U.S. Environmental Protection Agency
Information Collection Request
Title: Reporting and Recordkeeping Requirements for the Interim Final Safe Management of Recalled Airbags Rule (Renewal)
OMB Control Number: 2050-0221
EPA ICR Number: 2589.06
Abstract: The collection of information is necessary in order to ensure that the hazardous waste airbag modules and airbag inflators exempted under this rule are safely disposed of and that defective airbag modules and airbag inflators are not reinserted into vehicles where they would pose an unreasonable risk of death or serious injury. Information collection activities include maintaining at the airbag handler for no less than three years records of (1) all off-site shipments and (2) confirmations of receipt of airbag waste.
Supporting Statement A
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
The requirements covered in this ICR are necessary for EPA to oversee the handling and management of airbag waste. EPA is requiring the establishment of these information collection requirements under the authority of sections 2002, 3001, 3002, 3003, 3004, 3006, 3010, and 3017 of the Solid Waste Disposal Act of 1965, as amended by the Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA).
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
EPA will use the collected information to ensure that airbag waste is managed in a cost-effective manner that minimizes risks to human health and the environment.
USE OF TECHNOLOGY
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
The information collected, as described above, can be kept in an electronic format.
EFFORTS TO IDENTIFY DUPLICATION
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
None of the information required by this ICR will duplicate information required by existing RCRA regulations.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
Some respondents will be small organizations. However, all the provisions in the ICR are intended to provide greater flexibility to facilities involved in handling airbag waste. In the absence of these requirements, some facilities that are currently RCRA very small quantity generators or small quantity generators could become large quantity generators and face increased regulatory costs.
CONSEQUENCES OF LESS FREQUENT COLLECTION
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
EPA has carefully considered the burden imposed upon the regulated community. EPA is confident that those activities required of respondents are necessary, and to the extent possible, the Agency has attempted to minimize the burden imposed. EPA believes strongly that, if the minimum information collection requirements are not met, neither the industry nor EPA will be able to ensure that airbag waste is being managed in a manner protective of human health and the environment.
GENERAL GUIDELINES
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
The information collection is consistent with the guidelines set forth in 5 CFR 1320(d)(2) of the Paperwork Reduction Act.
If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on May 6, 2025 (90 FR 19202). The notice indicated that EPA was planning to submit an ICR, “Safe Management of Recalled Airbags Rule (Renewal)” (EPA ICR No. 2589.06, OMB Control No. 2050-0221), to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. The notice also requested comments on the information collection and burden estimates covered in the ICR. The public comment period extended through July 7, 2025. EPA received no comments on this ICR in response to the Federal Register notice.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
EPA consulted with Carmax, Resource One, RAS, Tesla, Key Automotive of Florida LLC, Clean Water Environmental, Custom Truck One Source, Royal Truck Body, and Spring Grove Resource Recovery Inc. As a result of these consultations, the burden calculation estimates were deemed to be acceptable.
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
There are no payments or gifts associated with this collection of information.
ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
EPA does not intend to collect any information related to trade secrets of the stakeholders. Section 3007(b) of RCRA and 40 CFR Part 2, Subpart B define EPA’s general policy on the public disclosure of information and contain provisions for confidentiality of business information. EPA protects from public disclosure all Confidential Business Information (CBI) obtained under RCRA and has provided businesses with procedures to claim confidentiality for such CBI. EPA makes extra efforts to protect the confidentiality of this CBI.
JUSTIFICATION FOR SENSITIVE QUESTIONS
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
The information collection activities covered by this ICR will not include questions about sensitive issues.
Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.
The primary entities impacted by this ICR are automobile dealerships that perform warranty repair/replacement work related to the recalled airbag inflators. These dealerships fall under NAICS code 441: Motor Vehicle and Parts Dealers. According to the National Automobile Dealers Association, there are about 16,957 new-car, franchised dealerships in the United States1. Assuming that the percentage of relevant car sales is roughly proportional to the number of relevant dealerships results in an estimate of 15,431 dealerships where work related to airbag inflators may occur (91 percent of 16,957).
All of the burden associated with this ICR is recordkeeping.
The recordkeeping requirements for this ICR consist of maintaining at the airbag handler for no less than three years records of (1) all off-site shipments and (2) confirmations of receipt of airbag waste. The recordkeeping requirements may be fulfilled by ordinary business records, such as bills of lading, and are intended to allow the Agency to verify that the airbag waste reaches its intended destination and is not diverted back into vehicles. It is estimated that .05 hours of a clerical workers time will be required for each off-site shipment and confirmation of receipt (individually).2
12d. Respondent Burden Hours and Labor Costs
Exhibit 1 summarizes the respondent burden associated this ICR. As shown in the exhibit, the hourly burden for handlers of airbag waste is a total of 4,320 hours annually (an average of 0.28 hours per facility).
The respondent cost burden reflects costs from two required recordkeeping activities: 1) Maintaining at the airbag handler for no less than three years records of all off-site shipments of hazardous secondary materials; 2) Maintaining at the airbag handler for no less than three years confirmations of receipt. The labor costs associated with this ICR are $151,290 annually.
Labor Category |
Non-loaded 2025 hourly rate3 |
Fringe benefits loading multiplier |
Overhead loading multiplier |
Loaded Hourly rate |
1. Legal |
$84.65 |
1.43 |
1.336 |
$161.72 |
2. Managerial |
$51.44 |
1.43 |
1.336 |
$98.28 |
3. Technical |
$44.78 |
1.43 |
1.336 |
$85.55 |
4. Clerical |
$18.33 |
1.43 |
1.336 |
$35.02 |
Respondent CAPITAL AND O&m CostS
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There are no capital and O&M costs associated with this ICR.
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
Since EPA is not required to regularly collect or monitor shipment records, there is no expected burden for the Agency associated with this ICR.
14b. Agency Labor Cost
There are no Agency labor costs associated with this ICR.
14c. Agency Non-Labor Costs
There are no Agency non-labor costs associated with this ICR.
REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
There is an increase of 71 hours in the burden estimates for this ICR due to an increase in the number of respondents.
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Results from this ICR are not published formally.
DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The agency plans to display the expiration date for OMB approval of the information collection on all instruments.
CERTIFICATION STATEMENT
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.
Exhibit 1: Annual Respondent Burden & Cost Estimates |
||||||||||||
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs |
||||||||||
Loaded Hourly Wages |
Labor Costs/ Activity |
Capital Costs |
O&M Costs |
No. of Respondents |
No. of Responses per Respondent |
Total Reponses |
Total Hours |
Total Cost |
||||
Legal |
Manag. |
Technical |
Clerical |
|||||||||
$161.72 |
$98.28 |
$85.55 |
$35.02 |
|||||||||
Maintain at the airbag handler for no less than three (3) years records of all off-site shipments of hazardous secondary materials |
0.00 |
0.00 |
0.00 |
0.05 |
$1.75 |
0 |
0 |
15,431 |
2.8 |
43,207 |
2,160 |
$75,645 |
Maintain at the airbag handler for no less than three (3) years confirmations of receipt |
0.00 |
0.00 |
0.00 |
0.05 |
$1.75 |
0 |
0 |
15,431 |
2.8 |
43,207 |
2,160 |
$75,645 |
TOTAL |
0.00 |
0.00 |
0.00 |
0.10 |
$3.50 |
$0.00 |
$0.00 |
15,431 |
5.6 |
86,414 |
4,320 |
$151,290 |
1 https://www.nada.org/nada/nada-data
2 Information Collection Request Supporting Statement for Revisions to the RCRA Definition of Solid Waste (Proposed Rule).
3 Bureau of Labor Statistics, National Occupational Employment and Wage Estimate, released May, 2021 for NAICS 4411.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 18Q Supporting Statement Instructions_draft |
| Author | Vyas, Peggy |
| File Modified | 0000-00-00 |
| File Created | 2026-01-01 |