INFORMATION COLLECTION REQUEST (ICR 1617.07) FOR SERVICING OF MOTOR
VEHICLE AIR CONDITIONERS

SUPPORTING STATEMENT 

1.	Identification of Information Collection

a) 	Title:	"Servicing of Motor Vehicle Air Conditioners"

OMB Control Number:  2060-0247

EPA Number: 1617.07

b)	Short Characterization/Abstract

History.  Section 609 of the Clean Air Act Amendments of 1990 (Act)
provides general guidelines for motor vehicle air conditioning (MVAC)
refrigerant handling and MVAC servicing. It states that “no person
repairing or servicing motor vehicles for consideration may perform any
service on a motor vehicle air conditioner involving the refrigerant for
such air conditioner without properly using approved refrigerant
recovery and/or recovery and recycling equipment (hereafter referred to
as “refrigerant handling equipment”) and no such person may perform
such service unless such person has been properly trained and
certified.” In 1992, EPA developed regulations under section 609 that
were published in 57 FR 31242, and codified at 40 CFR Subpart B (§
82.30 et seq.). The information required to be collected under the
Section 609 regulations is currently approved for use through December
31, 2008. 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 October 4, 2005, announcing the intent to extend the renewal
of this Information Collection Request and requesting comment on the
renewal. Descriptions of the recordkeeping and reporting requirements
mandated by section 609 and delineated in 40 CFR 82 subpart B are
summarized below in this section. The chart located at the end of this
document displays the estimated costs of these requirements.

Approved Refrigerant Handling Equipment.  In accordance with Section
609(b)(2)(A), 40 CFR 82.36 requires that refrigerant handling equipment
be certified by EPA or independent standards testing organization.
Certification standards are particular to the type of equipment and the
refrigerant to be recovered, and must be consistent with the Society of
Automotive Engineers (SAE) standards for MVAC equipment.

 

Approved independent standards testing organizations.  Section
609(b)(2)(A) of the Act requires independent laboratory testing of
refrigerant handling equipment to be certified by EPA. The Stratospheric
Protection Division (SPD) requires independent laboratories to submit an
application that documents: the organization’s capacity to accurately
test equipment compliance with applicable standards consistent with the
SAE standards for handling refrigerant, an absence of conflict of
interest or financial benefit based on test outcomes, and an agreement
to allow EPA access to verify application information. Once an
independent laboratory has been approved by EPA, the application is kept
on file in the SPD. Two laboratories – Underwriters Laboratories Inc.
and Intertek/ETL Testing Laboratories – are currently approved to test
refrigerant handling equipment. EPA does not anticipate that any
organizations will apply to EPA in the future to become approved
independent standards testing organizations. Therefore, annual hours and
costs related to information submitted by these organizations have been
eliminated.

                                                                        
                                  

Technician training and certification.  According to Section 609(b)(4)
of the Act, automotive technicians are required to be trained and
certified in the proper use of approved refrigerant handling equipment.
Programs that perform technician training and certification activities
must apply to the SPD for approval by submitting verification that its
program meets EPA standards. The information requested is used by the
SPD to guarantee a degree of uniformity in the testing programs for
motor vehicle service technicians.

Due to rapid developments in technology, the Agency requires that each
approved technician certification program conducts periodic reviews and
updates of test material, submitting a written summary of the review and
program changes to EPA every two years (as per 40 CFR §82.40 (c)).
After the test has been approved by EPA, a hard copy remains on file
with SPD. Currently, 19 testing programs are approved by EPA to train
technicians in the proper use of refrigerant handling equipment. Five of
these programs are designed specifically for individual company’s own
employees.

Certification, reporting and recordkeeping.  To facilitate enforcement
under Section 609, EPA developed several recordkeeping requirements. All
required records must be retained on-site for a minimum of three years,
unless otherwise indicated (40 CFR §82.42 (b)).

Section 609(c) of the Act states that by January 1, 1992, no person may
service any motor vehicle air conditioner without being properly trained
and certified, nor without using properly approved refrigerant handling
equipment. To this end, 40 CFR 82.42(a) states that by January 1, 1993,
each service provider must have submitted to EPA on a one-time basis a
statement signed by the owner of the equipment or another responsible
officer that provides the name of the equipment purchaser, the address
of the service establishment where the equipment will be located, the
manufacturer name, equipment model number, date of manufacture, and
equipment serial number. The statement must also indicate 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. The information is
used by the SPD to verify compliance with Section 609 of the Act. 

Any person who owns approved refrigerant handling equipment must
maintain records of the name and address of any facility to which
refrigerant is sent. Additionally, any person who owns approved
refrigerant handling equipment must retain records demonstrating that
all persons authorized to operate the equipment are currently certified
technicians.  

Finally, any person who sells or distributes a class I or class II
refrigerant that is in a container of less than 20 pounds must verify
that the purchaser is a properly trained and certified technician,
unless the purchase of small containers is for resale only. In that
case, the seller must obtain a written statement from the purchaser that
the containers are for resale only, and must indicate the purchaser's
name and business address. When a certified technician purchases small
containers of refrigerant for servicing motor vehicles, the seller must
have a reasonable basis for believing the accuracy of the information
presented by the purchaser. In all cases, the seller must display a sign
where sales occur that states the certification requirements for
purchasers. 

2.	Need for and Use of the Collection

a)	Authority for the Collection

The information requested for all entities that service motor vehicle
air conditioning is required by Section 609(d) of the Act and 40 CFR
82.36, 82.40, 82.42. This includes certification of both approved
equipment and properly trained personnel. Section 609(b)(2)(A) and 40
CFR 82.38 require the approval of independent standards testing
organization by EPA. Automotive air conditioning technician
certification programs are referred to in Section 609(b)(4), and
applicable requirements for program certification are detailed in 40 CFR
82.40. Reporting requirements associated with the sale of small
containers for resale only are noted in Section 609(e) of the Act and 40
CFR 82.42(b)(3). The reporting requirements for the motor vehicle
recycling program are derived from Section 114 of the Act.

                        

b)	Practical Utility/Users of the Data

MVAC service establishments are required, by Section 609 of the Act, to
have purchased approved refrigerant handling equipment and to have only
properly trained and certified personnel using the equipment by January
1, 1992. They must submit certification form or statement to EPA by
January 1, 1993 certifying that the MVAC service establishment  has
acquired and is properly using, approved equipment and that each
individual authorized to use the equipment is properly trained and
certified. The Agency uses the certificates to confirm compliance with
Section 609.

i) Equipment Certification

As per 30 CFR §82.36 (a) (1), the Agency is required either to certify
refrigerant handling equipment itself or to approve independent
laboratories to test and certify equipment. In order for EPA to certify
equipment, the Agency must be provided with information that proves the
equipment’s ability to recover and/or recycle refrigerant according to
the SAE J standards adopted into the appendices at 40 CFR part 82,
subpart B. Certification standards are particular to the type of
equipment used and refrigerant being recovered. 

Since EPA does not have the capabilities to test all refrigerant
handling equipment on a national scale, the Agency relies on approved
laboratories to test equipment. Currently, Underwriters Laboratories
(UL) and Intertek/ETL Testing Laboratories (ETL) certify equipment on a
voluntary basis. The Agency established an approval system at 40 CFR
§82.38 to evaluate procedures of laboratories that may request approval
in the future. Information submitted by the laboratories must include
documentation of their capacity to accurately test equipment, an absence
of a conflict of interest or financial benefit based on test results,
and agreement to allow EPA access to verify information. The SPD uses
the information provided by independent laboratories to evaluate their
capacity to properly test refrigerant handling equipment. The Agency has
required only the submission of information that will enable it to
ensure that all approved laboratories can test equipment under Agency
standards and the adopted SAE J standards. 

ii) Technician Certification Programs

Technicians must pass a test at the completion of a certification
program in order to perform any service or repair on MVACs and in order
to use the approved equipment as stipulated in Section 609 and 40 CFR
82.34, 82.40. Technician certification programs must submit verification
to EPA of their compliance with standards set forth in 40 CFR 82.40. 
SPD uses certification program information to ensure that Agency
standards are met, and that they are at least as stringent as the SAE J
standards of the Society of Automotive Engineers.

Because of the rapidly changing nature of the motor vehicle air
conditioning market, EPA requires that technician certification programs
conduct internal reviews and update their program periodically. By
requiring a written summary of the review and any program changes to be
reported to EPA every two years, the Agency ensures the accuracy of the
information, and maintains parity among testing programs. 

iii) Refrigerant Sent Off-site

EPA requires service establishments to record the name and address of
any off-site facility which is reclaiming refrigerant, per 40 CFR
§82.42 (b)(1). This information is used to verify compliance with the
motor vehicle air conditioning recycling program.  

iv) Purchases of Small Cans

Distributors who purchase small containers of refrigerant must be
properly trained and certified according to the standards set forth in
40 CFR §82.40, unless the purchaser provides a written statement
verifying that the small containers were purchased for resale only. The
seller may keep the initial statement from a distributor and update the
file with the amounts of refrigerant purchased in the form of small
containers. These records are used to ensure that small containers of
refrigerant are not available for non-certified technicians. By
requiring only minor additions to the existing invoice procedures, the
Agency has ensured total compliance with Section 609. 

3.	Non-duplication, Consultations, and Other Collection Criteria



a)	Non-Duplication

The specific information requested by this notice is not currently
collected by any other office within EPA or any other government agency.
 

b)	Public Notice Required Prior to ICR Submission to OMB

	In compliance with the Paperwork Reduction Act of 1995, EPA will issue
a public notice in the Federal Register soliciting public comments for a
60-day period.

c)	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.

To update this ICR, information was recently obtained from six 
technician certification organizations.

d)	Effects of Less Frequent Collection

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

Verifications of applications for technician certification programs and
independent standards testing organizations 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. 

	

e)         General Guidelines

The Section 609 regulations do not exceed any of the guidelines.

f)	Confidentiality

This section does not apply because this ICR does not request
information of a confidential nature.

g)	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 / NAICS Codes

The following is a list of NAICS codes for organizations potentially
affected by the information requirements covered under this ICR. It is
meant to include any establishment that may service or maintain motor
vehicle air conditioners. 

4411	   Automobile Dealers

4413	Automotive Parts, Accessories, and Tire Stores

44711	   

45299	All Other General Merchandise Stores

811198   All Other Automotive Repair and Maintenance

Other affected groups include:

	   Independent Standards Testing Organizations

	   Organizations with Technician Certification Programs

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, certification of an appropriate MVAC
refrigerant handling device. This certification must include the name of
the purchaser of the equipment, address of the establishment where the
equipment will be located, name of equipment manufacturer, model number,
date of manufacture, and serial number. The statement must be signed by
the owner of the equipment or other responsible officer, and must
indicate 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.

Independent laboratory testing of refrigerant handling equipment is
designed to ensure that the equipment is capable of safely meeting the
standards set forth by EPA in appendices to 40 CFR 82 Subpart B. To
establish a degree of uniformity to the equipment certification
programs, EPA requires organizations to submit applications documenting:
the equipment used for equipment testing; the expertise and technical
experience of their personnel; thorough knowledge of the standards in
the appendices to 40 CFR 82 Subpart B; test procedures to be used and
the rationale for them; absence of a conflict of interest or financial
benefit based on test results; and agreement to allow EPA access to
verify information. Specific reporting requirements may include:
equipment ability to remove moisture, oil, and non-condensable gases
from refrigerant, and a list of testing equipment used.

Technician certification programs interested in certifying technicians
are required to document that their program meets EPA standards. An
acceptable program includes the following components:  adequate training
through on-the-job or on-site instructional training, or self-study; a
test that effectively covers all relevant standards dealing with the
servicing and repair of motor vehicle air conditioners, anticipated
future technological developments, the 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; a test grader who receives no benefit based on test results;
means of identifying the individual taking the test; the measures taken
at the test site to ensure that the tests are completed honestly by each
technician; individual proof of certification in the form of a
certificate or card and unique certification number. 

Certification programs are required to conduct a periodic review of
their test material and submit to EPA a written program review summary
and any material changes every two years.  	

 

Service establishments that own approved refrigerant handling equipment
and send used refrigerant off-site for recycling or reclamation must
record the facility name and address to which any refrigerant is sent.
In addition, the seller of small containers to an uncertified purchaser
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. Finally, any person who owns equipment must retain records
demonstrating that all technicians authorized to operate the equipment
are certified pursuant to the Clean Air Act. All of these records must
be kept on-site for a minimum of three years. 

ii) Respondent Activities

	All Entities That Service Motor Vehicle Air Conditioners

One-Time Equipment and User Certification Forms:

Compile documentation for a certification that states the following: 
The name of the purchaser of the equipment, address of the establishment
where the equipment will be located, name of equipment manufacturer,
model number, date of manufacture, and serial number. The statement must
be signed by the owner of the equipment or other responsible officer,
and indicate 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. Prepare
and submit completed certification to EPA.

Records of Certified Technicians:

Maintain records on-site, for a minimum of three years, demonstrating
that all equipment users are properly trained and certified.

Records of Refrigerant Sent Off-site:

Record and file the facility address to which any refrigerant is sent
for off-site reclamation or recycling. Recordkeeping is required for a
minimum of three years. 

Records of Class I or Class II Refrigerant in Small Containers Sold for
Re-Sale:

Verify that purchaser is properly trained and certified.

Compile, file, and keep for a minimum of three years written statements
from uncertified purchasers verifying their intent to only resell the
small containers of refrigerant.

	Independent Standards Testing Organizations

New Independent Standards Testing Organization Certification

Research SAE J standards on MVAC refrigerant handling equipment.

Compile test methodology, a list of required equipment, and other
information regarding the SAE standards for the application to EPA.

Prepare and submit application to EPA that documents capacity to
accurately test whether refrigerant handling equipment complies with the
applicable standards, an absence of conflict of interest or financial
benefit based on test results and an agreement to allow EPA access to
verify information to ensure that the testing program fulfills the
applicable SAE J standards, adopted in the appendices at 40 CFR part 82,
subpart B, for recycling and recovery equipment.

Substantially Identical Equipment

Substantially Identical Equipment Owners or Manufacturers

Locate information that will verify that the equipment can perform to
the applicable SAE J standards, including process flow sheets and a list
of components.

Compile supporting information and submit it to EPA.

	Technician Certification Programs

New Technician Certification Program Certification:

Compile documents and submit to EPA verification that training program
meets EPA requirements.

Technician Certification Program Review:

Conduct periodic program reviews.

Prepare and submit summary of program review to EPA every two years.

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

a)	Agency Activities

One-Time Equipment and User Certification Forms:

Review and store certification applications and supporting documents
from all entities that have purchased approved refrigerant handling
equipment.

Records of Certified Technicians:

No Agency action required.

Records of Refrigerant Sent Off-site:

No Agency action required.

Records of Refrigerant Sold for Re-Sale:

No Agency action required.

New Independent Standards Testing Organization Certification:

Review applications from independent labs that request approval to
certify refrigerant handling equipment.

New Technician Certification Program Certification:

Review applications from new technician certification programs.

Technician Certification Program Review:

Review summaries of certification program updates every two years.



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 refrigerant
handling equipment. An establishment may submit the form provided by the
manufacturer of the 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.  

Independent standards testing organizations must submit to the Agency an
application documenting their capacity to accurately test whether
refrigerant handling equipment complies with the applicable standards,
an absence of conflict of interest or financial benefit based on test
results, and an agreement to allow EPA access to verify information. The
Agency examines the submitted test procedures for their ability to meet
the SAE standards as specified in Section 609 of the Act. These
applications 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. 

Technician certification programs must submit to the Agency a
verification of their compliance with EPA regulations for review and
approval by the 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.   

The Agency has determined that periodic on-site inspection is the most
effective method to ensure compliance with Section 609. 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 that allowed small entities (i.e.,
those which performed service on fewer than 100 motor vehicle air
conditioners during the calendar year 1990) an additional year to comply
with the provisions of Section 609.

EPA expects a small number of technician certification programs and
independent 

equipment standard testing organizations to apply for approval. The
requirement to submit the program application 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 were proposed and that had not
been certified by an approved independent laboratory. This provision
will benefit small entities that may have purchased recycling or recover
equipment in a good faith effort to recover refrigerant prior to a
regulatory mandate.

EPA does not expect any new independent standards testing programs to
apply for approval.

The name and address of the refrigerant handling facility to which
refrigerant is sent by an establishment with recovery-only capabilities
is a standard part of existing recordkeeping procedures for business
transactions. The regulations regarding records maintained by persons
who sell small containers of refrigerant solely require that the
resale-only statement be added into invoicing procedures for sales to
uncertified purchasers.

d)	Collection Schedule

All entities operating at the time the regulations were introduced were
required to submit certification forms to EPA by January 1, 1993. The
certification for refrigerant handling 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 periodically to account for technological developments. A
summary of the program review and any changes must be submitted to EPA
every two years. 

6. 	Estimating the Burden and Cost of the Collection

	

a) 	Estimating Respondent Burden

	The basis of the analysis is the identification of the principal steps
involved in complying with EPA recordkeeping and reporting requirements
and the estimated burden associated with each step. The burden has been
estimated by identifying the number of times the step will be undertaken
and the number of hours required to complete each step.   REF
_Ref197863544 \h  \* MERGEFORMAT  Appendix 1  presents the estimated
annual respondent burden and costs for information collection activities
associated with Section 609 of the Act.

	Time required for completion of each activity is derived from the
estimates in the previous ICR, with several exceptions. In this ICR, the
maintenance of records of technician certification (of photocopying and
filing the technician’s certification card) is estimated to require
0.083 clerical work hours per establishment (5 minutes), which remain
unchanged from the previous ICR. Additionally, in this ICR, the one-time
equipment and user certification for compilation, preparation, and
submission is estimated to require 0.17 hours (10 minutes) per
establishment, which remain unchanged from the previous ICR. Generally,
this one-time certification is submitted by a new motor vehicle service
facility, or by first-time refrigerant handling equipment owners or
lessees, or when there’s been a change in ownership on an existing
service facility, consistent with the recordkeeping a and reporting
requirements on 40 CFR 82.42. This labor burden includes completion and
mailing of a prepared form. The form requires information on
establishment name, name of the equipment owner or lessee, address, and
telephone number, as well as equipment manufacturer, model number,
serial number, and year.

	In this ICR, 1.5 hours has been allotted per establishment to conduct
the reviews, and 0.5 hours has been allotted per establishment to
prepare and submit the summary, which are unchanged from the time
allotted in the previous ICR.

	It should be noted that minimal records need to be developed by
industry establishments, and these records can be stored as hard copies;
there is no need for the creation (or maintenance) of a database system.
Therefore, no additional hours or costs are required for these
activities.

b) 	Estimating Respondent Costs

	

i) Estimating Labor Costs

	Respondent labor costs (hourly rate plus overhead and fringe) are
estimated using data from the Bureau of Labor Statistics. Average hourly
wages are multiplied by a factor of 2.1 to reflect the estimated
additional costs for overhead and fringe. General recordkeeping tasks
are assigned to administrative assistants, whereas preparations of
applications and reports are assigned to managers. The following job
characterizations were used in   REF _Ref197859080 \h  \* MERGEFORMAT 
Table 1 :

	

General and Operations Manager: $45.74/hr x 2.1 = $96.05

Executive Secretaries and Administrative Assistants: $21.91/hr x 2.1 =
$46.01

Automotive Service Technicians and Mechanics: $17.39hr x 2.1 = $36.52

Table   SEQ Table \* ARABIC  1 . Average Hourly Establishment Labor
Costs

Managerial	Clerical	Technical

$96.05	$46.01	$36.52



ii) Estimating Capital and Operations and Maintenance Costs

	The Agency estimates that there are no capital/operations and
maintenance costs associated with the requirements of Section 609, and
therefore, with the renewal of this information collection request.

c) 	Estimating Agency Burden and Cost

The basis of this analysis is the identification of the steps involved
in implementing and operating the system. The costs associated with each
step have been estimated by identifying the number of times the step
will be undertaken, the number of hours required to complete each step,
and the total dollar cost.   REF _Ref197863572 \h  \* MERGEFORMAT 
Appendix 2  presents the estimated Agency burden hours and costs
associated with the information collection activities for this ICR.
Agency labor costs are based on the 2011 GS Salary Schedule for the
locality pay area of Washington-Baltimore-Northern Virginia,
DC-MD-PA-WV, which are multiplied by 1.6, the standard government
benefits multiplier. See   REF _Ref197792538 \h  \* MERGEFORMAT  Table 2
 for EPA estimates of average hourly labor costs for managerial and
clerical staff, whose wage estimates are based on GS 12 step 2, and GS 7
step 2 hourly rates respectively. As shown, EPA estimates that the
annual Agency burden for all activities covered in this ICR is 188.38
hours at a total cost of $6,223.98 per year.

Wage estimates are based on the following characterizations of
occupations:

GS 12 Step 2 - Managerial: $36.04/hr x 1.6 = $57.65/hr

GS 7 Step 2 – Clerical (43-4199): $19.57/hr x 1.6 = $31.31/hr

Table   SEQ Table \* ARABIC  2 . Average Hourly Agency Labor Costs

Managerial	Clerical

$57.65	$31.31



	Estimates of burden hours are based on assumptions that filing and
recording information will take very little time. Specific estimates are
detailed in Appendix 2. No additional hours or costs will be incurred
for preparation or development of a recordkeeping database. For the
establishment activities that simply require on-site recordkeeping, EPA
has no correlated burden. Similarly, for the activities currently not
applicable to any establishments, EPA has no correlated burden.

d) 	Estimating the Respondent Universe and Total Burden and Costs

	An average estimate of 180 equipment certification forms are received
and processed by EPA each month. Therefore, it is estimated that 2,200
establishments will compile and submit one-time certification forms to
EPA each year. While these certification forms were historically sent by
respondents to EPA Headquarters and then forwarded on to EPA Regional
offices, as appropriate, they are now sent directly from establishments
to EPA Regional offices.  

	The previous ICR estimated that there will be 55,000 records of
technicians maintained in establishments per year demonstrating that all
equipment users are properly trained and certified. However, based a
decrease of number of technician certification programs and on data
collected in March 2012 from 6 out of 19 technician certification
centers, it is estimated that 50,000 new MVAC technicians are certified
each year. Assuming that MVAC service establishments will hire these
newly certified technicians and maintain records demonstrating their
certification, this ICR estimates that there will be 50,000 records
regarding certified technicians using proper refrigerant handling
equipment will be maintained each year. 

	The previous ICR estimated that 5,000 establishments per year that send
refrigerant off-site for handling, assuming all establishments sent
refrigerant fro reclamation. However, because most service
establishments recycle refrigerant on-site, the number of entities that
send refrigerant off-site for recycling/reclamation is very low. The
agency estimates that 3% of the total servicing establishments currently
operating in the United States (4100), will send the refrigerant
off-site for reclamation. Therefore, 120 facilities are estimated to
keep record and file off sire facility address of refrigerant sent for
reclamation.  

	It is estimated that there are 275purchases of small class I or class
II refrigerant containers made by uncertified purchasers for resale
only. This number is reduced from the estimate of 1,370 purchases in the
previous ICR, derived from an estimate of CFC-12 vehicles on road, which
estimated about 80% reduction of the existing CFC-12 vehicle fleet
estimated in 2008. 

	There are currently two independent standards testing organizations,
and it is unlikely that any others will apply for approval.
Additionally, no significantly identical equipment is expected to be
submitted to the Agency for review.	

	There are currently 19 technician certification programs that must
submit program reviews every other year. It is estimated that EPA will
review 1 program per year.  . 

e) 	Bottom Line Burden Hours and Cost Tables

i) Respondent Tally

	

	Total Annual Burden Hours: 4,522.75 hrs.

	Total Annual Cost: $208,307.40

	

ii) The Agency Tally

	Total Annual Burden Hours: 188.38 hrs.

	Total Annual Cost: $6,223.98

iii) Variations in the Annual Bottom Line

	Changes to the annual bottom line are due to a more accurate estimate
in hourly wages and a shift in the time requirements and number of
reporting establishments. See below for a more complete discussion of
these changes.

f) 	Reasons for Change in Burden

	The previously approved ICR’s supporting statement described an
estimated burden or estimated a total annual respondent burden of
2,865 hours. By comparison, this ICR estimates a total
annual burden of 4,522.75 hours. Hence, there is a decrease of
2,177.25 hours and a decrease of $54,637.07 since the previously
approved ICR. This change can be attributed to the following factors.

In the previous ICR, respondent hourly wages were $47.73, $18.83, and
$17.53 for managers, administrative assistants, and technicians,
respectively.  In this ICR, to increase accuracy, wages have been
estimated based on the most current Bureau of Labor Statistics (2011)
national averages for managers, administrative assistants, and
technicians to be $45.74, $21.91, and $17.39, respectively. These
baseline wages were then multiplied by a factor of 2.1 to incorporate
overhead and fringe costs into the hourly cost estimate, resulting in
estimated hourly costs of $96.05, $46.01, and $36.52.

The number of technician certification programs decreased from 24 to 19
since the previous ICR because several programs went out of business.

In this ICR, time requirements for each EPA activity related to
establishments’ report submissions have been estimated. Additionally,
wages for clerical and managerial EPA work has been estimated based on
the 2011 GS Salary Schedule for the locality pay area of
Washington-Baltimore-Northern Virginia, DC-MD-PA-WV. These baseline
wages were multiplied by a factor of 1.6, the standard government
benefits multiplier, to arrive at an accurate hourly cost. 

The previous ICR estimated that 55,000 new technician certifications
would be recorded and filed by owners of approved refrigerant handling
equipment each year. However, this ICR estimates the number to be
50,000.  Based on data collected in March 20123 from some technician
certification centers, it is estimated that 50,000 new MVAC technicians
are certified each year. The time allotted to this activity in the last
ICR was 0.083 hours per certification; no change in time allotted per
certification is expected on this ICR. 0.083 hours.

The previous ICR estimated that equipment and user certification form
compilation and submission would require 0.17 hours per establishment.
That estimate remains unchanged in this ICR.

In 2008 it was estimated that there would be 1,370 purchases of small
containers of class I and class II refrigerant for resale only by
uncertified purchasers. It is estimated that at the time (in 2008),
there were an estimated 3 million R-12 MVACs on the road. Today, it is
estimated that there are only 600 thousand R-12 MVACs on the road, or
roughly 80% less than there were in 2008. Therefore, to account for the
decreased market for small containers of CFC-12 refrigerant, this ICR
estimates that the number of purchases for resale only by uncertified
purchasers of small cans will be 80% less than in 2008, or 275
purchases.

Finally, the substantially identical equipment approval process is no
longer

applicable for CFC-12 and HFC-134a refrigerant handling equipment
manufactured prior proposal of refrigerant equipment handling
regulations. This portion of Section 609(b)(2)(B) of the Act and 40 CFR
82.36(b) allowed for equipment that was purchased before the proposal of
the regulations to be approved by EPA if it was substantially identical
to equipment that had been certified by the EPA or approved independent
laboratory. The substantially identical equipment regulation only
relates to CFC-12 recovery and recycling equipment initially purchased
before September 4, 1991; CFC-12 recovery-only equipment initially
purchased before April 22, 1992; HFC-134a recovery and recycling, or
recovery-only equipment initially purchased before March 6, 1996;
equipment that recovers but does not recycle any single, specific
refrigerant other than CFC-12 or HFC-134a that was initially purchased
before March 6,1996; or equipment that recovers and recycles HFC-134a
and CFC-12 refrigerant using common circuitry that was initially
purchased before March 6, 1996. Because the average lifetime of such
equipment is roughly 7 years, all such equipment is obsolete today.
Therefore, documentation requirements related to this section for CFC-12
and HFC-134a have been removed from this ICR. 

g) 	Burden Statement

The industry reporting burden for this collection is estimated in
Appendix 1. It includes the time needed to comply with EPA's
certification requirements and Agency reviews. The total respondent
burden is estimated at 4,522.75 hours.

The Agency burden for this collection is estimated in Appendix 2. It
includes the time needed to record, review, and file all certification
applications and related materials. The total Agency burden is estimated
at 188.38 hours.

	Send comments on the Agency’s need for this information, the accuracy
of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of automated
collection techniques to the Director, Collection Strategies Division,
U.S. Environmental Protection Agency (2137), 1200 Pennsylvania Avenue,
N.W., Washington, D.C. 20460; and 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. Include the
EPA ICR number and OMB control number in any correspondence.Appendix 1

Industry Reporting Burden

INFORMATION COLLECTION ACTIVITY	Frequency/ Number of Responses per Year
Labor Hours per Response	Costs



General and Operations Manager 

$96.05 	Automotive Service Technicians and Mechanics

$36.52 	Executive Secretaries and Administrative Assistants

46.01	Total Labor Hours 	Average Total Hours	 Total Labor Costs per
Response	Average Cost/Year

ENTITIES THAT SERVICE MVACs









One-Time Equipment and User Certification Forms









Compile, Prepare, and Submit Certification	2200	-

0.17	0.17	374	$ 7.82	$ 17,207.74

Records of Technician Certification









Maintain Records On-Site of Certification of Technicians	50,000

	0.08	0.08	4000	$ 3.68	$ 184.040.00

Records of CFC-12 Refrigerant Sent Off-Site









Record and file off-site facility address	120	-	0.25

0.25	30	$ 9.13	$ 1,095.60

Records of CFC-12 Refrigerant Sold









Verify certification of purchaser	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

Obtain and file written statements from purchaser verifying intent to
only resell small containers	275

	0.25	0.25	68.75	$ 11.50	$ 3163.20

Subtotal	52700



0.75	4472.75	$ 32.13	$ 205,506.50

INDEPENDENT STANDARDS TESTING ORGANIZATIONS









New Independent Standards Testing Organization Certification









Research SAE standards on MVAC recovery equipment	-	N/A	N/A	N/A	N/A	N/A
N/A	N/A

Compile information for application to EPA	-	N/A	N/A	N/A	N/A	N/A	N/A	N/A

Prepare and submit application to EPA	-	N/A	N/A	N/A	N/A	N/A	N/A	N/A

Subtotal

N/A	N/A	N/A	N/A	N/A	N/A	N/A

TECHNICIAN CERTIFICATION PROGRAMS









New Technician Certification Program Certification









Compile documents and submit to EPA for verification of program	1	N/A
N/A	40	40	40	$ 1,840.40	$ 1,840.40

Technician Certification Program Review









Conduct periodic program reviews	10	0.5

	0.5	5	$ 48.03	$ 480.25

Prepare and Submit summary of program review to EPA every two years	10
0.50

	0.50	5	$ 48.03	$ 480.25

Subtotal	21	2.00

-	2.00	50	$ 1936.46	$ 2,800.90

ANNUAL TOTAL 	N/A



	4522.75	$ 1968.59	$ 208,307.40

Appendix 2

Agency Reporting Burden

INFORMATION COLLECTION ACTIVITY	Frequency/ Number of Responses per Year
Labor Hours per Response	 Costs 



Manager	Clerical	Total Labor Hours 	Average Total Hours	  Total Labor
Costs per Response 	 Average Cost/Year  



$57.65 	$31.31 





One-Time Equipment and User Certification Forms







	Review and file applications	2,200

0.08	0.08	176	$ 2.50	$ 5,510.56

New Independent Standards Testing Organization Certification







	Review applications from testing organizations who request to certify
equipment	0

	-	-	$ -	$ -

New Technician Certification Program Certification







	Review applications from new technician certification programs	1	10

10	10	$ 576.50

	$ 576.50

Technician Certification Program Review







	Review summaries of certification program updates every two years	9.5
0.25

0.25	2.375	$ 14.41	$ 136.90

Annual Total



	188.38	$ 593.41	$ 6,223.98



 Labor rates were retrieved from the “May 2011 National
Industry-Specific Occupational Employment and Wage Estimates” for the
General and Operations Manager (11-1021), Executive Secretaries and
Administrative Assistants (43-6011), and Automotive Service Technicians
and Mechanics (49-3023) provided by the U.S. Bureau of Labor Statistics
at,   HYPERLINK "http://www.bls.gov/oes/2011/may/oes_nat.htm#43-0000" 
http://www.bls.gov/oes/2011/may/oes_nat.htm#43-0000 . 

 Labor rates were retrieved from the “May 2011 National
Industry-Specific Occupational Employment and Wage Estimates” for the
Federal Executive Branch (NAICS Code 999100) provided by the U.S. Bureau
of Labor Statistics at,
http://www.bls.gov/oes/current/naics4_999100.htm.

 BLS, 2011 

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