SUPPORTING
STATEMENT
FOR
STANDARD
FORM
83­
1
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
ENFORCEMENT
POLICY
REGARDING
THE
SALE
AND
USE
OF
AFTERMARKET
CATALYTIC
CONVERTERS
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Enforcement
Policy
Regarding
the
Sale
and
Use
of
Aftermarket
Catalytic
Converters.
51
FR
28114­
28119,
28133
(
Aug.
5,
1986);
52
FR
42144
(
Nov.
3,
1987).

OMB
No.
2060­
0135;
EPA
ICR
No.
1292.06.

1(
b)
Short
Characterization
The
aftermarket
catalytic
converter
policy
(
51
FR
28114­
28119,
28113
(
Aug.
5,
1986);
52
FR
42144
(
Nov.
3,
1987))
allows
aftermarket
automobile
catalytic
converter
manufacturers
and
reconditioners
to
compete
with
the
automobile
manufacturers
for
the
aftermarket
catalytic
converter
replacement
market.
Without
this
policy,
it
would
be
illegal,
under
section
203
of
the
Clean
Air
Act,
42
U.
S.
C.
§
7522,
to
sell
or
install
aftermarket
catalytic
converters
that
do
not
conform
exactly
to
the
automobile
manufacturers'
original
equipment
(
OE)
versions
of
these
parts.
The
policy
also
makes
it
possible
for
automobile
repair
shops,
which
are
often
small
businesses,
to
take
on
a
significant
share
of
the
aftermarket
catalyst
replacement
market.
In
doing
so,
consumers
are
able
to
purchase
replacement
catalytic
converters
(
converters)
at
a
much
lower
price
than
they
would
pay
for
an
OE
converter.
This
helps
to
ensure
that
vehicles
will
not
create
excessive
air
pollution
because
motorists
are
more
likely
to
replace
damaged
catalytic
converters
if
they
cost
much
less
than
OE
converters
(
cost
savings
resulting
from
the
policy
are
estimated
to
be
about
$
630,000,000).

However,
to
ensure
that
air
quality
will
not
be
compromised,
it
was
necessary
to
set
standards
for
aftermarket
catalytic
converters,
both
for
performance
and
durability.
It
was
also
necessary
to
ensure
that
appropriate
applications
are
installed
on
vehicles
(
i.
e.,
the
converter
has
to
be
of
a
type
and
size
appropriate
for
the
vehicle
application).
To
these
ends,
the
following
recordkeeping
and
reporting
requirements
exist
for
aftermarket
converter
manufacturers,
reconditioners
and
installers:

Manufacturers:
On
a
one­
time
basis
for
each
type
or
line
of
converter
manufactured:
Information
identifying
the
supplier,
and
information
regarding
the
physical
specifications
of
each
catalytic
converter
line
produced,
and
information
regarding
pre­
production
testing
of
the
converters
that
show
they
meet
standards
for
certain
specified
vehicle
applications
(
a
single
converter
line
can
be
used
on
a
large
number
of
vehicle
applications).
Once
production
has
begun
the
manufacturer
2
must
submit
to
EPA
on
a
semi­
annual
basis:
the
number
of
each
type
of
catalyst
manufactured
and
a
summary
of
information
contained
on
warranty
cards
or,
at
the
option
of
the
respondent,
copies
of
warranty
cards
for
all
converters
sold.

Reconditioners:
On
a
one­
time
basis:
Identity
of
company
and
a
description
of
the
test
bench
used
for
testing
used
catalytic
converters
and
intended
vehicle
application(
s)
for
each
converter
type.
On
a
semi­
annual
basis,
names
and
addresses
of
distributors
along
with
the
number
of
each
type
of
converter
sold
to
each
distributor.
All
used
converters
must
be
tested
individually
to
ensure
they
are
still
functional.

Installers
of
aftermarket
converters
:
Installers
have
no
reporting
requirements.
They
simply
fill
out
the
warranty
card
and
hand
it
to
the
retail
customer.
They
must
also
include
a
brief
statement
with
each
invoice
stating
the
need
for
replacing
the
original
converter.
They
also
tag
each
removed
converter
with
a
reference
to
the
invoice
for
repair.
The
invoices
are
required
to
be
kept
for
6
months.
The
tagged
converters
are
required
to
be
kept
for
15
days.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Section
203(
a)(
3)
of
the
Clean
Air
Act
(
Act)
prohibits
removal
or
rendering
inoperative
of
vehicle
emission
control
equipment
by
commercial
service
establishments
or
any
other
person.
It
also
prohibits
the
causing
of
such
acts.
It
also
prohibits
the
manufacture,
sale
or
installation
of
devices
that
defeat
the
emission
control
components
or
design
elements.
The
catalytic
converter
is
the
major
emission
control
device
used
by
motor
vehicle
manufacturers.
Oxidation
(
two­
way)
catalytic
converters
reduce
hydrocarbons
and
carbon
monoxide
emissions,
while
oxidation­
reduction
(
three­
way)
converters
(
widely
used
since
1981)
additionally
reduce
oxides
of
nitrogen
emissions.
If
a
vehicle
is
properly
maintained,
the
converter
frequently
will
not
require
replacement
for
the
life
of
the
vehicle.
However,
converters
sometimes
need
replacement
that
is
not
covered
by
the
automobile
manufacturer
emission
controls
warranty,
and
therefore
any
replacement
cost
is
paid
for
by
the
vehicle
owner.

The
U.
S.
Environmental
Protection
Agency
(
EPA)
has
promoted
vehicle
emissions
inspection
programs
which
require
converter
replacement
where
missing
or
non­
functioning
converters
are
discovered.
The
EPA
believes
that
the
success
of
State
and
local
government
programs
of
this
type
depends,
in
part,
on
the
availability
and
cost
of
replacement
converters.
The
average
cost
of
a
new
original
equipment
manufacturer
(
OE)
converter
is
approximately
$
500­
$
600
installed.
This
high
cost
severely
limited
their
installation.
This
enforcement
policy
allows
the
sale
of
low­
cost
effective
alternatives
to
the
new
OE
converters.
For
the
aftermarket
converter
industry,
including
the
installers,
this
is
a
multimillion
dollar
industry.
Over
2,000,000
aftermarket
converters
are
installed
each
year.

The
popularity
of
these
low­
cost
replacement
converters
and
the
3
need
to
ensure
air
quality
benefits
while
promoting
local
tampering
inspection
programs
have
led
the
Agency
to
implement
this
policy
for
the
manufacture,
sale,
and
installation
of
new
non­
OE
and
used
OE
converters.
Prior
to
the
implementation
of
the
policy,
aftermarket
converter
manufacturers
and
reconditioners
were
frequently
selling
catalysts
that
had
little,
if
any,
efficacy.
Manufacturers
who
were
attempting
to
make
a
quality
product
were
not
able
to
compete
on
a
level
playing
field
because
muffler
shops
could
purchase
poor
quality
converters
for
half
the
price
of
better
aftermarket
converters
and
undersell
the
competition.
The
manufacturer
recordkeeping
requirements
help
ensure
that
proper
equipment
is
manufactured
and
distributed
to
installers
and
helps
ensure
proper
retail
level
installation
of
converters.

The
installer
requirements
exist
to
enable
EPA
to
monitor
whether
correct
applications
are
made
at
the
retail
level
and
whether
OE
converters
are
being
replaced
with
aftermarket
converters
only
in
appropriate
circumstances
(
e.
g.,
the
original
equipment
converter
should
not
be
replaced
with
an
aftermarket
converter
while
the
vehicle
is
still
under
its
emissions
warranty).
A
strong
incentive
exists
for
cheating;
for
example
installing
a
used,
untested
converter
would
cost
less
than
half
the
price
of
a
properly
tested
converter.

These
are
important
requirements.
An
improper
application
(
e.
g.,
a
2­
way
converter
on
a
vehicle
that
needs
a
3­
way
converter)
will
result
in
much
higher
emissions
of
harmful
pollutants
than
a
proper
application
would.
Likewise,
replacement
of
the
original
converter
when
the
repair
is
not
needed
can
result
in
an
increase
in
emissions
since
working
OE
converters
are
more
efficient
than
aftermarket
converters.

2(
b)
Practical
Utility/
Users
of
the
Data
USE
The
collection
of
information
is
necessary
for
the
proper
performance
of
the
functions
of
the
Agency,
including
that
the
information
collected
will
have
practical
utility.
Without
these
requirements,
enforcement
would
be
nearly
impossible.
Neither
EPA
nor
a
converter
reconditioners
can
determine
whether
a
used
converter
is
effective
by
conducting
a
visual
inspection
of
the
converter.
The
efficacy
of
new
aftermarket
converters
for
particular
vehicle
applications
cannot
be
determined
without
prototype
testing
and
information
on
specifications.

All
testing
is
to
be
conducted
by
the
manufacturer
or
reconditioners,
and
therefore
the
Agency
believes
that
it
is
important
that
it
have
access
to
testing
records.
A
record
of
the
names
and
addresses
of
dealers
and
distributors,
as
is
required
in
the
policy,
allows
for
prompt
notification
of
these
parties
in
the
event
of
such
an
enforcement
action.

The
primary
use
of
the
sales
and
warranty
card
information
is
for
direct
compliance
action.
Warranty
cards
often
reveal
direct
evidence
of
misapplication
or
defect
warranty
violations.
Sales
information
from
reconditioners
provides
an
indirect
way
to
make
sure
that
4
production
is
not
exceeding
the
capacity
of
the
test
stand,
and
provides
the
Agency
with
a
list
of
distributor
or
retail
facilities
for
enforcement
audits
and
testing.

The
installer
requirements
are
needed
to
assure
installation
of
appropriate
applications
and
to
assure
that
converters
are
only
replaced
when
necessary.
Some
repair
shops
could
gain
an
unfair
advantage
if
they
were
to
install
cheaper
2­
way
converters
on
vehicles
requiring
3­
way
converters.
Repair
shops
could
also
improperly
benefit,
at
cost
to
both
the
consumer
and
ambient
air
quality,
if
OEM
converters
are
replaced
when
they
are
still
functional
or
when
they
are
still
within
the
warranty
period.

The
requirements
also
facilitate
knowledge
on
the
part
of
the
installers
of
aftermarket
converters
and
of
the
driving
public
that
the
converters
they
are
using
are
appropriate
and
effective
and
that
no
potential
liability
should
exist
for
the
installer
so
long
as
the
appropriate
converter
is
installed
on
each
vehicle.

USERS
Air
Enforcement
Division,
Office
of
Regulatory
Enforcement,
Office
of
Enforcement
and
Compliance
Assurance,
U.
S.
EPA.
As
noted
above,
the
requirements
also
assist
industry
by
assuring
a
level
playing
field
and
by
ensuring
installers
and
their
customers
that
the
converter
to
be
installed
is
effective
and
appropriate
for
the
vehicle
(
e.
g.,
3­
way
converter
of
proper
capacity
on
vehicle
that
needs
3­
way).

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
collection
is
not
unnecessarily
duplicative
of
information
otherwise
reasonably
accessible
to
the
Agency.
The
required
warranty
provisions
and
the
manufacturer
reports
and
test
records
are
the
only
records
of
their
kind
available
to
document
the
information
needed
to
determine
compliance.
The
information
can
be
in
a
variety
of
formats
and
the
manufacturers'
warranty
card
information
reporting
can
be
electronic
or
the
manufacturer
can
submit
the
actual
warranty
cards.
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act,
a
public
comment
period
of
60
days
was
announced
in
the
Federal
Register
at
67
FR
319­
20
(
January
3,
2002)
regarding
this
proposed
renewal
ICR.
Formal
comments
were
received
from
Douglas
L.
Greenhaus
of
the
National
Automobile
Dealers
Association
of
McLean,
VA.
Mr.
Greenhaus
reiterated
earlier
objections
to
the
Policy
relating
to
the
recordkeeping/
paperwork
requirements
of
the
Policy,
the
perceived
failure
of
the
Policy
to
accurately
reflect
the
plain
language
requirements
of
the
CAA,
inaccurate
estimates
of
aftermarket
catalysts
subject
to
the
Policy,
as
well
as
the
numbers
of
onboard
diagnostics
relating
to
converter
replacements.
Mr.
Greenhaus
also
stated
that
representations
of
regulatory
compliance
burden
times
required
of
converter
installers
were
unrealistically
low.
5
The
ICR
estimated
burdens
and
costs
that
are
being
submitted
to
OMB
for
this
renewal
have
been
revised
and
updated
to
reflect
wage
and
inflation
increases,
as
well
as
estimated
current
workloads
and
corresponding
burden
times
for
installers,
reconditioners
and
manufacturers.
An
additional
estimate
has
been
continued
in
this
ICR
regarding
amortized
startup
costs
for
new
aftermarket
converter
installation
businesses.
A
second
Federal
Register
notice
is
being
published
announcing
the
submission
of
this
Policy
to
OMB
for
approval.

3(
c)
Consultations
For
this
ICR,
EPA
has
contacted
various
affected
industry
respondents
for
information
regarding
burdens
and
costs.
Following
is
a
list
of
non­
EPA
contacts,
by
name,
phone
number
and
affiliation:

1.
Hans
Borneby,
Maremont
Corporation,
865.458.4681.
2.
George
Schafer,
Eastern
manufacturing,
Inc.,
800­
533­
7199.
3.
Pat
Haynes,
Tenneco
automotive,
517.796.6744.
4.
Dave
Miller,
Miller
Catalyzer,
510.732.0622.
5.
Jerry
and
Cecil
Brown,
Brown
Recycling,
800.367.9271.
6.
Gordon
Badgett,
Smith
Brothers
Associated,
417.345.4393.
7.
Mike
Probs,
Mr.
Muffler,
Amarillo,
TX,
806.463.1118.
8.
Dan,
Midas
Muffler,
Arvada,
CO,
303.425.9784
9.
Hake
Woodard,
Am
Phil
Products,
540.236.6969
10.
Douglas
Greenhaus,
National
Auto
Dealers
Assn.,
703.827.6869
3(
d)
Effects
of
Less
Frequent
Collection
The
information
requested
from
the
manufacturers
would
normally
by
kept
as
part
of
their
records,
and
should
not
constitute
a
significant
burden
to
maintain.
Additionally,
the
information
requested
is
the
minimum
considered
necessary
to
adequately
monitor
the
aftermarket
converter
market
and
properly
enforce
the
policy.
It
should
be
noted
that
the
manufacturers
and
reconditioners
are
voluntarily
accepting
recordkeeping
burdens
as
a
condition
of
EPA
not
bringing
actions
for
violation
of
section
203
of
the
Clean
Air
Act.
EPA
is
willing
to
allow
the
sale
of
aftermarket
converters
not
certified
to
meet
OE
standards
only
if
it
can
insure
that
aftermarket
converters
meet
the
less
strict
standards
of
the
policy
and
that
they
are
properly
installed.

The
product
development
information
requested
is
only
collected
when
a
new
product
line
is
introduced
by
an
aftermarket
converter
manufacturer.
Less
frequent
collection
of
test
results
would
allow
some
converters
to
reach
the
market
without
proof
of
sufficient
emission
testing
to
verify
their
effectiveness.
Semi­
annual
reports
of
production
or
sales
information
are
needed
to
closely
monitor
the
proper
installation
of
the
converters,
and
enhances
timely
enforcement
actions
taken
by
the
Agency.
Test
data
on
used
converters
cannot
be
taken
on
less
than
every
converter
that
is
recycled,
since
the
condition
of
the
used
converters
varies
widely
because
of
prior
use
history.

No
reporting
is
required
for
installers.
The
recordkeeping
must
accompany
installation
since
there
is
no
way
to
collect
the
6
information
afterward.

3(
e)
General
Guidelines
The
collection
is
in
compliance
with
OMB
guidelines
except
that
new
aftermarket
converter
manufacturers
are
required
to
keep
warranty
cards
for
5
years.
Because
the
warranty
period
for
the
converters
is
5
years,
this
length
of
time
is
necessary.
This
requirement
is
also
in
line
with
the
applicable
statute
of
limitations.
EPA
has
not
received
negative
comment
regarding
this
maintenance
period
from
the
industry.

3(
f)
Confidentiality
Confidentiality
protections
are
provided
pursuant
to
40
C.
F.
R.
§
2.201
et
seq.

3(
g)
Sensitive
Questions
This
section
is
inapplicable
to
this
ICR.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
Respondents
include
the
manufacturers
of
new
aftermarket
automobile
catalytic
converters
and
reconditioners
of
used
aftermarket
converters.
The
SIC
code
is
346.
The
other
respondents
are
automobile
exhaust
repair
facilities.
Their
SIC
code
is
7533.

4(
b)
Information
Requested
(
i)
Data
Items,
Including
Recordkeeping
Requirements
This
ICR
indicates
for
each
recordkeeping
requirement
the
length
of
time
persons
are
required
to
maintain
the
records
specified.

One­
time
Reporting
:

Parties
required
to
submit
converter
testing
information
include
all
manufacturers
of
new
non­
OEM
converters
and
reconditioners
of
used
OEM
converters.

Manufacturers
of
New
Converters­­
Specifications
Information
:

1)
Converter
supplier
and
address.

2)
General
type
of
converter
(
e.
g.,
oxidation,
reduction,
threeway
etc.).

3)
Number
of
each
type
of
catalyst
used
per
can
(
number
of
individual
monoliths
containing
catalytic
metals
in
each
unit).

4)
Substrate
(
e.
g.,
monolithic,
pelleted)
­
give
configuration
construction
technique
(
e.
g.,
extruded,
laid­
up,
formed,
etc.),
composition,
supplier
and
address,
composition
of
active
constituents
7
in
substrate
(
grams
or
troy
ounces);
for
monolithic
substrates,
give
number
of
cells
per
square
inch
of
frontal
area,
design
tolerances,
and
nominal
cell
wall
thickness
(
in
mils);
for
pelleted
substrates,
specify
pellet
shape
and
dimensions,
pellet
bulk
density,
the
use
of
more
than
one
type
of
pellet
(
e.
g.,
Rh,
or
Pt/
Pd),
any
geometrical
distribution
of
pellets,
and
(
if
this
is
controlled
in
production)
the
mean
impregnation
depth
(
in
microns)
of
active
materials
with
production
tolerances.

5)
Washcoat
­
give
composition
of
active
constituents,
and
total
active
material
loading
(
grams
or
troy
ounces)
in
washcoat.

6)
Active
material
­
give
composition
of
active
constituents,
loading
of
each
active
material
including
design
tolerances,
and
total
active
material
loading
including
design
tolerances
(
grams
or
troyounces

7)
Container
­
specify
dimensions,
volume,
materials
used,
technique
of
containment
and
restraint,
method
of
constructing
container,
canner
(
if
different
from
catalyst
supplier),
and
insulation
and
shielding
(
converter
and/
or
vehicle).

8)
Physical
description
­
dimensions
(
e.
g.,
length,
width,
height,
etc.),
weight
(
lbs.),
volume
including
design
tolerances,
active
surface
area
(
BET),
and
total
active
surface
area
including
design
tolerances.

New
converter
manufacturers
Prototype
Testing
:

1)
Year,
make,
and
model
of
vehicles
tested.

2)
Method
of
mileage
accumulation.

3)
Name
and
address
of
testing
facility.

4)
Summary
of
conversion
efficiency
test
results.

5)
Intended
vehicle
applications
for
each
converter
type
tested.

Reconditioners
of
Catalytic
Converters­­
Information
on
Test
Bench:

1)
Name
and
address
of
testing
facility.

2)
Description
of
facilities
used
for
testing.

3)
Intended
vehicle
applications
for
each
converter
type.

Periodic
Reporting
:

Manufacturers:

Once
production
has
begun,
the
manufacturers
must
submit
to
EPA
the
following
information
on
a
semi­
annual
basis:

1)
The
number
of
each
type
of
converter
manufactured.
8
2)
A
summary
of
the
information
contained
on
the
warranty
cards
received,
or
copies
of
the
actual
warranty
cards.

Reconditioners:

Submit
names
and
addresses
of
the
persons
or
companies
to
whom
the
remanufacturer
distributes,
along
with
the
number
of
each
type
of
converter
sold
to
each.
This
information
is
reported
on
a
semi­
annual
basis.

Recordkeeping
by
Manufacturers
of
New
Aftermarket
Converters:

The
period
of
record
retention
for
new
aftermarket
converter
manufacturers
for
warranty
cards
is
5
years.

Recordkeeping
by
Installers
:

There
is
no
reporting.
Fill
out
warranty
card
if
new
aftermarket
converter,
or
provide
card
to
vehicle
owner
for
completion
of
applicable
sections
and
submittal
to
manufacturer.
State
reason
for
replacement
on
invoice.
Maintain
invoice
for
6
months.
Tag
replaced
converter
for
15
days.

(
ii)
Respondent
Activities
The
information
collection
is
to
be
implemented
in
ways
consistent
and
compatible,
to
the
maximum
extent
practicable,
with
the
existing
reporting
and
recordkeeping
practices
of
those
who
are
to
respond.

"*"
indicates
an
item
is
a
customary
and
usual
business
practice
(
CBP),
or
is
partially
CBP.

"
N/
A"
indicates
this
was
a
one­
time
cost
that
has
already
been
absorbed
under
start­
up
costs
associated
with
the
policy
when
it
was
promulgated
or
is
otherwise
not
applicable.
NOTE:
There
have
been
gains,
mergers
and
losses
of
new
aftermarket
catalytic
converter
manufacturers
since
the
last
ICR.
The
overall
population
appears
to
be
constant
at
12.

A.
New
Aftermarket
Catalytic
Converter
Manufacturers:

A.
1.
Provide
Information
Re
Specifications
and
Applications
and
Information
re
Test
Results
for
New
Product
Lines
N/
A(
1)
Reviewing
instructions;
(
2)
Developing,
acquiring,
installing
and
utilizing
("
DAIU")
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information;
(
3)
DAIU
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information;
N/
A(
4)
DAIU
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
9
collection
of
information;
(
7)
Searching
data
sources;
(
8)
Completing
&
reviewing
the
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
the
information.

This
requirement
is
a
one­
time
burden
that
only
applies
to
new
product
lines.
It
has
already
been
accomplished
for
all
existing
product
lines,
many
of
which
are
likely
to
be
usable
for
many
years
to
come.
ICR
assumes
each
manufacturer
develops
and
tests
one
new
line
per
year.

A.
2.
Testing
for
Each
New
Product
Line
N/
A(
1)
Reviewing
Instructions;
(
2)
DAIU
technology
and
systems
for
collecting,
validating
and
verifying
information;
(
3)
DAIU
technology
and
systems
for
processing
and
maintaining
information;
N/
A(
4)
DAIU
technology
and
systems
for
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
7)
Searching
data
sources;
(
8)
Completing
&
reviewing
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
the
information.

This
requirement
is
a
one­
time
burden
that
only
applies
to
new
product
lines.

A.
3.
Semi­
Annual
Reports
re
Manufacturing
and
Submittal
of
Warranty
Cards
and
Maintain
Warranty
Cards
N/
A(
1)
Reviewing
instructions;
(
2)
DAIU
technology
and
systems
for
collecting,
validating
and
verifying
information;
*(
3)
DAIU
technology
and
systems
for
processing
and
maintaining
information;
N/
A(
4)
DAIU
technology
and
systems
for
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
7)
Searching
data
sources;
(
8)
Completing
&
reviewing
the
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
information.

B.
Used
Catalytic
Converter
Reconditioners:

B.
1.
Submit
Test
Facility
Information
10
N/
A(
1)
Reviewing
instructions;
(
2)
DAIU
technology
and
systems
for
collecting,
validating
and
verifying
information;
(
3)
DAIU
technology
and
systems
for
processing
and
maintaining
information;
(
4)
DAIU
technology
and
systems
for
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
7)
Searching
data
sources;
(
8)
Completing
&
reviewing
the
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
the
information.

This
is
a
one­
time
burden
which
has
already
been
absorbed
by
ongoing
facilities
and
we
know
of
no
new
facilities.

B.
2.
Perform
Efficiency
Test
on
Each
Used
Converter
N/
A(
1)
Reviewing
instructions;
(
2)
DAIU
technology
and
systems
for
collecting,
validating
and
verifying
information;
(
3)
DAIU
technology
and
systems
for
processing
and
maintaining
information;
N/
A(
4)
DAIU
technology
and
systems
for
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
7)
Searching
data
sources;
(
8)
Completing
&
reviewing
the
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
the
information.

B.
3.
Semi­
Annual
Report
Regarding
Distribution
of
Products
N/
A(
1)
Reviewing
instructions;
(
2)
DAIU
technology
and
systems
for
collecting,
validating
and
verifying
information;
(
3)
DAIU
technology
and
systems
for
processing
and
maintaining
information;
N/
A(
4)
DAIU
technology
and
systems
for
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
7)
Searching
data
sources;
(
8)
Completing
&
reviewing
the
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
the
information.

C.
Catalytic
Converter
Installers
C.
1.
Fill
Out
Warranty
Card
(
For
New
Aftermarket
Converters
11
Only),
State
Reason
for
Replacement
on
Invoice
and
Tag
Removed
Converter
N/
A(
1)
Reviewing
instructions;
*(
2)
DAIU
technology
and
systems
for
collecting,
validating
and
verifying
information;
*(
3)
DAIU
technology
and
systems
for
processing
and
maintaining
information;
N/
A(
4)
DAIU
technology
and
systems
for
disclosing
and
providing
information;
N/
A(
5)
Adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
N/
A(
6)
Training
personnel
to
be
able
to
respond
to
a
collection
of
information;
*(
7)
Searching
data
sources;
*(
8)
Completing
&
reviewing
the
collection
of
information;
(
9)
Transmitting
or
otherwise
disclosing
the
information.
Most
of
the
recordkeeping
and
maintenance
is
CBP;
Filling
out
and
maintaining
invoices
is
CBP.

This
ICR
also
makes
an
estimate
for
startup
burdens
and
costs
for
new
businesses.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
information
collection
has
been
developed
by
an
office
within
EPA
(
OECA)
that
has
planned
and
allocated
resources
for
the
efficient
and
effective
management
and
use
of
the
information
to
be
collected,
including
the
processing
of
the
information
in
a
manner
which
shall
enhance,
where
appropriate,
the
utility
of
the
information
to
agencies
and
the
public.

EPA
engages
in
the
following
activities
in
regard
to
the
information
collection.

­­
Review
reports,

­­
Inspections
or
audits
as
appropriate,

­­
Enforcement
actions
where
appropriate.

5(
b)
Collection
Methodology
and
Management
New
aftermarket
catalytic
converter
manufacturers
collect
sales
data
and
warranty
cards
submitted
to
them
by
retail
customers
who
have
had
converters
installed,
or
directly
from
the
installers
themselves.
This
is
a
customary
business
practice
for
many
businesses.
The
new
aftermarket
converter
manufacturers
then
send
EPA
manufacturing
information
(
types
of
converters
and
how
many
sold)
and
either
a
computerized
list
summarizing
converter
installations
or
copies
of
the
actual
warranty
cards,
at
their
option.
Cards
must
be
kept
5
years
because
that
is
the
length
of
the
warranty
period.
Since
warranties
are
not
required
on
reconditioned
converters,
the
converter
12
reconditioners
just
give
information
regarding
to
whom
they
sold
reconditioned
converters,
how
many
were
sold,
and
what
types
were
sold.
For
both
types
of
aftermarket
converters,
these
reports
are
submitted
semi­
annually.

No
other
recordkeeping
or
reporting
is
necessary
for
new
aftermarket
converter
manufacturers
unless
they
create
a
new
line
of
converters,
in
which
case
data
must
be
submitted
regarding
test
results
and
appropriate
applications
of
the
converters.
For
used
converter
reconditioners,
testing
of
each
converter
is
necessary
to
determine
if
it
is
still
functional.
However,
no
specific
record
retention
requirement
exists
regarding
the
results
of
individual
tests,
other
than
to
include
a
certification
with
the
converter
that
it
passed
testing.
This
short
statement
can
be
pre­
printed
form.

If
industry
voices
an
interest
in
electronic
reporting,
EPA
will
facilitate
such
data
interchange,
if
practical.
In
the
meantime,
we
would
be
willing
to
accept
computer
discs
or
other
electronic
information
containing
warranty
information
instead
of
hard
copies
of
the
information.

Installers
have
no
reporting
requirement.
They
merely
fill
out
a
warranty
card
for
each
converter
installed,
and
include
on
the
customary
business
practice
invoice
a
pre­
printed
statement
with
a
blank
for
why
replacement
was
appropriate.
The
invoice,
including
the
reason
for
replacement
statement,
must
be
kept
for
6
months.
In
addition,
the
removed
converter
is
tagged
for
a
15
day
period,
so
it
can
be
directly
related
to
the
vehicle
and
to
the
aftermarket
converter
that
replaced
it.

5(
c)
Small
Entity
Flexibility
The
information
collection
reduces
to
the
extent
practicable
and
appropriate
the
burden
on
persons
who
shall
provide
information
to
or
for
the
Agency,
including
with
respect
to
small
entities,
as
defined
by
the
Regulatory
Flexibility
Act
(
5
U.
S.
C.
§
601(
6)),
the
use
of
such
techniques
as:
(
1)
establishing
differing
compliance
or
reporting
requirements
or
timetables
that
take
into
account
the
resources
available
to
those
who
are
to
respond;
(
2)
the
clarification,
consolidation,
or
simplification
of
compliance
and
reporting
requirements;
or
(
3)
an
exemption
from
coverage
of
the
collection
of
information,
or
any
part
thereof.

New
aftermarket
converter
manufacturers
are
substantial
businesses
with
gross
revenues
in
the
millions
of
dollars
per
year.
The
converter
reconditioners
tend
to
be
smaller
businesses
and
the
recordkeeping
and
reporting
requirements
are
somewhat
less;
to
wit:
there
are
no
warranty
requirements
and
therefore
no
requirements
to
maintain
warranty
cards
or
report
warranty
information.
More
importantly,
the
policy
allows
small
businesses
to
compete
with
the
original
equipment
manufacturers
in
a
market
which
was
previously
inaccessible
to
them,
and
which
would
not
be
legal
but
for
this
policy.
Many
installers
are
small
businesses
and
have
benefitted
significantly
from
this
multimillion
dollar
industry.
Their
requirements
are
minimal
(
4­
5
minutes
per
installation,
at
least
some
of
which
is
not
an
EPA
imposed
burden
since
maintaining
invoices
is
a
13
customary
business
practice).

5(
d)
Collection
Schedule
Sales
reports
are
submitted
to
EPA
by
manufacturers
and
reconditioners
semi­
annually.
No
other
regular
reporting
exists.
Installers
do
not
report.
Their
recordkeeping
occurs
at
the
time
of
each
transaction.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
Assumptions:

The
estimated
dollar
cost
for
new
aftermarket
converter
manufacturers
will
be
different
than
for
used
OE
converter
reconditioners,
since
the
policy
is
different
for
each
group.
The
cost
estimates
for
manufacturers
and
reconditioners,
and
for
installers,
are
outlined
below.

New
Converter
Manufacturers
1.
The
number
of
new
aftermarket
converter
manufacturers
is
approximately
12.
The
cost
to
new
converter
manufacturers
consists
of
1)
the
one­
time
cost
of
submitting
new
product
line
specifications
and
testing
information
to
EPA;
2)
the
one­
time
cost
to
test
two
converters
for
each
product
line
using
the
specifications
outlined
in
the
policy;
and
3)
submission
of
semi­
annual
reports
regarding
manufacturing
and
sales.

2.
Contractor
cost:
Based
on
estimates
supplied
by
companies
that
provide
the
testing
services,
the
testing
cost
for
a
typical
manufacturer
is
approximately
$
81,488
per
product
line.
This
estimate
includes
the
cost
for
personnel
to
conduct
the
testing,
as
well
as
the
actual
cost
of
the
testing
equipment
and
procedures.
If
the
typical
manufacturer
markets
three
new
product
lines
every
ten
years,
the
total
testing
cost
for
a
typical
new
converter
manufacturer
would
be
$
244,260.
Under
the
assumption
that
the
prevailing
interest
rate
is
1O%,
the
annualized
cost
of
the
development
testing
would
be
$
244,260
amortized
over
120
months
at
10%
compounded
monthly,
or
$
38,735
per
manufacturer
per
year.

3.
To
estimate
the
labor
cost
of
tabulating
and
reporting
the
information
as
required,
it
was
assumed
in
the
1998
ICR
that
the
cost
for
a
technician
is
$
32,463
per
year,
which
when
doubled
to
take
into
account
overhead
and
benefits,
comes
to
$
64,926
per
year,
or
$
70,542
in
2002
dollars.
This
yearly
figure
yields
an
hourly
2002
cost
of
about
$
33.68/
hr.
These
cost
figure
have
been
adjusted
for
inflation
from
data
on
the
BLS
website.
The
Bureau
of
Labor
Statistics
website
is
found
at
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm).
A
110%
overhead
adjustment
was
calculated
in
order
to
accurately
reflect
inflation
and
other
cost
variables
between
1998
and
2002.

4.
The
actual
hour
estimates
per
response
have
been
revised
downward
due
to
the
fact
that
companies
have
utilized
computerized
record
keeping
systems
and
are
otherwise
well­
organized
to
submit
the
required
information.
For
new
converter
manufacturers,
putting
14
together
an
EPA
report
on
specifications
of
a
new
product
line
takes
about
2
hours.
Putting
together
a
computerized
report
on
manufacturing
and
sales
information
takes
about
0.5
hr.
Warranty
card
information
is
submitted
manually;
this
takes
about
1
hour
to
box
and
send
to
EPA.

Reconditioners
of
Used
Converters
1.
The
number
of
reconditioned
converter
businesses
is
approximately
eight
at
this
point
in
time.

2.
The
cost
to
a
used
converter
reconditioner
consists
of
the
labor
costs
of
testing
each
individual
converter
according
to
the
test
procedures
outlined
in
the
policy,
the
cost
of
setting
up
the
bench
testing
equipment,
and
the
cost
of
tabulating
and
reporting
the
information
required
in
the
policy.
These
cost
elements
are
treated
separately
below.

3.
Two
technicians
are
needed
to
test
each
converter.
The
cost
of
a
technician
per
hour
is
estimated
to
be
about
the
same
as
for
new
converter
manufacturers,$
33.68
per
hour.

4.
An
average
of
2.00
minutes
are
required
for
each
test.

5.
Capital
Costs
for
reconditioners
equipment
are
based
on
test
equipment
cost
of
about
$
162,840,
having
a
useful
life
of
about
5
years.
If
this
is
amortized
over
5
years
with
10%
interest,
the
yearly
cost
comes
to
$
41,518
per
reconditioners.

6.
Record­
keeping
costs
for
tabulating
and
reporting
information
to
Agency
are
based
on
the
same
labor
rate
as
above.

7.
Reconditioners
have
reduced
their
reporting
burden
by
keeping
information
in
computer
databases.
Because
of
this,
preparation
of
a
semi­
annual
report
may
take
less
than
4
hrs.
That
is
less
than
8
hrs.
per
year.

Installers
of
Aftermarket
Converters
1.
There
are
approximately
30,000
automotive
exhaust
repair
shops
nationwide.
It
is
assumed
that
these
entities
install
the
vast
majority
of
aftermarket
converters
and
it
is
further
assumed
that
all
of
these
entities
install
converters,
and
generally
excludes
tire/
brake
shops,
and
other
non­
exhaust
repair
facilities
such
as
electrical
diagnostic
and
other
such
facilities.

2.
There
are
currently
2.3­
2.7
million
new
aftermarket
converters
installed
per
year.
A
recent
report
from
the
Manufacturers
of
Emission
controls
Association
reported
a
total
of
3,079,249
new
aftermarket
converters
produced
in
2001.

3.
Typically,
it
takes
an
exhaust
repair
technician
4­
5
minutes
per
installation
to
handle
all
recordkeeping
requirements
(
fill
out
warranty
card
if
applicable,
fill
in
blank
on
invoice
regarding
reason
for
replacement,
and
tag
the
converter
that
was
removed).
This
estimate
is
based
on
information
from
shop
owners
as
well
as
EPA
15
experience
with
the
paperwork.
In
many
cases,
blank
warranty
cards
are
simply
provided
to
customers,
further
reducing
burden
times.

4.
Employee
salaries
are
estimated
to
be
at
a
rate
well
above
minimum
wage,
but
substantially
less
than
that
of
a
new
car
dealership
mechanic.
It
is
believed
that
pay
and
benefit
rates
within
this
industry
vary
greatly
between
locations
and
between
individual
businesses
in
the
same
area.
The
same
wage
rate,
$
33.68
per
hour,
which
was
used
for
installers
and
reconditioners
has
been
used
to
estimate
the
cost
to
the
business.

5.
Using
the
above
assumptions,
each
shop
averages
118
installations
per
year.
On
the
average,
the
paperwork
takes
about
4
minutes
per
installation,
or
10
hours
per
year.
At
$
33.68
per
hour,
this
comes
to
$
337
per
year
per
shop.

6(
a)
Estimates
of
Respondent
Burden
and
Cost
See
Tables
A.
1.
and
3,
B.
2
and
3,
and
C.
1,
Attached,
for
a
detailed
accounting.

A.
New
Aftermarket
Catalytic
Converter
Manufacturers
1.
PROVIDE
SPECIFICATIONS
FOR
NEW
PRODUCT
LINES:

One­
time
burden
for
each
new
product
line.
Assume
each
manufacturer
develops
one
new
product
line
every
3
years.

HRS.
PER
RESPONDENT:
2.0
COST
PER
RESPONDENT:
$
67.00
HRS.
FOR
12
RESPONDENTS:
24
COST
FOR
12
RESPONDENTS:
$
808
2.
TESTING
OF
PROTOTYPES
(
Purchased
Services):

One­
time
burden
for
new
product
lines.
Assume
3
new
product
lines
per
manufacturer
per
10
year
period,
with
costs
amortized
over
that
period.

HRS.
PER
RESPONDENT:
(
contracted
out)
COST
PER
RESPONDENT:
$
38,767
HRS
FOR
12
RESPONDENTS:
N/
A
COST
FOR
12
RESPONDENTS:
$
465,204
3.
SEMI­
ANNUAL
SUBMISSIONS
OF
MANUFACTURING
DATA
AND
WARRANTY
CARDS:

HRS.
PER
RESPONDENT:
3
COST
PER
RESPONDENT:
$
101
HRS.
FOR
12
RESPONDENTS:
36
COST
FOR
12
RESPONDENTS:
$
1,216
16
4.
ANNUALIZED
O
&
M
COSTS
(
for
postage):
$
65
X
12
respondents
=
$
780
for
all
respondents.

B.
USED
CATALYTIC
CONVERTER
RECONDITIONERS
1.
SUBMIT
TEST
FACILITY
INFORMATION:

This
is
a
one­
time
burden
which
has
already
been
absorbed
by
current
reconditioners.
No
new
facilities
are
anticipated
within
the
period.

1a.
AMORTIZED
CAPITAL
COSTS
PER
RESPONDENT:
$
41,518.
AMORTIZED
CAPITAL
COSTS
FOR
8
RESPONDENTS:
$
332,144.

2.
PERFORM
EFFICIENCY
TESTS
ON
EACH
NEW
CONVERTER:

HRS.
PER
RESPONDENT:
623
COST
PER
RESPONDENT:
$
20,984
HRS.
FOR
8
RESPONDENTS:
4,984
COST
FOR
8
RESPONDENTS:
$
167,869
3.
SEMI­
ANNUAL
REPORTS
REGARDING
DISTRIBUTION
OF
PRODUCTS:

HRS.
PER
RESPONDENT:
8
COST
PER
RESPONDENT:
$
269.00
HRS.
FOR
8
RESPONDENTS:
64
COST
FOR
8
RESPONDENTS:
$
2,156.00
4.
ANNUALIZED
O
&
M
(
for
postage):
$
217
X
8
RESPONDENTS
=
$
1,736
for
all
respondents.

C.
RECORDKEEPING
BY
EXHAUST
SYSTEM
REPAIR
FACILITIES
1.
MAINTAIN
INVOICES
&
REMOVAL
JUSTIFICATION
&
TAG
CONVERTERS
HRS.
PER
RESPONDENT:
3.54
COST
PER
RESPONDENT:
$
119.51
HRS.
FOR
30,000
RESPONDENTS
(
revised
upward
from
17,000
respondents
in
previous
renewal):
106,200
COST
FOR
30,000
RESPONDENTS:
$
3,576,900
2.
STARTUP
COSTS:
100
STARTUPS
X
5
HRS.
=
500
TOTAL
hours
x
$
33.68
=
$
16840
+
$
217
CAPITAL
COSTS
(
to
purchase
file
storage
space)
X
100
=
$
38,540
for
all
respondents.

6(
b)
Summary
of
Respondent
Costs
1.
Total
Yearly
Costs
for
New
Aftermarket
Converter
Manufacturers:

$
39,575
per
respondent,
including
contractor
testing
costs
&
17
O
&
M
costs;
$
474,900
for
all
12
respondents.

2.
Total
Yearly
Costs
for
Converter
Reconditioners:

$
62,502,
including
cost
of
testing
each
converter
to
check
efficiency,
capital
costs
of
$
41518
+
O
&
M
costs
of
$
20,984
=
$
500,016
for
all
8
respondents.

3.
Total
yearly
costs
for
installers:

$
119.23
for
1
respondent
=
$
3,576,900
for
all
30,000
installer
facilities.

Total
Startup
costs
for
new
businesses:
5
hrs.
plus
$
217
for
filing
space
or
$
385
per
party
X
100
new
parties
per
year
=
$
38,540
total.

TOTAL
YEARLY
BURDEN:
$
3,576,900
(
including
salaries);
106,200
hrs.
for
all
respondents,
including
testing
(
plus
500
hrs.
for
100
startups
=
106,700
hrs.).
Annualized
cost
burden
other
than
salaries:
$
821,876.

SUMMARY
OF
RESPONDENTS'
BURDENS
AND
COSTS
BY
CATEGORY:

I.
New
Aftermarket
Catalytic
Converter
Manufacturers
A.
Annual
Burden
Hours
per
Party:
5.

B.
Annualized
Capital
Costs
per
Party:
$
0.00.

C.
Annualized
Operating
Costs
per
party
(:
$
65.00
D.
Annualized
Startup
Costs:
$
0.00
(
new
entities
entering
the
market
have
been
largely
offset
by
mergers
and
closures).

E.
Annual
Purchased
Services
per
Party(
for
Testing
of
Prototypes):
$
38,767.

II.
Used
Aftermarket
Catalytic
Converter
Manufacturers
A.
Annual
Burden
Hours
per
Party:
631
(
most
of
which
is
testing
of
catalytic
converters
to
determine
they
are
functional;
the
actual
recordkeeping
burden
is
minimal).

B.
Annualized
Capital
Costs
per
Party:
$
41,518.

C.
Annualized
Operating
Costs
per
Party:
$
217.

D.
Annualized
Startup
Costs:
None.
There
have
been
no
new
parties
and
none
are
expected
in
the
next
3
years.

E.
Annual
Purchased
Services
per
Party:
$
0.00.
18
III.
Installers
of
Aftermarket
Converters
A.
Annual
Burden
Hours
per
Party:
3.5
B.
Annualized
Capital
Costs
per
Party:
$
0.00.

C.
Annualized
Operating
Costs
per
party:
$
0.00.

D.
Annual
Purchased
Services
per
Party:
$
0.00.

E.
Annualized
Startup
Costs:
Assume
100
new
installers
per
year;
Assume
reviewing
instructions
and
setting
up
recordkeeping
systems
requires
5
hrs
per
party
and
the
purchase
of
file
space
of
$
200.
Total
startup
cost
would
be
$
168
plus
$
217,
for
a
total
of
$
385
per
party
and
$
38,540
nationwide.

6(
c)
Estimated
EPA
Burden
and
Cost
The
direct
cost
of
personnel
to
process
and
analyze
the
information
collected
is
estimated
to
be
$
32,595
or
about
one­
quarter
person/
year
at
the
cost
of
a
grade
12
employee.
An
estimated
travel
cost
of
$
5433
would
be
needed
to
monitor
compliance
with
the
policy,
in
addition
to
travel
already
used
for
retail
level
inspections
for
automobile
emissions
tampering
generally.
The
total
annual
cost
to
the
government
is
thus
estimated
to
be
$
38,027.

6(
d)
Reasons
for
Change
in
Burden
Burdens
for
new
and
used
aftermarket
converter
manufacturers
and
reconditioners
have
not
been
changed.
We
believe
previous
estimates
on
burdens
and
costs
were
somewhat
high
and
interest
rates
for
annualized
capital
costs
have
been
reduced
in
recent
years.
Numbers
of
converter
installation
facilities
have
been
revised
upward
to
reflect
current
industry
estimates.

6(
e)
Burden
Statement
The
public
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average:

5
hours
per
new
aftermarket
converter
manufacturer,
on
average,
with
$
65
annual
operational
costs
per
year
and
annualized
purchased
services
costs
per
year
of
$
38,788;
631
hours
(
including
converter
testing
time)
per
used
converter
reconditioned,
on
average,
with
annualized
capital
costs
per
year
of
$
41,518
and
annualized
operational
costs
per
year
of
$
217;
and
3.5
hours
per
respondent
for
aftermarket
converter
installation
facilities,
with
an
additional
5
hours
for
the
first
year
for
startup
facilities
and
an
additional
$
217
for
startup
capital
costs.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions,
develop,
acquire,
install,
and
utilize
19
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
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,
OIC
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822T),
1200
Pennsylvania
Avenue,
NW,
Washington,
DC
20460­
0001;
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
the
OMB
control
number
in
any
correspondence.

PART
B.
COLLECTION
OF
INFORMATION
EMPLOYING
STATISTICAL
METHODS
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
the
aftermarket
catalytic
converter
policy.

APPENDIX
A.
Summary
of
Comments
to
First
Federal
Register
Notice
Comments
were
received
from
Mr.
Douglas
Greenhaus
of
the
National
Automotive
Dealers
Association.
Mr.
Greenhaus
expressed
concerns
regarding
the
burden
estimates
utilized
in
previous
ICRs,
the
absence
of
technical
changes
to
reflect
current
warranty
requirements,
and
his
perception
that
the
Policy
itself
as
a
defacto
rulemaking
that
circumvents
normal
rulemaking
procedures.

APPENDIX
B.
Citation
for
Information
Requirements
of
the
ICR
The
information
requirements
of
this
ICR
are
enumerated
in
the
Agency's
proposed
and
interim
enforcement
policy
published
in
the
Federal
Register
on
August
5,
1986
(
51
FR
28114).
In
this
FR
notice
the
Agency
proposed
to
amend
40
CFR
Part
85
by
adding
a
new
Appendix
IX,
which
would
consist
of
this
enforcement
policy.
There
are
no
regulations
applicable
to
this
information
collection.
The
citations
listed
below
for
the
information
requirements
refer
to
this
FR
notice.

Information
Requirement
FR
Citation
New
Converter
Manufacturers
Collect
and
transmit
converter
specifications
to
Agency
51
FR
28119
Transmit
semi­
annual
manufacturing
totals
by
20
converter
type
51
FR
28117
Transmit
semi­
annual
sales
figures
from
warranty
cards
or
copies
of
warranty
cards
51
FR
28117
collect,
file,
and
maintain
warranty
card
information
51
FR
28117
Used
Converter
Reconditioners
Collect
and
transmit
converter
application
information
to
Agency
51
FR
28119
Transmit
semi­
annual
sales
information
51
FR
28118
Transmit
semi­
annually
the
names
and
addresses
of
customers
to
whom
converters
were
sold
51
FR
28118
Collect,
file,
and
maintain
sales
figures
and
customer
lists
51
FR
28118
Installers
Invoices,
Warranties,
Tag
Converters:
51
FR
28116
APPENDIX
C:
Burden
Tables:
A1,
A3,
B2,
B3
and
C1.
