Description and Estimate of Burden on Small Businesses Sample Clauses

Description and Estimate of Burden on Small Businesses. The proposed test procedures for LED lamps, if adopted by FTC, would potentially require re-testing of any previously tested product. Further, if adopted by FTC, the proposed test procedures would require manufacturers to update their existing package and product labeling and online and hardcopy retailers to update their catalogs. The estimated cost of testing, packaging and labeling, and revising catalogs are discussed below. Testing To estimate the cost of testing, DOE determined the initial cost for setup and the costs to perform tests for determining the input power, lumen output, CCT, and rated lifetime of LED lamps. The initial setup for testing input power, lumen output, and CCT would require a custom-built rack for mounting lamps for testing. DOE estimated that up to 120 hours of labor may be required for building a rack that can hold up to 100 lamps. XXX estimated that the cost to build a rack by an electrical engineer whose rate is $39.79 per hour 36 would be approximately $4,770. DOE estimated that the material cost to build a custom-built rack holding 100 sockets would be $3,000 and the power supply and regulator costs would be $3,300 and $1,250 respectively. DOE estimated the total cost to build a rack to be approximately $12,000. DOE expects that manufacturers of LED lamps would already have other instrumentation necessary for testing, because IES LM– 79–2008 is the recommended standard for testing LED lamps for the FTC Lighting Facts label. In addition to setup, the labor cost associated with carrying out the testing contributes to the overall testing burden. As discussed in section III.D, for testing lumen output, input power, and CCT, manufacturers would be required to test a total of 21 LED lamps. DOE estimated that this testing would require approximately four hours per lamp by an electrical engineer whose rate is $39.79 per hour. DOE estimated about 19 small business manufacturers of LEDs would be impacted, each typically manufacturing about 17 basic models. In total, the use of this test method for determining light output, input power, and CCT would result in testing related labor costs of $57,000 for each manufacturer. For lifetime testing, as discussed in