December
18,
2003
Supporting
Statement
under
the
Paperwork
Reduction
Act
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
TITLE:
Final
Rule
Related
Addendum
to
an
Existing
EPA
ICR
entitled:
TSCA
§
402/
404
Training
and
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
ICR
No.
EPA
ICR
No.
1715.05;
OMB
2070­
0155
1(
b)
Short
Characterization/
Abstract
This
information
collection
request
(
ICR)
is
an
addendum
to
an
existing
ICR,
identified
under
EPA
ICR
No.
1715.02
and
OMB
Control
No.
2070­
0155.
That
ICR
covers
the
reporting
and
recordkeeping
requirements
for
lead­
based
paint
abatement
professionals
conducting
leadbased
paint
activities
and
training
programs
providing
lead­
based
paint
activities
courses,
which
were
promulgated
under
the
authority
of
Sections
402,
404,
and
407
of
the
Toxic
Substances
Control
Act
(
TSCA).
This
addendum
is
intended
to
provide
the
burden
estimates
associated
with
the
final
rule
entitled:
"
Lead;
Notification
Requirements
for
Lead­
Based
Paint
Abatement
Activities
and
Training,"
and
serves
to
amend
the
approved
burden
for
the
existing
ICR
to
include
the
burden
associated
with
the
notification
provisions
recently
promulgated.

The
final
rule,
issued
under
the
authority
of
Section
407
of
TSCA,
establishes
notification
procedures
for
lead
abatement
professionals
(
certified
under
40
CFR
745.226)
conducting
leadbased
paint
activities,
and
training
programs
(
accredited
under
40
CFR
745.225)
providing
leadbased
paint
activities
courses.
Specifically,
this
regulation
establishes
procedures
for
notifying
the
Agency
prior
to
commencement
of
lead­
based
paint
abatement
activities
as
required
by
40
CFR
745.227(
e)(
4).
In
addition,
this
regulation
establishes
new
requirements
for
training
programs
accredited
under
40
CFR
745.225
to
notify
the
Agency
under
the
following
conditions:
1)
prior
to
providing
lead­
based
paint
activities
training
courses,
and
2)
following
completion
of
lead­
based
paint
activities
training
courses.
These
notification
requirements
are
necessary
to
provide
EPA
compliance
monitoring
and
enforcement
personnel
with
information
necessary
to
track
compliance
activity
and
to
prioritize
inspections.
Today's
regulation
also
supports
the
effort
of
40
CFR
part
745,
subpart
L
to
ensure
that
lead
abatement
professionals
involved
in
inspecting,
assessing
or
removing
lead­
based
paint,
dust
or
soil
are
well
qualified,
trained
and
certified
to
conduct
these
activities.

A
proposed
addendum
to
the
existing
ICR
(
identified
as
EPA
ICR
No.
1715.04),
was
made
available
for
public
comment
along
with
the
proposed
rule
in
2001.
As
an
addendum,
this
document
provides
the
information
that
would
be
in
addition
to
that
already
provided
in
the
existing
ICR
(
identified
as
EPA
ICR
No.
1715.02).
When
the
existing
ICR
is
renewed
in
the
first
quarter
of
FY2004,
EPA
will
amend
that
ICR
to
reflect
the
action
taken
in
this
addendum,
both
in
terms
of
explanation
and
burden
estimates.
Page
2
of
24
2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
Agency
is
issuing
this
regulation
under
the
authority
of
section
407
of
the
Toxic
Substances
Control
Act
(
TSCA),
15
U.
S.
C.
2687.
Section
407
states
that
regulations
of
the
Administrator
under
Subchapter
IV
of
TSCA
shall
include
such
record
keeping
and
reporting
requirements
as
may
be
necessary
to
insure
effective
implementation.
EPA
regulations
under
Subchapter
IV
of
TSCA
include
lead­
based
paint
activities
regulations,
which
this
regulation
seeks
to
amend,
codified
at
40
CFR
745
subpart
L.

This
authority
is
in
addition
to
those
authorities
summarized
in
Section
2(
a)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02).

2(
b)
Practical
Utility/
Users
of
the
Data
These
users
are
the
same
as
the
users
summarized
in
Section
2(
b)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02).

EPA
This
information
collection
will
provide
EPA
compliance,
monitoring,
and
enforcement
personnel
with
information
necessary
to
track
compliance
activity
and
to
prioritize
inspections.

EPA/
States
This
collection
will
enable
EPA/
States
to
determine
compliance
with
and
enforce
the
requirements
for
lead­
based
paint
abatement
activities
and
training.
Without
this
collection,
there
would
be
no
meaningful
way
of
ensuring
the
implementation
of
the
statutory
objective:
to
establish
procedures
to
notify
the
Agency
prior
to
commencement
of
lead­
based
paint
abatement
activities.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
Agency's
collection
pursuant
to
the
TSCA
Section
402,
204,
and
407
regulations
does
not
duplicate
any
other
Agency
collection.
There
is
no
other
model
program
for
lead­
based
paint
activities
or
associated
State
program
approval
process,
and
there
are
currently
no
Federal
standards
for
the
conduct
of
these
activities.

This
section
is
the
same
as
Section
5(
a)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02)

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
The
publication
of
the
proposed
regulation
for
these
requirements
(
66
FR
7208)
served
as
the
public
notice
for
this
ICR.
Interested
parties
submitted
comments
to
the
Agency
which
were
taken
into
account
when
developing
this
final
rulemaking.
On
October
12,
2001,
OMB
filed
the
Page
3
of
24
following
comments
on
the
proposed
addendum
(
identified
as
EPA
ICR
#
1715.04),
which
it
received
on
January
23,
2001:
"
This
ICR
is
associated
with
a
proposed
rulemaking.
Due
to
the
likelihood
of
public
comment,
OMB
will
act
on
the
ICR
at
the
final
rule
stage.
When
EPA
submits
the
ICR
associated
with
the
final
rule,
it
should
include
a
discussion
of
comments
received
and
the
Agency
response
to
those
comments."
EPA
has
provided
OMB
with
a
copy
of
the
Response
to
Comment
document.
See
attachment
E.

3(
c)
Consultations
During
the
development
of
this
rule,
the
Agency
has
consulted
with
a
broad
range
of
interested
parties,
including
States,
training
providers,
and
firms/
individuals.
The
Agency
has
also
worked
directly
with
other
Federal
agencies,
States,
and
lead­
based
paint
abatement
contractors
to
develop
the
program.

This
section
is
the
same
as
Section
5(
b)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02).

3(
d)
Effects
of
Less
Frequent
Collection
Due
to
the
nature
of
this
regulation
and
its
collection,
less
frequent
collection
is
not
feasible.
In
particular,
each
training
program
requires
specific
notification
and
documentation
prior
to
commencement
and
upon
completion
of
each
lead­
based
paint
activity
course,
and
each
lead­
based
paint
abatement
activity
is
a
separate
and
unique
event
requiring
specific
notification
and
documentation
prior
to
commencement.

This
section
is
the
same
as
Section
5(
c)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02)

3(
e)
General
Guidelines
This
ICR
is
consistent
with
OMB's
general
guidelines.
The
Agency
is
requiring
that
individuals
and
firms
maintain
records
for
three
years.

Training
providers
must
maintain
records
for
3.5
years.
This
is
due
to
the
interim
certification
period
of
six
months
following
an
individual
completing
training,
which
allows
the
individual
time
to
apply
to
EPA/
States
to
receive
official
certification.
At
such
time,
the
individual
remains
certified
for
three
years
(
or
five
years
for
individuals
who
have
passed
a
proficiency
test
as
part
of
their
training)
before
he
or
she
must
obtain
refresher
training
and
recertification.
EPA
wishes
training
providers
to
maintain
records
on
a
particular
student
for
as
long
as
the
individual
is
certified
following
training.
Therefore,
the
Agency
believes
that
the
3.5
years
is
an
appropriate
period
for
the
retention
of
such
records.

This
section
is
the
same
as
Section
5(
d)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02).

3(
f)
Confidentiality
This
regulation
does
not
address
questions
of
a
confidential
nature
and
contains
the
same
information
as
Section
5(
e)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02).

3(
g)
Sensitive
Questions
Page
4
of
24
This
regulation
does
not
address
questions
of
a
sensitive
nature
and
contains
the
same
information
as
Section
5(
e)
of
the
existing
ICR
(
EPA
ICR
No.
1715.02).

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
NAICS
Codes/
SIC
Codes
Respondents
to
this
rule
include:
1)
firms
and
supervisors
engaged
in
lead­
based
paint
activities,
and
2)
training
programs
providing
training
services
in
lead­
based
paint
activities.
The
impacted
industries
are
the
same
as
those
covered
in
ICR
1715.03.

NAICS
codes
include:

562910
Lead
abatement
professionals
611519
Training
programs
Other
SIC
codes
include:

1521
General
Contractors
­
Single
Family
Homes
1522
General
Contractors
­
Residential
Buildings,
Other
Than
Single
Family
1531
Operative
Builders
1542
Other
Nonresidential
Buildings
1721
Painting
Contractors
1742
Plastering,
Dry
Wall,
Acoustical,
Insulation
Work
1751
Carpentry
Work
Contractors
1761
Roofing,
Siding,
Sheet
Metal
Work
1795
Wrecking
and
Demolition
1799
Miscellaneous
Trade
Contractors,
NEC
8249
Schools:
Industrial,
Technical
&
Trade
Vocational
Schools
NEC
8299
Vocational
Guidance
Training
Programs
&
Services
4(
b)
Information
Requested
This
regulation
specifies
reporting
and
record
keeping
for
training
providers
and
individuals/
firms
undertaking
lead­
based
paint
abatement
activities.
These
are
new
requirements
that
must
be
performed,
in
addition
to
the
activities
covered
in
ICR#
1715.03.

Notification
of
Lead­
Based
Paint
Activities
Courses
Offered
By
Training
Providers
(
745.225(
c)(
13))

As
outlined
in
Section
745.225(
c)(
13)(
i­
v),
the
training
manager
shall
provide
the
Agency
with
notice
of
all
lead­
based
paint
activities
courses
offered.
The
original
notice
must
be
received
by
the
Agency
at
least
seven
(
7)
business
days
prior
to
offering
any
lead­
based
paint
activities
course.
The
training
manager
shall
provide
the
Agency
updated
notice:
1)
at
least
seven
business
days
before
the
revised
start
date
if
the
course
start
date
is
moved
up,
2)
at
least
two
business
days
prior
to
the
course
start
date
if
the
course
is
delayed,
3)
at
least
seven
business
days
before
the
course
start
date
if
the
course
location
has
changed,
and
4)
at
least
two
business
days
prior
to
the
course
start
date,
if
the
course
is
cancelled
or
other
change
is
made
to
the
original
notice.
Page
5
of
24
As
required
by
Section
745.225(
c)(
13)(
vi),
providers
shall
notify
the
Agency
by
written
notice.
Written
notification
of
lead­
based
paint
activities
course
schedules
can
use
either
the
sample
form,
entitled
"
Lead­
Based
Paint
Activities
Training
Course
Schedule"
or
a
similar
form
developed
by
the
training
program
containing
the
required
information.
All
written
notices
shall
be
delivered
by
the
U.
S.
Postal
Service,
fax,
commercial
delivery
service,
or
hand
delivery
(
Persons
submitting
notification
by
U.
S.
Postal
Service
are
reminded
that
they
should
allow
three
additional
business
days
for
delivery
in
order
to
ensure
that
the
Agency
receives
the
notification
by
the
required
date).
In
addition,
beginning
in
the
Summer
of
2004
training
providers
may
provide
electronic
submissions
using
the
Agency's
Central
Data
Exchange
(
CDX).
The
CDX
system
provides
secure
internet
based
electronic
submission
of
data
to
the
Agency.

(
i)
Data
Items
The
initial
notice
should
include
the
following:

°
Notification
type
(
Original,
Updated,
Cancellation);
°
Training
program
name,
EPA
accreditation
number,
address,
and
phone
number;
°
Course
discipline,
type
(
initial/
refresher),
and
the
language
in
which
instruction
will
be
given;
°
Date(
s)
and
time(
s)
of
training;
°
Training
location(
s)
phone
number,
and
street
address;
°
Principal
instructor's
name;
and
°
Training
manager's
name
and
signature.

(
ii)
Respondent
Activities
As
required
by
Section
745.225(
c)(
13)(
i­
iv),
training
providers
notifying
the
Agency
must
perform
the
following
activities:

°
Provide
notification
to
the
Agency
of
all
lead­
based
paint
activities
courses
offered;
°
Update
the
Agency
regarding
any
changes
to
training
dates,
course
locations,
course
cancellations,
or
other
change
is
made
to
the
original
notice.

Notification
by
Training
Providers
Following
Completion
of
Lead­
Based
Paint
Activities
Courses
(
745.225(
c)(
14))

As
required
in
Section
745.225(
c)(
14),
training
providers
shall
provide
the
Agency
notice
within
10
days
of
completion
of
any
lead­
based
paint
activities
course.
Notification
shall
be
provided
in
writing
using
either
the
sample
form,
entitled
"
Lead­
Based
Paint
Activities
Training
Course
Follow­
Up"
or
a
similar
form
developed
by
the
training
program
containing
the
required
information.
All
written
notices
shall
be
delivered
by
the
U.
S.
Postal
Service,
fax,
commercial
delivery
service,
or
hand
delivery
(
Persons
submitting
notification
by
U.
S.
Postal
Service
are
reminded
that
they
should
allow
three
additional
business
days
for
delivery
in
order
to
ensure
that
the
Agency
receives
the
notification
by
the
required
date).
In
addition,
beginning
in
the
Summer
of
2004
training
providers
may
provide
electronic
submissions
using
the
Agency's
CDX
system.
The
CDX
system
provides
secure
internet
based
electronic
submission
of
data
to
the
Agency.

(
i)
Data
Items
Page
6
of
24
The
notice
should
include
the
following:

°
Training
program
name,
EPA
accreditation
number,
address,
and
phone
number;
°
Course
discipline
and
type
(
initial/
refresher);
°
Date(
s)
of
training;
°
The
following
information
for
each
student
who
took
the
course:

S
Name
S
Address
S
Date
of
birth
S
Course
completion
certificate
number
S
Student
test
score;
and
S
Training
manager's
name
and
signature.

(
ii)
Respondent
Activities
As
required
by
Section
745.225(
c)(
14)
training
providers
must:

°
Provide
the
Agency
notice
of
the
completion
of
all
lead­
based
paint
activities
courses
offered.

Notification
of
Lead­
Based
Paint
Abatement
Activities
By
Lead
Abatement
Firms
(
745.227(
e)(
4))

As
required
under
Section
745.227(
e)(
4),
certified
firms
must
notify
EPA
of
lead­
based
paint
abatement
activities
at
least
five
(
5)
business
days
prior
to
beginning
lead­
based
paint
abatement
activities.
In
the
case
of
abatement
activities
required
in
response
to
an
elevated
blood
lead
level
determination
or
a
Federal,
State,
Tribal,
or
local
emergency
abatement
order,
the
notice
should
be
submitted
to
the
Agency
not
later
than
the
day
lead­
based
paint
abatement
activities
begin.
Firms
must
submit
an
updated
notice:
(
1)
at
least
five
business
days
before
the
revised
start
date,
if
the
start
date
is
moved
up,
(
2)
on
or
before
the
project
start
date
if
the
abatement
activities
are
delayed,
(
3)
at
least
five
business
days
before
the
original
project
start
date
if
the
course
location
has
changed,
and
(
4)
on
or
before
the
project
start
date,
if
the
project
is
canceled
or
significantly
changed.

As
required
by
Section
745.227(
e)(
4),
providers
shall
notify
the
Agency
by
written
notice.
Written
notification
of
lead­
based
paint
activities
course
schedules
can
use
either
the
sample
form,
entitled
"
Lead­
Based
Paint
Activities
Training
Course
Follow­
Up"
or
a
similar
form
developed
by
the
training
program
containing
the
required
information.
All
written
notices
shall
be
delivered
by
the
U.
S.
Postal
Service,
fax,
commercial
delivery
service,
or
hand
delivery
(
Persons
submitting
notification
by
U.
S.
Postal
Service
are
reminded
that
they
should
allow
three
additional
business
days
for
delivery
in
order
to
ensure
that
the
Agency
receives
the
notification
by
the
required
date).
In
addition,
beginning
in
the
Summer
of
2004
certified
firms
may
provide
electronic
submissions
using
the
Agency's
CDX
system.
The
CDX
system
provides
secure
internet
based
electronic
submission
of
data
to
the
Agency.

(
i)
Data
Items
Notices
submitted
under
Section
745.227(
e)(
4)
should
include
the
following
information:
Page
7
of
24
°
Notification
type
(
Original,
Updated,
Cancellation);
°
Date
when
lead­
based
paint
abatement
activities
will
start;
°
Date
when
lead­
based
paint
abatement
activities
will
end
(
approximation
using
best
professional
judgement);
°
Firm's
name,
EPA
certification
number,
address,
and
phone
number;
°
Type
of
building
(
e.
g.
single
family
dwelling,
multi­
family
dwelling,
child­
occupied
facilities)
on/
in
which
abatement
work
will
be
performed;
°
Property
name
(
if
applicable);
°
Property
address
including
apartment
or
unit
number
(
if
applicable)
for
abatement
work;
°
Documentation
showing
evidence
of
an
EBL
determination
or
a
copy
of
the
Federal/
State/
Tribal/
Local
emergency
abatement
order,
if
applicable;
°
Name
and
EPA
certification
number
of
the
project
supervisor;
°
Approximate
square
footage/
acreage
to
be
abated;
°
Brief
description
of
abatement
activities
to
be
performed;
and
°
Name,
title,
and
signature
of
the
representative
of
the
certified
firm
who
prepared
the
notification.

Additionally,
if
the
abatement
activity
utilizes
the
abbreviated
notification
period
allowable
for
activities
required
in
response
to
an
Elevated
Blood
Lead
Level
determination
or
a
Federal,
State,
Tribal,
or
local
emergency
abatement
order,
the
notice
must
contain
documentation
showing
evidence
of
an
EBL
determination
or
a
copy
of
the
Federal/
State/
Trial/
Local
emergency
abatement
order.

(
ii)
Respondent
Activities
As
required
by
Section
745.227(
e)(
4),
firms
notifying
the
Agency
must
perform
the
following
activities:

°
Provide
notification
to
the
Agency
of
all
lead­
based
paint
abatement
activities;
°
Update
the
Agency
regarding
any
changes
to
project
start
dates,
project
cancellations,
or
significant
project
changes.

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
will
perform
the
following
activities
in
response
to
the
submittals
required
by
this
rule:

°
Receive,
review,
and
file
initial
notices
and
updates
received
from
training
providers;
°
Receive,
review,
and
file
course
completion
notices
received
from
training
providers;
and
°
Receive,
review,
and
file
notices
of
abatement
activities
from
lead
abatement
firms.

5(
b)
Collection
Methodology
and
Management
Page
8
of
24
For
purposes
of
this
regulation,
the
Agency
will
make
use
of
existing
technology
to
simplify
the
lead­
based
paint
abatement
and
training
notification
process.
Therefore,
in
addition
to
the
more
traditional
notification
methods
(
mail,
commercial
delivery
service,
or
hand
delivery)
the
Agency
will
allow
fax,
and
internet
based
submission
of
notifications
via
the
Agency's
CDX
system.

The
Environmental
Protection
Agency
is
establishing
a
single
portal
on
the
Web
for
environmental
data
entering
called
CDX.
Beginning
in
the
Summer
of
2004
the
Agency
will
accept
abatement
and
training
program
notifications
through
this
system.
CDX
offers
a
faster,
easier,
more
secure
reporting
option.
CDX
provides
built­
in
data
quality
checks,
web
forms,
standard
file
formats,
and
a
user
friendly
approach
to
reporting
data.

CDX
Helps
Reporting
Entities
By:

°
Reducing
their
reporting
burden
and
associated
costs.
°
Enabling
automated,
machine
to
machine
transactions
eliminating
tedious
paper
forms
and
redundant
data
entry.
°
Ensuring
a
secure
electronic
environment.
°
Improving
data
quality
through
built­
in
edit
and
data
quality
checks.
°
Offering
faster,
easier
click­
and­
send
reporting
with
one
consistent
point
of
entry
for
reporting,
one
streamlined
set
of
procedures,
and
one
password.
°
Confirming
EPA's
receipt
of
their
data.
°
Translating
and
distributing
incoming
data
to
the
appropriate
data
system.

CDX
Helps
EPA
By:

°
Centralizing
receipt,
security,
user
authentication,
archiving,
translation,
distribution
and
related
user
support
services
for
incoming
data.
°
Eliminating
redundant
infrastructure
and
its
associated
cost.
°
Enabling
the
Agency
to
streamline
and
simplify
compliance
reporting
for
everyone.

The
Agency
also
considered
telephone
notification
and
found
it
inappropriate
because
it
would
increase
administrative
burden,
and
would
be
less
reliable
due
to
inherent
problems
associated
with
transcribing
verbal
information.
Therefore,
the
Agency
does
not
intend
to
allow
telephone
notification.

5(
c)
Small
Entity
Flexibility
The
Agency
has
attempted
to
ensure
that
its
regulatory
requirements
do
not
unduly
burden
small
business.
The
notification
requirements
are
very
simple.
A
firm
need
only
notify
the
Agency
that
it
is
commencing
lead­
based
paint
abatement
activities
and
that
it
will
comply
with
the
required
standards.

5(
d)
Collection
Schedule
The
Agency
believes
that
receipt
of
notification
five
and
seven
business
days
respectively
prior
to
conducting
lead­
based
paint
abatement
activities
or
training
courses
is
necessary
to
facilitate
the
inspection
of
abatement
and
training
locations.
The
regulation
also
includes
provisions
for
updating
the
original
notification.
The
Agency
determined
that
the
time
periods
for
Page
9
of
24
initial
notification
willalso
apply
to
a
change
in
course
location,
or
if
the
course
is
to
be
presented
earlier
than
described
in
the
original
notification.
Other
changes,
including
cancellation
of
courses
or
abatement
projects,
need
only
be
received
by
the
Agency
at
least
two
business
days
before
a
training
course
is
scheduled
to
begin,
or
by
the
start
date
of
an
abatement
activity.
Such
notification
periods
are
appropriate
to
allow
proper
allocation
of
EPA
compliance
monitoring
and
enforcement
resources,
and
to
prevent
the
arrival
of
Agency
personnel
at
the
wrong
location
or
time.

6.
Estimating
the
Burden
and
Cost
This
section
estimates
the
incremental
burden
of
reporting
and
recordkeeping
for
the
notification
requirements
in
§
§
402
(
a)
and
404
of
TSCA.
The
burden
estimates
in
this
amendment
are
offered
in
addition
to
those
previously
submitted
for
reporting
and
recordkeeping
in
the
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement.
The
notification
burden
estimates
in
this
amendment
are
based
on
personal
communications
with
lead­
based
paint
abatement
firms
in
the
state
of
Massachusetts,
which
currently
has
notification
regulations
similar
to
those
proposed
by
EPA,
as
well
as
personal
communications
with
training
providers
and
states
which
are
implementing
similar
programs.

The
number
of
entities
in
state
programs
subject
to
the
proposed
requirement
were
derived
from
the
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.
The
number
of
entities
in
states
with
EPAadministered
programs
subject
to
the
proposed
requirement
are
based
on
actual
data
collected
by
EPA
for
the
period
through
March
20,
2002.
The
events
per
entity
estimates
were
taken
from
the
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.
Burden
and
cost
estimates
are
provided
for
three
calender
years
2002,
2003,
and
2004.

Sections
6(
a)
and
6(
b)
discuss
the
respondents'
notification
burdens
and
costs,
respectively.
Section
6(
c)
reports
EPA
burdens
and
costs,
and
sections
6(
d)
through
6(
f)
provide
summaries
of
the
respondents'
burdens,
and
provide
the
Federal
Register
burden
statement.

EPA
published
the
final
402/
404
rule
on
August
29,
1996.
States
and
tribes
could
begin
applying
for
authorization
to
operate
their
own
lead­
based
paint
training
and
certification
programs
on
October
28,
1996.
On
August
31,
1998,
EPA
began
operating
the
Federal
program
in
all
non­
authorized
States
and
Tribes.
There
was
an
additional
phase­
in
of
elements
of
the
Federal
program
to
allow
the
regulated
community
to
come
into
compliance.
The
accreditation
requirements
became
effective
on
March
1,
1999,
and
all
training
providers
must
now
be
accredited
by
EPA
to
offer
lead­
based
paint
activities
training
courses
in
the
Federal
program.
The
final
rule
also
stated
that
after
August
30,
1999,
no
individuals
or
firms
could
perform,
offer,
or
claim
to
perform
lead­
based
paint
activities
without
certification
from
EPA.
However,
several
unavoidable
delays
slowed
the
process
of
approving
a
sufficient
number
of
training
providers
to
accommodate
the
number
of
individuals
who
would
be
seeking
certification
prior
to
the
August
30,
1999
date.
Therefore,
on
August
6,
1999,
EPA
extended
the
effective
date
for
certification
of
individuals
and
firms
and
use
of
work
practice
standards
to
March
1,
2000
(
64
FR
42849).

EPA
is
now
establishing
notification
procedures
for
lead
abatement
firms
seeking
to
conduct
lead­
based
paint
activities,
and
training
providers
offering
lead­
based
paint
activities
Page
10
of
24
1Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule
2Personal
communications
with
Training
Providers
courses.
Under
these
regulations
firms
will
be
required
to
submit
a
pre­
abatement
notification
at
least
5
days
prior
to
the
start
of
lead­
based
paint
activities.
Lead­
based
paint
training
providers
will
be
required
to
submit
pre­
course
notification
at
least
7
days
prior
to
the
start
of
lead­
based
paint
activity
courses
and
post­
course
notification
within
10
days
of
course
completion.

6(
a)
Estimating
Respondent
Burden
Introduction
Three
types
of
respondents
will
be
affected
by
this
information
collection
request
(
ICR):
1)
training
providers,
2)
firms
performing
lead­
based
paint
activities,
and
3)
states.
The
burden
and
cost
associated
with
notification
are:
1)
reporting
during
the
course
of
the
year
and
2)
recordkeeping
during
the
course
of
the
year.
The
reporting
and
recordkeeping
burden
estimates
include
the
time
associated
with
completing
and
sending
the
notification
forms
to
the
appropriate
authority,
as
well
as
the
time
required
to
collect
the
information
needed
to
complete
the
form.
The
recordkeeping
burden
estimates
include
the
time
required
for
the
respondent
to
copy
and
file
a
record
of
the
notification
form.
In
addition
some
states
and
the
federal
government
will
be
affected
in
their
role
as
administrators
of
the
notification
requirement.

Training
Providers
Pre­
course
notification
will
be
required
at
least
7
business
days
prior
to
the
start
of
a
leadbased
paint
activities
course.
Re­
notification
will
be
required
if
the
course
date
changes.
Within
10
days
of
course
completion,
training
providers
will
be
required
to
submit
a
post­
course
notification.
The
information
training
providers
will
be
required
to
submit
during
pre­
course
and
post­
course
notification
is
detailed
in
section
4
of
this
document.
The
following
sections
discuss
how
the
reporting
and
recordkeeping
burden
estimates
in
this
analysis
were
developed.
Exhibit
6.1.
presents
the
estimation
of
training
provider
burden
for
the
proposed
notification
rule.

Reporting
This
analysis
assumes
that
training
providers
will
complete
a
separate
notification
form
for
each
lead­
based
paint
activity
course
conducted.
The
number
of
pre­
course
and
post­
course
notification
events
was
estimated
by
dividing
the
total
number
of
students
in
a
given
year1
by
an
estimated
average
class
size2
to
obtain
the
estimated
number
of
courses.
According
to
training
providers
and
abatement
firms,
contacted
during
the
data
collection
phase
of
this
analysis,
currently
some
notification
programs
require
pre­
course
notification
for
each
individual
course,
while
other
programs
allow
training
providers
to
submit
a
list
of
the
courses
they
plan
to
offer
during
the
coming
year.
This
analysis
conservatively
assumes
one
pre­
course
and
one
post­
course
notification
for
each
training
course.
In
addition,
some
courses
may
require
re­
notification.
Training
providers
and
state
program
representatives
contacted
said
that
re­
notification
does
occur.
However,
they
were
not
able
to
estimate
a
re­
notification
rate.
Therefore,
this
analysis
has
adopted
a
re­
notification
rate
of
10
percent.
An
estimate
of
the
amount
of
time
required
to
complete
the
pre­
course
and
post­
course
notification
forms,
described
in
section
4
of
this
Page
11
of
24
document,
was
determined
by
calling
a
sample
of
training
providers
distributed
across
the
U.
S..
The
number
of
training
providers
in
states
with
programs
was
adopted
from
the
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.
The
number
of
training
providers
in
states
with
EPA­
administered
programs
is
based
on
actual
data
collected
by
EPA
through
March
20,
2002.
A
distribution
of
burden
between
training
providers
in
EPA
administered
programs
and
training
providers
in
state
administered
programs
was
developed
using
estimates
from
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement.

Recordkeeping
The
training
provider
burden
estimates
described
above
includes
the
burden
associated
with
filing
a
one
page
record
of
the
notification
form
sent
to
the
administering
agency.
An
estimate
of
the
amount
of
time
needed
to
file
a
record
was
adopted
from
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.

Annual
Burden
Hours
As
presented
below
in
Exhibit
6.1.,
this
amendment
estimates
the
notification
burden
for
all
training
providers
in
the
calender
year
2002
to
be
hours.
In
calender
year
2003
the
notification
burden
for
all
training
providers
drops
to
hours,
due
to
the
initial
surge
of
course
offerings
having
passed,
and
remains
at
this
level
in
calender
year
2004.

Exhibit
6.1.
Training
Providers:
Notification
Burden
Estimates
Category
Events
per
Training
Provider
Reporting
Hours/
Event
Recordkeeping
Hours/
Event
Total
Hours/
Event
2002
2003
2004
Notification
Pre­
notification
8.72
1.97
1.97
0.15
0.01
0.16
Re­
notification
0.87
0.20
0.20
0.15
0.01
0.16
Post­
notification
8.72
1.97
1.97
1.54
0.01
1.54
Annual
Total
18.32
4.14
4.14
Burden
Hours
per
Training
Provider
2002
2003
2004
14.98
3.39
3.39
Training
Providers
per
Year
State
Administered
EPA
Administered
2002
2003
2004
2002
2003
2004
126
126
126
39
39
39
Total
Burden
Hours
per
Year
2002
2003
2004
2,471
559
559
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis;
Personal
Communications
with
Training
Providers;
and
EPA
data
collection.
Page
12
of
24
3Personal
communications
with
Massachusetts
firms
Firms
Pre­
abatement
notification
will
be
required
at
least
5
business
days
prior
to
the
start
of
lead­
based
paint
abatement
activities.
Re­
notification
will
be
required
if
the
start
date
or
end
date
of
the
abatement
activity
changes.
Firms
are
not
required
to
provide
notification
after
the
completion
of
an
abatement
project.
The
information
firms
will
be
required
to
submit
during
preabatement
notification
is
detailed
in
section
4
of
this
document.
The
following
sections
discuss
how
the
reporting
and
recordkeeping
burden
estimates
in
this
analysis
were
developed.
Exhibit
6.2.
presents
the
estimation
of
firm
burden
for
the
proposed
notification
rule.

Reporting
This
analysis
assumes
that
firms
will
complete
a
separate
notification
form
for
each
leadbased
paint
abatement
activity
conducted.
The
number
of
pre­
abatement
notification
events
was
adopted
from
the
TSCA
Title
V
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis.
The
number
of
re­
notifications
was
calculated
using
a
re­
notification
rate
of
9
percent3.
An
estimate
of
the
amount
of
time
required
to
complete
the
pre­
abatement
notification
form,
described
in
section
4
of
this
document,
was
determined
by
calling
a
sample
of
firms
in
the
state
of
Massachusetts.
The
number
of
firms
in
states
with
programs
was
adopted
from
the
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.
The
number
of
firms
in
states
with
EPAadministered
programs
is
based
on
actual
data
collected
by
EPA
through
March
20,
2002.
A
distribution
of
burden
between
firms
in
EPA
administered
programs
and
firms
in
state
administered
programs
was
developed
using
estimates
from
the
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement.

Recordkeeping
The
firm
burden
estimates
described
above
include
the
burden
associated
with
filing
a
one
page
record
of
the
notification
form
sent
to
the
administering
agency.
An
estimate
of
the
amount
of
time
needed
to
file
a
record
was
adopted
from
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.

Annual
Burden
Hours
As
presented
below
in
Exhibit
6.2.,
this
amendment
estimates
the
notification
burden
for
all
firms
in
the
calender
year
2002
to
be
hours.
The
notification
burden
for
all
firms
is
estimated
to
remain
at
this
level
during
calender
years
2003
and
2004.

Exhibit
6.2.
Firms:
Notification
Burden
Estimates
Category
Events
per
Firm
Reporting
Hours/
Event
Recordkeeping
Hours/
Event
Hours
per
Firm
Notification
Pre­
notification
14.09
0.22
0.01
3.23
Page
13
of
24
Re­
notification
1.27
0.22
0.01
0.29
Annual
Total
15.36
0.22
0.01
3.52
Firms
per
Year
State
Administered
EPA
Administered
2002
2003
2004
2002
2003
2004
2,902
2,902
2,902
833
833
833
Total
Burden
Hours
per
Calender
Year
2002
2003
2004
13,153
13,153
13,153
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis;
Personal
Communications
with
Firms;
and
EPA
data
collection.

State
Burden
Notifications
submitted
by
training
providers
and
abatement
firms
will
be
used
by
states
with
authorized
programs
in
support
of
compliance
monitoring
and
enforcement
activities,
and
to
prioritize
inspections.
The
administrative
management
of
information
collected
under
this
proposed
rule
is
detailed
in
section
4
of
this
document.
The
following
sections
discuss
how
the
recordkeeping
burden
estimates
were
developed.
Exhibit
6.3.
presents
the
estimation
of
state
burden
for
the
proposed
notification
rule.

Recordkeeping
The
number
of
notification
events
per
entity
are
the
sum
of
pre­
course,
post­
course,
and
re­
notifications
submitted
by
training
providers,
and
the
sum
of
pre­
abatement
and
re­
notifications
submitted
by
firms.
The
sources
of
this
information
are
discussed
in
detail
in
the
respective
training
provider
and
firm
sections
of
this
analysis.
The
state
recordkeeping
burden
per
notification
event
is
estimated
at
0.11
hours
for
training
providers
and
0.09
hours
for
abatement
firms.
Both
estimates
were
obtained
by
contacting
two
state
agencies,
which
currently
operate
similar
lead­
based
paint
training
programs,
and
maintain
lead­
based
paint
activity
notification
records
in
both
electronic
and
hardcopy
forms.
The
number
of
entities
administered
by
state
programs
was
adopted
from
the
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement.

Annual
Burden
As
presented
below
in
Exhibit
6.3.,
this
amendment
estimates
the
notification
recordkeeping
burden
for
all
states
in
the
calender
year
2002
to
be
hours.
The
notification
recordkeeping
burden
for
all
states
is
estimated
to
drop
slightly
to
hours
during
calender
year
2003,
due
to
a
drop
in
training
provider
notifications,
and
remain
at
this
level
during
calender
year
2004.

Exhibit
6.3.
State:
Notification
Burden
Estimates
Category
Notifications
per
Entity
Clerical
Hours/
Notification
Page
14
of
24
4
EPA
used
2000
wage
rates,
inflated
to
2002
dollars.
The
wage
rates
will
be
updated
when
this
burden
is
incorporated
into
the
base
ICR,
which
is
scheduled
to
be
renewed
in
2004,
and
which
will
begin
that
process
at
the
end
of
2003.
2002
2003
2004
Firms
15.36
15.36
15.36
0.09
Training
Providers
18.32
4.14
4.14
0.11
Entities
per
Year
2002
2003
2004
Firms
2,902
2,902
2,902
Training
Providers
126
126
126
Burden
Hours
per
Year
2002
2003
2004
Firms
4,086
4,086
4,086
Training
Providers
250
57
57
Total
Burden
4,336
4,142
4,142
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis.

6(
b)
Estimating
Respondent
Costs
Introduction
The
cost
estimates
addressed
in
this
section
are
based
on
the
burden
estimates
discussed
in
section
6(
a).
Wage
rates
for
each
category
of
non­
government
personnel
are
based
on
wage
rate
information
from
the
Bureau
of
Labor
Statistics
(
BLS),
while
wage
rates
for
each
category
of
government
personnel
were
taken
from
the
Office
of
Personnel
Management.

All
wage
rates
are
reported
in
2002
US
dollars.
The
sum
of
this
amendment
and
the
previous
ICR
may
be
found
in
Section
6(
c)
of
this
document.
The
following
fringe
and
overhead
factors
from
the
fees
rule
and
the
Comprehensive
Assessment
Information
Rule
(
CAIR)
were
applied:

­
Government
Employees:
1.6
(
fees
rule)
­
Clerical
Non­
government:
1.66
(
CAIR).

The
following
table
presents
the
wage
rates
used
in
this
analysis
including
fringe
and
overhead
(
2002
US
dollars)
4:

Clerical
B
non­
government
(
BLS
Administrative
Support,
including
Clerical)

Page
15
of
24

Inflated
from
2000
US
dollars
to
2002
US
dollars
using
the
GDP
inflator.

Training
Providers
Based
on
occupational
descriptions
accompanying
the
BLS
data,
the
BLS
occupational
wage
rate
for
Administrative
Support,
including
Clerical
was
chosen
to
calculate
the
clerical
labor
costs.
The
wage
rate
was
updated
using
the
GDP
inflator
and
multiplied
by
the
overhead
and
fringe
factor
of
1.66
for
clerical
staff.
The
final
loaded
wage
rate
is
for
clerical
staff.
Additionally,
training
provider
costs
include
a
$
0.08
postage
stamp
for
mailing
the
notification
and
$
0.05
for
a
one
page
copy
of
the
notification
for
the
firm's
records.
The
postage
and
copy
costs
were
adjusted
for
EPA's
rule
amendment
that
now
allows
faxed
and
e­
mailed
notifications
to
serve
as
sufficient
forms
of
notification
to
EPA.
The
analysis
assumes
that
50%
of
training
providers
will
notify
via
fax
(
and
so
would
not
need
to
mail
or
copy),
25%
would
utilize
the
CDX
electronic
notification,
and
25%
would
notify
by
mail.

Annual
Costs
As
presented
below
in
Exhibit
6.4.,
based
on
the
burden
estimates
provided
in
section
6(
a)
and
the
wage
rates
discussed
above,
this
amendment
estimates
the
notification
costs
for
all
training
providers
in
the
calender
year
2002
at
,
due
to
the
initial
surge
of
course
offerings
having
passed,
and
remains
at
this
level
in
calender
year
2004.
Page
16
of
24
Exhibit
6.4.
Training
Providers:
Notification
Cost
Estimates
Category
Events
per
Training
Provider
Reporting
Cost/
Event
Recordkeeping
Cost/
Event
Materials
Cost/
Event
Total
Cost/
Event
2002
2003
2004
Notification
Pre­
notification
8.72
1.97
1.97
$
3.18
$
0.18
$
0.13
$
3.49
Re­
notification
0.87
0.20
0.20
$
3.18
$
0.18
$
0.13
$
3.49
Post­
notification
8.72
1.97
1.97
$
32.88
$
0.18
$
0.13
$
33.18
Cost
per
Training
Provider
2002
2003
2004
$
322.88
$
73.06
$
73.06
Training
Providers
per
Year
State
Administered
EPA
Administered
2002
2003
2004
2002
2003
2004
126
126
126
39
39
39
Total
Cost
per
Year
2002
2003
2004
$
53,275
$
12,055
$
12,055
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis;
Personal
Communications
with
Training
Providers;
and
EPA
data
collection.

Firms
Performing
Lead­
based
Paint
Activities
Costs
Based
on
occupational
descriptions
accompanying
the
BLS
data,
the
BLS
occupational
wage
rate
for
Administrative
Support,
including
Clerical
was
chosen
to
calculate
the
clerical
labor
costs.
The
wage
rate
was
updated
using
the
GDP
inflator
and
multiplied
by
the
overhead
and
fringe
factor
of
1.66
for
clerical
staff.
The
final
loaded
wage
rate
is
for
clerical
staff.
Additionally,
training
provider
costs
include
a
$
0.08
postage
stamp
for
mailing
the
notification
and
$
0.05
for
a
one
page
copy
of
the
notification
for
the
firm's
records.
The
postage
and
copy
costs
were
adjusted
for
EPA's
rule
modification
that
now
allows
faxed
and
emailed
notifications
to
serve
as
sufficient
forms
of
notification
to
EPA.
The
analysis
assumes
that
50%
of
firms
will
notify
via
fax
(
and
so
would
not
need
to
mail
or
copy),
25%
would
utilize
the
CDX
electronic
notification,
and
25%
would
notify
by
mail.

Annual
Costs
As
presented
below
in
Exhibit
6.5.,
based
on
the
burden
estimates
provided
in
section
6(
a)
and
the
wage
rates
discussed
above,
this
amendment
estimates
the
costs
associated
with
notification
for
all
firms
in
the
calender
year
2002
at
The
notification
cost
for
all
firms
is
estimated
to
remain
at
this
level
during
calender
years
2003
and
2004.
Page
17
of
24
Exhibit
6.5.
Firms:
Notification
Cost
Estimates
Cost
Element
Events
per
Firm
Reporting
Cost/
Event
Recordkeeping
Cost/
Event
Materials
Cost/
Event
Cost
per
Firm
Notification
Pre­
notification
14.09
$
4.73
$
0.18
$
0.13
$
70.95
Re­
notification
1.27
$
4.73
$
0.18
$
0.13
$
6.39
Annual
Total
15.36
$
4.73
$
0.18
$
0.13
$
77.33
Firms
per
Year
State
Administered
EPA
Administered
2002
2003
2004
2002
2003
2004
2,902
2,902
2,902
833
833
833
Total
Cost
per
Calender
Year
2002
2003
2004
$
288,830
$
288,830
$
288,830
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis;
Personal
Communications
with
Firms;
and
EPA
data
collection.

State
Costs
The
notification
costs
are
based
on
the
burden
estimated
in
Section
6(
a)
and
the
following
wage
rate
information.
The
wage
rate
used
to
calculate
the
state
costs
for
the
relevant
GS
level
personnel
was
taken
from
the
Office
of
Personnel
Management.
The
final
loaded
wage
rate
is
for
clerical
staff.

Annual
Costs
As
presented
below
in
Exhibit
6.6.,
this
amendment
estimates
the
notification
cost
for
all
states
combined
in
the
calender
year
2002
to
be
.
The
notification
cost
for
all
states
is
estimated
to
drop
slightly
to
during
calender
year
2003,
due
to
a
drop
in
training
provider
notifications,
and
remain
at
this
level
during
calender
year
2004.

Exhibit
6.6.
State:
Notification
Cost
Estimates
for
All
States
Combined
Category
Notifications
per
Firm
Clerical
Cost/
Notification
2002
2003
2004
Firms
15.36
15.36
15.36
$
1.78
Training
Providers
18.32
4.14
4.14
$
2.10
Entities
per
Year
2002
2003
2004
Firms
2,902
2,902
2,902
Training
Providers
126
126
126
Cost
per
Year
Page
18
of
24
2002
2003
2004
Firms
$
79,357
$
79,357
$
79,357
Training
Providers
$
4,856
$
1,099
$
1,099
Total
Burden
$
84,213
$
80,456
$
80,456
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis.

6(
c)
Estimating
Agency
Burden
and
Cost
Agency
Burden
Under
the
proposed
rule,
notifications
submitted
by
training
providers
and
abatement
firms
would
be
used
by
EPA
regions
in
support
of
compliance
monitoring
and
enforcement
activities,
and
to
prioritize
inspections.
The
administrative
management
of
information
collected
under
this
regulation
is
detailed
in
section
4
of
this
document.
The
following
sections
discuss
how
the
recordkeeping
burden
estimates
were
developed.
Exhibit
6.7.
presents
the
estimation
of
state
burden
for
the
final
notification
rule.

Recordkeeping
The
number
of
notification
events
per
entity
are
the
sum
of
pre­
course,
post­
course,
and
re­
notifications
submitted
by
training
providers,
and
the
sum
of
pre­
abatement
and
re­
notifications
submitted
by
firms.
The
sources
of
this
information
are
discussed
in
detail
in
the
respective
training
provider
and
firm
sections
of
this
analysis.
The
EPA
recordkeeping
burden
per
notification
event
is
estimated
at
0.11
hours
for
training
providers
and
0.09
hours
for
abatement
firms.
Both
estimates
were
obtained
by
contacting
two
state
agencies,
which
currently
operate
similar
lead­
based
paint
training
programs,
and
maintain
lead­
based
paint
activity
notification
records
in
both
electronic
and
hardcopy
forms.
The
number
of
entities
administered
by
states
with
EPA­
administered
programs
was
taken
from
actual
data
collected
by
EPA
through
March
20,
2002.

Annual
Burden
As
presented
below
in
Exhibit
6.7.,
this
amendment
estimates
the
notification
recordkeeping
burden
for
EPA
in
the
calender
year
2002
to
be
hours
during
calender
year
2003,
due
to
a
drop
in
training
provider
notifications,
and
remain
at
this
level
during
calender
year
2004.

Exhibit
6.7.
EPA:
Notification
Burden
Estimates
Category
Notifications
per
Entity
Clerical
Hours/
2002
2003
2004
Notification
Firms
15.36
15.36
15.36
0.09
Training
Providers
18.32
4.14
4.14
0.11
Page
19
of
24
Entities
per
Year
2002
2003
2004
Firms
833
833
833
Training
Providers
39
39
39
Burden
Hours
per
Year
2002
2003
2004
Firms
1,173
1,173
1,173
Training
Providers
77
18
18
Total
Burden
1,250
1,190
1,190
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis;
and
EPA
data
collection.

Agency
Cost
The
notification
costs
are
based
on
the
burden
estimated
in
Section
6(
a)
and
the
following
wage
rate
information.
The
wage
rate
used
to
calculate
the
EPA
costs
for
the
relevant
GS
level
personnel
was
taken
from
the
Office
of
Personnel
Management.
The
final
loaded
wage
rate
is
for
clerical
staff.

Annual
Cost
As
presented
below
in
Exhibit
6.8.,
this
amendment
estimates
the
notification
cost
for
EPA
in
the
calender
year
2002
to
be
der
year
2003,
due
to
a
drop
in
training
provider
notifications,
and
remain
at
this
level
during
calender
year
2004.

Exhibit
6.8.
EPA:
Notification
Cost
Estimates
Category
Notifications
per
Firm
Clerical
Cost/
Notification
2002
2003
2004
Firms
15.36
15.36
15.36
$
1.99
Training
Providers
18.32
4.14
4.14
$
2.35
Entities
per
Year
2002
2003
2004
Firms
833
833
833
Training
Providers
39
39
39
Cost
per
Year
2002
2003
2004
Firms
$
25,406
$
25,406
$
25,406
Training
Providers
$
1,676
$
379
$
379
Total
Annual
Burden
$
27,082
$
25,785
$
25,785
Note(
s):
numbers
may
not
calculate
due
to
rounding
Source(
s):
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule;
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis;
and
EPA
data
collection.
Page
20
of
24
6(
d)
Bottom
Line
Burden
Hours
and
Cost
(
I)
Respondent
Burden/
Cost
2002
2003
2004
Burden
Hours
Costs
Burden
Hours
Costs
Burden
Hours
Costs
Notification
Amendment
Training
Providers
2,471
$
53,275
559
$
12,055
559
$
12,055
Firms
13,153
$
288,830
13,153
$
288,830
13,153
$
288,830
States
4,336
$
84,213
4,142
$
80,456
4,142
$
80,456
Notification
Amendment
Total
19,960
$
426,319
17,854
$
381,341
17,854
$
381,341
Previously
Estimated
4
Training
Providers
1,620
$
49,290
218
$
5,639
218
$
5,639
Firms
308,106
$
11,667,375
282,867
$
10,839,548
282,867
$
10,839,548
Individuals
14,188
$
468,366
3,053
$
98,494
3,053
$
98,494
States
99,734
$
3,262,687
19,025
$
612,956
19,025
$
612,956
Previously
Estimated
Total
423,648
$
15,447,718
305,164
$
11,556,637
305,164
$
11,556,637
Amended
Respondent
Total
Training
Providers
4,091
$
102,565
777
$
17,694
777
$
17,694
Firms
321,260
$
11,956,205
296,020
$
11,128,378
296,020
$
11,128,378
Individuals
15,180
$
430,661
3,234
$
90,548
3,234
$
90,548
States
104,070
$
3,346,900
23,167
$
693,412
23,167
$
693,412
New
Total
(
Previously
estimated
+
amendment)
444,600
$
15,836,331
323,199
$
11,930,032
323,199
$
11,930,032
4
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement,
Section
6(
d),
Table
(
I).
Page
21
of
24
(
II)
Agency
Burden/
Cost
2002
2003
2004
Burden
Hours
Costs
Burden
Hours
Costs
Burden
Hours
Costs
Notification
Amendment
Regions
1,250
$
27,082
1,190
$
25,785
1,190
$
25,785
Previously
Estimated
5
Regions
32,270
$
1,052,014
6,593
$
211,809
6,593
$
211,809
Headquarters
728
$
26,183
728
$
26,183
728
$
26,183
Amended
Agency
Total
Regions
33,520
$
1,079,096
7,783
$
237,594
7,783
$
237,594
Headquarters
728
$
26,183
728
$
26,183
728
$
26,183
New
Total
(
Previously
estimated
+
amendment)
34,248
$
1,105,279
8,511
$
263,777
8,511
$
258,737
5
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement,
Section
6(
d),
Table
(
II).

6(
e)
Reasons
for
Change
in
Burden
EPA
is
amending
the
rule
to
include
notification
requirements
for
lead
abatement
firms
and
training
providers.
The
burden
related
to
these
amendments
serve
as
a
program
change
to
the
burden
currently
approved
by
OMB
under
the
existing
ICR.
The
following
is
a
quick
summary
of
the
changes
in
burden
related
to
the
final
notification
rule:

The
respondent
burden
for
the
collection
of
notification
information
in
the
first
effective
year
is
estimated
to
be
2,471
hours
for
the
estimated
165
training
providers,
13,153
hours
for
the
estimated
3,735
firms
performing
lead­
based
paint
activities,
and
4,336
hours
for
the
states.

The
respondent
burden
for
the
collection
of
this
notification
information
in
the
second
effective
year
is
estimated
to
be
559
hours
for
the
estimated
165
training
providers,
13,153
hours
for
the
estimated
3,735
firms
performing
lead­
based
paint
activities,
and
4,142
hours
for
the
states.

6(
f)
Burden
Statement
The
estimates
in
this
addendum
are
in
addition
to
the
previously
estimated
totals
in
the
TSCA
§
§
402/
404
Training,
Certification,
Accreditation,
and
Standards
for
Lead­
Based
Paint
Activities
Information
Collection
Request
Supporting
Statement
which
is
approved
under
OMB
Control
No.
2070­
0155
(
identified
as
EPA
ICR
No.
1715.02).
As
such,
the
amended
burden
statement
for
the
ICR
is
as
follows:

The
annual
public
burden
for
the
collection
of
information
approved
under
OMB
Control
No.
2070­
0155,
is
estimated
to
be
as
follows:

°
For
the
first
effective
year
with
the
notification
amendments,
it
is
estimated
to
4,091
hours
Page
22
of
24
for
the
estimated
165
training
providers,
321,260
hours
for
the
estimated
3,735
firms
performing
lead­
based
paint
activities,
15,180
hours
for
the
14,188
individual
lead
personnel,
and
104,070
hours
for
the
states.

°
For
the
second
effective
year
with
the
notification
amendments,
it
is
estimated
to
be
777
hours
for
the
estimated
165
training
providers,
296,020
hours
for
the
estimated
3,735
firms
performing
lead­
based
paint
activities,
3,234
hours
for
the
14,188
individual
lead
personnel,
and
23,167
hours
for
the
states.

According
to
the
Paperwork
Reduction
Act,
"
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.
For
this
collection
it
includes
the
time
needed
to
review
the
rule
and
applicable
instructions
or
guidance;
the
initial
certification/
accreditation,
and
all
reporting
and
recordkeeping
requirements.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
subject
to
the
PRA
unless
the
Agency
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
in
title
40
of
the
CFR,
after
appearing
in
the
Federal
Register,
are
listed
in
40
CFR
part
9
and
included
on
the
related
collection
instrument
or
form,
if
applicable.

Although
comments
are
not
currently
being
sought
on
this
addendum
ICR,
the
public
is
always
welcomed
to
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques.
Since
EPA
will
be
seeking
comments
shortly
on
the
renewal
of
the
existing
ICR,
which
will
be
revised
to
reflect
this
addendum,
EPA
asks
that
you
first
review
that
revised
ICR
and
then
submit
any
comments
you
have
in
accordance
with
the
instructions
provided
in
that
revised
ICR.
If
you
would
like
to
be
notified
when
the
renewal
is
issued
for
public
comment,
please
e­
mail
your
request
to
the
technical
information
contact
for
the
final
lead
notification
rule,
Mike
Wilson,
National
Program
Chemicals
Division
(
7404T),
Office
of
Pollution
Prevention
and
Toxics,
Environmental
Protection
Agency,
1200
Pennsylvania
Ave.,
N.
W.,
Washington,
DC
20460;
telephone
number:
(
202)
566­
0521;
e­
mail
address:
wilson.
mike@
epa.
gov.

EPA
has
established
a
public
docket
for
the
accompanying
final
rule,
which
includes
a
copy
of
this
ICR
addendum,
under
Docket
ID
No.
OPPT­
2003­
0061,
which
is
available
for
public
viewing
at
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Pollution
Prevention
and
Toxics
Docket
is
(
202)
566­
0280.
An
electronic
version
of
the
public
docket
is
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
OMB
Control
number
2070­
0155
in
any
correspondence
to
OMB.
Page
23
of
24
ATTACHMENTS:

[
NOTE:
Unless
otherwise
noted,
an
electronic
copy
of
the
attachment
is
available
only
as
a
PDF
file.
You
can
still
easily
access
the
electronic
PDF
file
in
the
electronic
version
of
the
public
docket
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Once
in
the
system,
select
"
quick
search,"
then
indicate
that
you'd
like
to
search
by
Docket
and
key
in
the
following
docket
ID
number:
OPPT­
2003­
0061.
Search
the
docket
index
for
the
document
by
the
title
provided
below.]

Attachment
Document
A
Final
Rule
Related
to
this
Addendum
­
"
Lead;
Notification
Requirements
for
Lead­
Based
Paint
Abatement
Activities
and
Training;
Final
Rule"

B
The
Regulation
Before
Amendment:
40
CFR
745
[
The
electronic
copy
for
this
attachment
is
available
through
the
eCFR
cite
at
http://
www.
access.
gpo.
gov/
ecfr/.
You
may
also
access
these
regulations
and
other
related
information
through
EPA's
Lead
Program
website
at
http://
www.
epa.
gov/
opptintr/
lead/
index.
html.]

C
Sample
Notification
Forms/
Formats
1)
Notification
2)
Training
Notification
3)
Post­
Training
Notification
D
Paperwork
Reduction
Act
Notice
[
The
electronic
copy
for
this
attachment
is
available
as
part
of
the
electronic
copy
of
the
ICR's
Supporting
Statement.]

E
Response
to
Comment
Page
24
of
24
Attachment
D
Paperwork
Reduction
Act
Notice
Under
5
CFR
1320.8(
c)(
1),
the
Agency
is
required
to
provide
reasonable
notice
to
potential
respondents
that
informs
them
about
the
information
collection
activity
and
OMB's
approval.
As
such,
pursuant
to
5
CFR
1320.8(
c)(
1)(
i),
the
following
statement
will
be
included
with
each
form,
either
on
the
form,
as
part
of
the
instructions,
or
in
the
cover
letter
or
memorandum
accompanying
the
form,
and,
pursuant
to
5
CFR
1320.8(
c)(
1)(
ii),
the
following
statement
will
be
included
as
a
pop­
up
message
that
the
respondent
will
encounter
before
they
access
the
associated
form(
s)
online
or
be
printed
to
accompany
the
paper
version
of
the
form:

Paperwork
Reduction
Act
Notice:
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0155,
is
estimated
to
be
##
hours
[
the
entry
for
each
form
will
be
inserted
and
fit
within
the
total
burden]
per
response.
This
represents
the
average
burden
for
completing
this
form,
including
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;
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
subject
to
approval
under
the
PRA
unless
it
displays
a
currently
valid
OMB
control
number.

Once
the
notification
forms
are
approved
by
OMB,
the
OMB
Control
number
assigned
to
this
ICR
will
also
be
included
in
the
upper
right
corner
of
the
form,
i.
e.,
"
Approved
under
OMB
Control
No.
2070­
0155;
OMB
Approval
expires
[
insert
ICR
expiration
date]."
