
refrigerant
is
sent.

(
2)
Any
person
who
owns
approved
refrigerant
recycling
equipment
must
retain
records
demonstrating
that
all
persons
authorized
to
operate
the
equipment
are
currently
certified
under
§
82.40.

(
3)
Any
person
who
sells
or
distributes
any
class
I
or
class
II
substance
that
is
suitable
for
use
as
a
refrigerant
in
a
motor
vehicle
air
conditioner
and
that
is
in
a
container
of
less
than
20
pounds
of
such
refrigerant,
must
verify
that
the
purchaser
is
properly
trained
and
certified
under
§
82.40.
The
seller
must
have
a
reasonable
basis
for
believing
that
the
information
presented
by
the
purchaser
is
accurate.
The
only
exception
to
these
requirements
is
if
the
purchaser
is
purchasing
the
small
containers
for
resale
only.
In
this
case,
the
seller
must
obtain
a
written
statement
from
the
purchaser
that
the
containers
are
for
resale
only
and
indicate
the
purchasers
name
and
business
address.
Records
required
under
this
paragraph
must
be
retained
for
a
period
of
three
years.

(
4)
All
records
required
to
be
maintained
pursuant
to
this
section
must
be
kept
for
a
minimum
of
three
years
unless
otherwise
indicated.
Entities
which
service
motor
vehicle
air
conditioners
for
consideration
must
keep
these
records
on­
site.

(
5)
All
entities
which
service
motor
vehicle
air
conditioners
for
consideration
must
allow
an
authorized
representative
of
the
Administrator
entry
onto
their
premises
(
upon
presentation
of
his
or
her
credentials)
and
give
the
authorized
representative
access
to
all
records
required
to
be
maintained
pursuant
to
this
section.

§
82.42(
c)
Public
Notification
Any
person
who
conducts
any
retail
sales
of
a
class
I
or
class
II
substance
that
is
suitable
for
use
as
a
refrigerant
in
a
motor
vehicle
air
conditioner,
and
that
is
in
a
container
of
less
than
20
pounds
of
refrigerant,
must
prominently
display
a
sign
where
sales
of
such
containers
occur
which
states:
"
It
is
a
violation
of
federal
law
to
sell
containers
of
Class
I
and
Class
II
refrigerant
to
anyone
who
is
not
properly
trained
and
certified
to
operate
approved
refrigerant
recycling
equipment."

Need
for
and
Use
of
the
Collection
a)
Authority
for
the
Collection
The
information
requested
from
all
entities
that
service
motor
vehicle
air
conditioners
is
required
by
Section
609
of
the
Act,
Subpart
B
 
Servicing
of
Motor
Vehicle
Air
Conditioners.
All
recordkeeping
and
reporting
requirements
are
contained
in
§
82.42
Certification,
recordkeeping
and
public
notification
requirements.

b)
Practical
Utility/
Users
of
the
Data
(
1)
Any
person
who
owns
approved
refrigerant
recycling
equipment
must
retain
records
demonstrating
that
all
persons
authorized
to
operate
the
equipment
are
currently
certified
under
§
82.40.
The
seller
must
have
a
reasonable
basis
for
believing
that
the
information
presented
by
the
purchaser
is
accurate.
There
are
two
exceptions
to
this
rule:
1)
if
the
purchaser
is
purchasing
a
small
container
for
resale
only;
or
if
the
purchaser
is
going
to
service
their
own
car.
If
the
purchaser
is
going
to
resell
the
refrigerant,
they
must
submit
a
written
statement
to
the
seller
stating
that
the
containers
they
are
purchasing
are
for
resale
only
identifying
the
purchasers
name
and
business
address.
Records
required
under
this
paragraph
must
be
retained
for
a
period
of
three
years.

(
2)
EPA
uses
the
refrigerant
recycling
equipment
certificate
to
confirm
compliance
with
Section
609
and
to
identify
businesses
engaged
in
motor
vehicle
air
conditioning
repair
and
maintenance.
The
Agency
is
required
to
either
test
refrigerant
recycling
equipment
itself
or
have
independent
laboratories
test
the
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
UL
and
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.
SPD
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
standards.
EPA
has
only
requested
information
which
will
verify
whether
or
not
a
laboratory
is
capable
of
testing
equipment
to
these
minimum
national
standards.

(
3)
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.
SPD
uses
the
information
submitted
by
an
equipment
owner
or
an
equipment
manufacturer
to
determine
if
its
equipment
is
substantially
identical
to
equipment
certified
by
an
EPA
approved
independent
laboratory.

(
4)
All
records
associated
with
this
collection
must
be
maintained
on­
site
at
service
facilities
for
a
period
of
three
years.
It
is
considered
good
business
practice
to
maintain
records
for
the
life
of
the
business
though,
in
order
to
provide
documentation
of
proper
handling
of
repair,
in
the
event
of
a
dispute.
EPA
inspectors,
mechanics,
and\
or
manufacturing
representatives
use
this
information
to
assess
system
performance,
and
mechanic
care.

(
5)
EPA
requires
service
establishments
to
record
the
name
and
address
of
any
off­
site
facility
to
which
refrigerant
is
sent.
EPA
inspectors
from
the
Office
of
Enforcement
and
Compliance
Assistance
(
OECA)
are
authorized
to
enter
any
service
facility
to
review
records
of
air
conditioning
repair
and
maintenance
activities
by
trained\
certified
personnel
to
verify
their
compliance
with
the
motor
vehicle
air
conditioning
recycling
program.

(
6)
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
programs
every
two
years.
By
requiring
that
a
summary
of
the
review
to
be
sent
to
EPA,
the
Agency
is
assured
of
the
accuracy
of
the
information
and
is
able
to
compare
program
guidelines.

3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
a)
Non­
duplication
The
specific
information
requested
in
this
ICR
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
9/
4/
98
(
63
FR
47284);
no
comments
were
received.

c)
Effects
of
Less
Frequent
Collection
The
equipment
certification
timetable
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
a
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
a)
Respondents
/
NAIC
Codes
The
following
is
a
list
of
NAIC
codes
affected
by
the
manifest
information
requirements
covered
under
this
ICR:

44111
­
New
Motor
Vehicle
Dealers
44112
­
Used
Motor
Vehicle
Dealers
53211
­
Passenger
Car
Rental
81112
­
Top,
Body
Upholstery
Repair
and
Paint
Shops
81111
­
General
Automotive
Repair
Shops
44711
­
Gasoline
Service
Stations
53212
­
Truck
Rental
and
Leasing
Without
Drivers
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
who
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
honestly
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
the
609
regulations
To
ensure
a
degree
of
uniformity
in
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
documentation,
applicants
must
submit
process
flow
sheets,
and
a
complete
list
of
equipment
components.
An
applicant
is
free
to
submit
any
other
information
he
or
she
feels
would
assist
EPA
in
identifying
the
equipment
as
substantially
identical
to
certified
equipment.

Service
establishments
must
record
the
name
and
address
of
any
facility
to
which
any
refrigerant
is
sent
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.

Any
retailer
who
sells
Class
I
and\
or
Class
II
substances
suitable
for
use
as
a
refrigerant
in
a
motor
vehicle
must
post
a
sign
on
the
shelf
,
stating:
"
It
is
a
violation
of
federal
law
to
sell
containers
of
Class
I
and
Class
II
refrigerant
of
less
than
20
pounds
of
such
refrigerant
to
anyone
who
is
not
properly
trained
and
certified
to
operate
approved
refrigerant
recycling
equipment."

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
­
Research
SAE
J
standards
on
motor
vehicle
air
conditioning
recycling
and
recovery
equipment.
­
Compile
test
procedures
to
ensure
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.

F.
Sellers/
Distributors
of
Small
Containers
­
Compile
and
file
written
statements
to
verify
that
purchasers
intend
to
only
resell
the
small
containers
of
refrigerant.

G.
Public
Notification
Any
person
who
conducts
any
retail
sales
of
a
class
I
or
class
II
substance
that
is
suitable
for
use
as
a
refrigerant
in
a
motor
vehicle
air
conditioner,
and
that
is
in
a
container
of
less
than
20
pounds
of
refrigerant,
must
prominently
display
a
sign
where
sales
of
such
containers
occur
which
states:
"
It
is
a
violation
of
federal
law
to
sell
containers
of
Class
I
and
Class
II
refrigerant
to
anyone
who
is
not
properly
trained
and
certified
to
operate
approved
refrigerant
recycling
equipment."

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

­
Review
applications
and
supporting
documents
from
recycling
or
recovery
equipment
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
SPD
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
for
their
use
in
reporting
to
EPA.
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
SPD.
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.
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.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
a)
Estimating
Respondent
Burden,
Estimating
Respondent
Costs,
and
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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.
The
wage
for
service
workers
in
the
motor
vehicle
repair
industry
is
$
16.61,
based
on
Bureau
of
Labor
Statistics'
quotes
from
2005.
The
number
of
respondents
under
the
previous
information
collection
was
estimated
at
10,000,
but
based
on
the
response
from
service
stations
at
the
time
of
the
last
accounting,
we
adjusted
our
estimate
down
to
2,000
service
stations
needing
to
present
a
single
certification
to
EPA
in
a
given
year,
with
an
estimated
burden
of
1/
4
burden
hour,
or
$
4.15
per
service
station.
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.
Original
estimates
about
the
number
of
service
stations
that
would
need
to
submit
certifications
have
been
shown
to
be
invalid.
The
average
hourly
wage
for
service
workers
in
the
automotive
repair
industry
is
$
16.61
according
to
Bureau
of
Labor
Statistics'
quotes
from
2005.
EPA
estimated
that
1,000
certification
forms
would
be
received
per
year.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

ii)
2­
Year
Summary
of
Review
of
Training
Program
There
are
twenty
four
programs
currently
enrolled
in
this
program.
We
have
assessed
the
burden
for
submitting
a
review
of
technician
certification
training
programs
at
1
hour.
Since
certifying
programs
will
need
to
conduct
reviews
of
their
programs,
every
other
year,
the
number
of
burden
hours
is
therefore
calculated
at
12
hours
each
year
for
12
reviews.
The
Training
Director
of
the
certifying
program
would
be
expected
to
conduct
the
program
review,
and
the
salary
of
a
Training
Director
is
approximated
at
$
35.45
in
the
Bureau
of
Labor
Statistics
for
2005.

iii)
Technician
Certification
Programs
The
burden
of
submitting
the
training
program
to
EPA
can
easily
be
incorporated
into
an
establishment's
mailing
system.
The
burden
for
Training
Director's
at
Technician
Certification
developing
a
management
plan
and
a
test
for
submission
to
EPA
was
estimated
at
three
hours
because
of
the
brief
nature
of
the
documentation
needed.
Each
hour
of
the
Training
Director's
time
has
been
valued
at
$
35.45
based
on
estimates
from
the
Bureau
of
Labor
Statistics
for
2005.
New
programs
have
been
submitted
under
this
program,
at
a
rate
of
one
every
other
year,
and
a
burden
of
3
hours
is
therefore
being
added
to
account
for
the
company's
time
to
prepare
submissions
to
apply
for
acceptance
in
this
program.
The
total
number
of
respondents
each
year
in
this
category
is
just
1
program.

iv)
Information
Submission
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.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.
We
do
not
anticipate
any
respondents
in
this
category
during
the
course
of
this
ICR.

v)
Verification
Statements
of
the
Purchase
of
Small
Containers
of
Refrigerant
for
Resale
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).
No
operation
and
maintenance
costs
are
factored
under
this
collection,
because
cabinets
to
maintain
records
are
considered
essential
to
business
operation
regardless
of
this
exercise.
Reporting
is
not
required
and
therefore
no
additional
burden
is
necessary
other
than
what
is
necessary
to
record
sales.
An
average
hour
of
clerical
time
was
valued
at
$
13.10.
per
hour,
based
on
the
Bureau
of
Labor
Statistics
2005
Data
quoted
for
a
Word
Processor\
Typist.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.
The
total
number
of
respondents
is
estimated
at
2,000
and
the
burden
hours
are
500,
based
on
the
fact
that
each
occurrence
only
takes
.25
hours
of
clerical
time.

vi)
Recordkeeping
of
Name
and
Address
of
Facilities
Receiving
Refrigerant
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
determined
from
sales
of
recycling
equipment
that
refrigerant
is
being
recycled
on­
site.
The
removal
of
35,000
service
establishments
from
the
total
number
of
establishments
allowed
us
to
derive
that
the
number
of
establishments
expected
to
use
off­
site
facilities
is
5,000.
This
number
was
based
on
the
continuing
trend
at
service
establishments
to
recycle
on­
site
therefore
reducing
the
burden
in
this
category.
There
are
no
reporting
requirements
associated
with
this
information
collection.
The
median
hourly
rate
for
a
service
station
workers'
time
was
valued
at
$
16.61,
based
on
the
BLS
statistics
from
2005.
The
number
of
respondents
is
estimated
at
5,000,
and
the
burden
hours
are
400
based
on
5
minutes
(
or
.08
hr.
for
each
occurrence).
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.

vii)
All
Equipment
Operators
are
Certified
Technicians
The
time
burden
was
estimated
at
five
minutes
based
on
the
limited
nature
of
the
information
requested
and
the
ease
of
obtaining
the
information.
The
median
hourly
rate
for
a
service
station
workers'
time
was
valued
at
$
16.61,
based
on
the
BLS
statistics
from
2005.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.
The
number
of
respondents
for
this
category
is
estimated
at
14,000,
and
the
burden
is
therefore
assessed
at
1,120
hours
given
that
each
occurrence
only
takes
five
minutes
(
or
.08
hr.)
to
record.

viii)
Public
Notification
The
time
burden
was
estimated
at
.08
hours
to
post
notification
for
customers
of
certification
requirements
for
the
purchase
of
class
I
and
class
II
refrigerants.
The
median
hourly
rate
for
a
service
station
workers'
time
was
valued
at
$
16.61,
based
on
the
BLS
statistics
from
2005.
See
the
attached
table
for
the
estimated
number
of
respondents
and
burden
hours
for
each
respondent.
The
number
of
respondents
for
this
category
is
estimated
at
1,000
vendors,
and
the
burden
is
assessed
at
80
hours,
given
that
each
occurrence
only
takes
five
minutes
(
or
.08
hr.)
to
post.

c)
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.
This
activity
will
be
conducted
by
a
clerical
employee
at
EPA.
We
do
not
expect
any
more
independent
laboratories
to
apply
for
EPA
approval.
Consideration
of
equipment
as
substantially
identical,
has
not
been
requested
once
during
the
course
of
the
current
3­
year
ICR,
so
we
have
eliminated
this
category
from
the
request.
The
EPA
review,
and
response
on
Technician
Certification
Program
Applications
will
be
conducted
by
a
mid­
level
EPA
Analyst,
and
will
take
approximately
16
hours
per
program.
The
opening
at
Headquarters
and
routing
of
Equipment
Certification
Forms
is
handled
by
a
clerical
employee.
This
process
is
estimated
at
2
hours
per
week,
for
a
total
of
100
hours
a
year,
considering
vacations.
The
handling
of
Certification
Forms
in
the
Regions
is
handled
by
a
mid­
level
employee
generally,
and
the
estimate
of
hours
for
that
activity
is
100
hours,
based
on
the
rate
of
30
forms
per
hour.
An
average
labor
rate
of
$
30
per
hour
was
used
to
calculate
the
burden
of
these
activities
conducted
by
EPA
personnel
and
our
current
estimate
for
these
activities
is
200
hours
and
$
6,000.

e)
Bottom
Line
Burden
Hours
and
Cost
Tables
i)
Respondent
Tally
25,013
ii)
Annual
Burden
Hours:
2,865
Annual
Costs:
$
46,002
ii)
Agency
Tally
22
Annual
Burden
Hours:
200
Annual
costs:
$
6,000
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
the
original
ICR
and
was
adjusted
downward
in
the
last
revision
to
this
ICR.
In
this
revision
to
the
ICR,
we
were
able
to
acknowledge
significant
cost
reductions
in
the
public
sector,
because
the
Bureau
of
Labor
Statistics'
data
on
salaries
shows
that
our
previous
salary
assumptions
were
arbitrarily
inflated.
In
addition,
a
number
of
erroneous
entries
and
inconsistencies
were
detected
in
the
previous
revision
to
the
ICR.
Correcting
those
errors
has
resulted
in
significant
reductions
in
resultant
burden
associated
with
this
rule.

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

2
year
review
of
training
program
 
preparing
a
summary
for
submission
to
EPA
1
Submission
of
Technician
Certification
Program
Application
3
Substantially
Identical
Equipment
Response
Activities
Applicant
hrs.

Recording
information
on
equipment
and
submit
to
EPA
1
Maintain
Verification
Statements
for
the
Purchase
of
Small
Containers
of
Refrigerant
for
Resale
.08
Recordkeeping
Requirements
Response
Activities
Sellers
of
Small
Containers
hrs.
Compile
and
file
information
.08
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
Recording
activities
Service
Establishment
hrs.

Filing
equipment
certifications
.25
TOTAL
5.91
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).

Technician
Certification
Program
­­
2
year
review
of
training
program:
40
CFR
82.40.

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).
Public
Notification
Requirement
 
Posting
sign
on
shelf
that
certification
is
required
to
purchase
refrigerant
in
small
containers:
40
CFR
82.42(
c).

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OAR­
2004­
0389,
which
is
available
for
public
viewing
at
the
EPA
Air
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
EPA
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OAR­
2004­
0389
and
OMB
Control
Number
2060­
0247
in
any
correspondence.
ACTIVITY
CAPITAL/
START
UP
BURDEN
CAPITAL/
START
UP
COSTS
#
ANNUAL
RESPONDENTS
ANNUAL
BURDEN
HOURS
RESPONDENT
HOURLY
LABOR
RATE
ANNUAL
COSTS
REPORTING
Compliance
certification
by
owners
of
motor
vehicle
air
conditioning
service
facilities
0
0
2000
0.25
Annual
Burden
=
#
respondents
x
burden
per
response
(
2,000
x0.25=
500
hrs)
500
hrs.
$
16.61
$
8,305
Compliance
certification
by
owners
of
motor
vehicle
air
conditioning
service
facilities
that
change
ownership
or
enter
the
market
0
0
1000
0.25
hrs.

Annual
Burden
=
#
respondents
x
burden
per
response
(
1,000
x0.25=
250
hrs)
250
hrs.
$
16.16
$
4,040
2­
Year
Summary
of
Review
and
technical
changes
to
technician
training
and
certification
program
0
0
12
1hrs
Annual
Burden
=
#
respondents
x
burden
per
response
(
12
x1.0=
12
hrs)
12
hrs.
$
35.45
$
425
609
Technician
Certification
Program
Applications
Received
0
0
1
3
hrs.

Annual
Burden
=
#
respondents
x
burden
per
response
(
1
x
3
­
3
hours)
3
hrs.
$
34.45
$
106
Owners
Submission
of
Request
for
Determination
of
Substantially
Identical
Equipment
0
0
0
0
hrs.

Annual
Burden
=
#
respondents
x
burden
per
response
(
0
x1.0=
0
hrs)
0
hrs.
$
16.61
$
0
TOTALS:
3,013
765
hrs
$
12,876
RECORDKEEPING
The
name
and
address
of
offsite
facilities
receiving
used
refrigerant
0
0
5,000
.08
Annual
Burden
=
#
respondents
x
burden
per
response
(
5,000
x.
08=
400
hrs)
400
hrs.
$
16.61
$
6,644
All
persons
operating
recycling
equipment
are
certified
technicians
0
0
14,000
.08
hrs.

Annual
Burden
=
#
respondents
x
burden
per
response
(
4,000
x
0.08=
1,120
hrs)
1,120
hrs.
$
16.61
$
18,603
Seller
of
refrigerants
maintain
verification
statements
for
the
purchase
of
small
containers
of
refrigerant
intended
for
resale
0
0
2,000
0.25
hrs.

Annual
Burden
=
#
respondents
x
burden
per
response
(
2,000
x0.25=
500
hrs)
500
hrs.
$
13.10
$
6,550
Posting
of
public
notification
by
sellers
of
motor
vehicle
refrigerants
0
0
1,000
.08
hrs
Annual
Burden
=
#
respondents
x
burden
per
response
(
1,000
x0.08=
80
hrs)
80
hrs.
$
16.61
$
1,329
TOTALS
0
0
25,013
2,100
hrs
$
33,126
RECORDKEEPING:

TOTAL
RECORDKEEPING
CAPITAL/
START
UP
BURDEN
HOURS:
0
TOTAL
RECORDKEEPING
ANNUAL
BURDEN
HOURS:
2,100
HOURS
TOTAL
RECORDKEEPING
CAPITAL/
START
UP
COSTS:
0
TOTAL
RECORDKEEPING
ANNUAL
COSTS:
$
33,126
REPORTING:

TOTAL
REPORTING
CAPITAL/
START
UP
BURDEN
HOURS:
0
HOURS
TOTAL
REPORTING
ANNUAL
BURDEN
HOURS:
765
HOURS
TOTAL
REPORTING
CAPITAL/
START
UP
COSTS:
$
0
TOTAL
REPORTING
ANNUAL
COSTS:
$
12,876
TOTAL
PUBLIC
BURDEN:

SUM
OF
TOTAL
ANNUAL
BURDEN
HOURS:
2,865
SUM
OF
TOTAL
CAPITAL/
START
UP
COSTS
AND
TOTAL
ANNUAL
COSTS:
$
46,002
