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 EPA for approval by submitting verification that its program meets EPA standards. The information requested is used by the EPA to guarantee a degree of uniformity in the testing programs for motor vehicle service technicians. 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.
Certification, reporting and recordkeeping:To facilitate enforcement under Section 609, EPA has developed several recordkeeping requirements. All required records must be retained on-site for a minimum of three years, unless otherwise indicated.
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 to verify compliance.
Any person who owns approved refrigerant handling equipment must maintain records of the name and address of any facility to which refrigerant is sent and 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. In all cases, the seller must display a sign where sales occur that states the certification requirements for purchasers.
Burden Statement:The annual public reporting and recordkeeping burden for this collection of information is estimated to average less than one hour per response. 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 technology and systems for the purposes 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 which have subsequently changed; 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.
The ICR provides a detailed explanation of the Agency's estimate, which is only briefly summarized here:
Affected Entities:Motor vehicle dealers, automobile parts stores, general automotive repair shops, and automotive repair shops not elsewhere classified.
Estimated Number of Potential Respondents:52,614.
Frequency of Response:On occasion.
Estimated Total Annual Hour Burden:4,523 hours.
Estimated Total Annual Costs:$208,307. This includes $208,307 in labor costs and no capital or operation and maintenance costs.
Changes in the Estimates:There is a decrease of 2,177 hours in the total estimated burden currently identified in the OMB Inventory of Approved ICR Burdens. There are three reasons for this decrease in burden hours. Today, it is estimated that there are only 600 thousand R-12 MVACs on the road, or 80% less than 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. The second reason for the burden hours decrease is that CFC-12 refrigerant sent off-site for reclamation to an approved refrigerant reclaimed by owners of refrigerant recycling equipment certified under 40 CFR 82.36(a) has decreased and is anticipated to continue decreasing due to the significant decline of CFC-12 vehicles on road. The third reason for the burden hours decreased is that there are less approved technician certification programs in business than in the previous ICR. However, EPA anticipates a slow increase of one organization approval per year as new alternative refrigerants become available and new businesses become interested in certifying technicians for MVAC servicing for consideration.
Director, Collection Strategies Division.