Burden Calculations Table

1764t09.xlsx

National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR part 59, subpart C) (Renewal)

Burden Calculations Table

OMB: 2060-0348

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents


Sheet 1: Summary

ICR Summary Information
Hours per Response 261
Number of Respondents 337
Total Estimated Burden Hours 17,500
Total Estimated Costs $2,210,000
Annualized Capital O&M $0
Total Annual Responses 67
Form Number Not Applicable

Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal).


























REPORTING/RECORDKEEPING REQUIREMENT a (A)
Respondent Hours
per Occurrence
(Technical hours)
(B)
Number of
Occurrences
per Respondent
per Year
(C)
Hours
per Respondent
per Year
(C=A x B)
(D)
Number of
Respondents
per Year
(E)
Technical Hours
per Year
(E=C x D)
(F)
Management
Hours per Year
(F= E x 0.05)
(G)
Clerical Hours
per Year
(G= E x 0.1)

Total
Labor Costs
per Year b



Reporting










1 Read instructions
2 1 2 30 60 3 6 $8,701
Managerial Labor Rate $163.17
2 Gather information
1 1 1 30 30 1.5 3 $4,350
Technical Labor Rate $130.28
3 Initial notification
1 1 1 30 30 1.5 3 $4,350
Clerical Labor Rate $65.71
4 Update date code
1 1 1 30 30 1.5 3 $4,350


5 Variance application
2 1 2 5 10 0.5 1 $1,450


6 Innovative products application
24 1 24 2 48 2.4 5 $6,960




Total for Reporting




239
$30,162
















Recordkeeping










7 Read instructions
------------------------Included in 1----------------------------



8 Plan activities
2 1 2 300 600 30 60 $87,006


9 Implementation
4 12 48 300 14,400 720 1,440 $2,088,137


10 Charcoal lighter results
1 1 1 5 5 0.3 0.5 $725




Total for Recordkeeping




17,256
$2,175,868
















Total Industry Burden (rounded) c






17,500
$2,210,000
261 hrs/response














a The recordkeeping and reporting requirements of 40 CFR Part 59, Subpart C apply to distributors named on product labels or manufacturers or importers of products. We have assumed that 337 respondents per year will do new reporting or recordkeeping due to changes in products.


b This ICR uses the following labor rates: Managerial $163.17 ($77.70 + 110%); Technical $130.28 ($62.04 + 110%); and Clerical $65.71 ($31.29 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2022, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation." The rates have been increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.


c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – National Volatile Organic Compound Emission Standards for Consumer Products (40 CFR Part 59, Subpart C) (Renewal)













0.869565


$46.22



REPORTING/RECORDKEEPING REQUIREMENT a (A)
Person Hours per Occurrence
(B)
Occurrences per Year
(C)
Technical Person Hours
(C=A x B)
(D)
Management Person Hours
(D = C x 0.05)
(E)
Clerical Person Hours
(E=C x 0.1)

Total Cost per Year b



Reporting









Initial notification 1 30 30 1.5 3 $1,834
Managerial Labor Rates $73.46

Update date code 1 30 30 1.5 3 $1,834
Technical Labor Rates $54.51

Variance application 8 5 40 2 4 $2,445
Clerical Labor Rates $29.50

Innovative products application 8 2 16 0.8 1.6 $978


Total Agency Burden c



133 $7,090














a The recordkeeping and reporting requirements of 40 CFR Part 59, Subpart C apply to distributors named on product labels or manufacturers or importers of products. We have assumed that 337 respondents per year will do new reporting or recordkeeping due to changes in products . We assume that 37 of these respondents will submit reports for Agency review.


b The cost is based on the following labor rates: Managerial rate of $73.46 (GS-13, Step 5, $45.91 + 60%), Technical rate of $54.51 (GS-12, Step 1, $34.07 + 60%), and Clerical rate of $29.50 (GS-6, Step 3, $18.44 + 60%). These rates are from the Office of Personnel Management (OPM), 2023 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.


c Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.



Sheet 4: Capital O&M

The only costs to the regulated industry resulting from information collection activities required by the subject standard(s) are labor costs. There are no capital/startup or operation and maintenance costs.

Sheet 5: Responses

Total Annual Responses
(A) (B) (C) (D) (E)
Information Collection Activity Number of Respondents Number of Responses Number of Existing Respondents That Keep Records But Do Not Submit Reports Total Annual Responses E=(BxC)+D
Initial notification 30 1 0 30
Update date code 30 1 0 30
Variance application 5 1 0 5
Innovative products application 2 1 0 2



Total 67






Sheet 6: Respondents

Number of Respondents

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

(A) (B) (C) (D) (E)
Year Number of New Respondents 1 Number of Existing Respondents Number of Existing Respondents that keep records but do not submit reports Number of Existing Respondents That Are Also New Respondents Number of Respondents (E=A+B+C-D)
1 37 37 300 37 337
2 37 37 300 37 337
3 37 37 300 37 337
Average 37 37 300 37 337
1 The recordkeeping and reporting requirements of 40 CFR Part 59, Subpart C apply to distributors named on product labels or manufacturers or importers of products. We have assumed that 337 respondents per year will do new reporting or recordkeeping due to changes in products.
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