Supporting
Statement
for
a
Request
for
OMB
Review
under
The
Paperwork
Reduction
Act
1
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
Title:
Asbestos­
Containing
Materials
in
Schools
Rule
and
Revised
Asbestos
Model
Accreditation
Plan
Rule
EPA
ICR
No.
1365.07
OMB
Control
No.
2070­
0091
1(
b)
Short
Characterization
This
ICR
addresses
reporting
and
recordkeeping
requirements
found
in
the
Asbestos­
Containing
Materials
in
Schools
Rule
("
AHERA
Rule")
and
the
Asbestos
Model
Accreditation
Plan
(
MAP)
Rule.

AHERA
Rule:
Under
Section
203
of
the
Asbestos
Hazard
Emergency
Response
Act
(
AHERA,
15
U.
S.
C.
2641­
2656)
(
see
Attachment
A),
EPA
was
required
to
finalize
the
Asbestos­
Containing
Materials
in
Schools
Rule.
This
rule
required
Local
Education
Agencies
(
LEAs)
to
conduct
inspections,
develop
management
plans,
and
design
or
conduct
response
actions.
Records
must
be
maintained
by
all
LEAs
on
inspections
and
response
action
activity,
and
current
management
plans
must
be
provided
upon
request
to
EPA
and
State
reviewers
for
examination.

MAP:
Additionally,
Section
206
of
AHERA
(
see
Attachment
B)
required
that
EPA
issue
a
Model
Accreditation
Plan
(
MAP)
for
persons
who
inspect
for
asbestos,
develop
management
plans,
and
design
or
conduct
response
actions.
States
are
required
to
adopt
an
accreditation
program
at
least
as
stringent
as
the
EPA
model.
In
1990,
EPA
was
required
to
make
certain
changes
in
its
original
Model
Accreditation
Plan.
Accreditation
of
laboratories
that
analyze
asbestos
bulk
samples
and
asbestos
air
samples
is
also
required
by
AHERA.
The
National
Institute
of
Standards
and
Technology
(
NIST)
was
required
to
establish
the
bulk
sampling
accreditation
program,
and
the
air
sampling
program.

This
information
collection
activity
will
assure
that
LEAs
continue
to
inspect
for
asbestos
and
update
management
plans
with
accredited
personnel
to
protect
all
school
building
occupants
from
exposure
to
asbestos.
This
collection
will
also
assure
that
persons
who
inspect
for
asbestos,
develop
management
plans,
and
design
or
conduct
response
actions
are
properly
accredited,
and
that
states
will
adopt
appropriate
accreditation
programs.
2
2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
AHERA
Rule
and
MAP:
The
reporting
and
recordkeeping
requirements
covered
by
this
ICR
are
required
by
the
Asbestos­
Containing
Materials
in
Schools
Rule
(
40
CFR
763,
Subpart
E)
and
the
Model
Accreditation
Plan
(
40
CFR
763,
Subpart
E,
Appendix
C);
see
Attachments
C
and
D,
respectively.

2(
b)
Use/
Users
of
the
Data
AHERA
Rule:
The
activities
pertaining
to
the
use
of
this
information
collection
activity
help
assure
that
LEAs
continue
to
inspect
for
asbestos
and
update
their
management
plans
using
accredited
personnel.
This
is
intended
to
ensure
the
protection
of
all
school
building
occupants
from
exposure
to
asbestos
fibers.
All
public
and
private
elementary
and
secondary
schools
(
unless
exempt
under
provision
of
the
rule)
were
required
to
conduct
inspections
for
asbestos­
containing
building
materials
(
ACBM)
and
develop
management
plans
that
describe
necessary
actions
to
be
undertaken.
Reinspections
by
accredited
persons
must
take
place
every
three
years
unless
all
ACBM
has
been
removed.
Records
retention
as
part
of
an
updated
asbestos
management
plan
is
necessary
in
order
to
document
specific
response
action
activities
and
periodic
surveillance/
3­
year
reinspection
reports,
and
for
an
LEA
to
demonstrate
compliance
with
the
regulations.
Beneficiaries
of
the
collection
activities
include
the
LEA's
asbestos
program
manager
and
staff,
accredited
professionals
who
may
be
called
upon
to
perform
response
actions
at
a
school,
and
Federal
and
State
enforcement
agencies.

MAP:
This
collection
will
enable
EPA,
as
well
as
State
regulators,
to
determine
initial
compliance
and
to
monitor
continued
compliance
with
the
revised
MAP
standards.
Lacking
both
application
submissions
and
other
recordkeeping
requirements,
regulators
would
have
no
meaningful
way
of
measuring
the
implementation
of
the
MAP's
statutory
mandates.
Other
beneficiaries
of
the
collection
activities
include
1)
individuals
who
may
desire
to
obtain
asbestos
training
meeting
at
least
prescribed
minimum
quality
standards
for
accreditation
and
subsequent
employment
purposes;
2)
LEAs
and
other
building
owners
and
managers
seeking
to
procure
the
services
of
qualified
and
accredited
asbestos
consultants
and
contractors;
and
3)
enforcement
agencies
at
the
Federal
and
State
level.

3
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
AHERA
Rule:
EPA
has
tried
to
identify
alternate
sources
of
the
information
requested
be
maintained
to
implement
and
enforce
this
recordkeeping,
and
was
not
successful.
This
activity
does
not
duplicate
information
already
required
to
be
reported
by
another
agency
or
EPA
program
office.
MAP:
All
of
the
training
and
accreditation
information
collected
pursuant
to
this
ICR
is
specific
to
the
MAP
and
does
not
duplicate
any
other
collection.
There
is
no
other
model
accreditation
plan
for
States
other
than
the
MAP,
and
there
is
no
procedure
for
the
accreditation
of
asbestos
training
programs
under
ASHARA
other
than
what
is
specifically
provided
for
in
the
MAP.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Prior
to
submission
to
OMB,
this
ICR
will
be
made
available
to
the
public
for
comment
through
a
Federal
Register
3
notice.
The
public
will
have
60
days
to
provide
comments.
Any
comments
received
will
be
given
consideration
when
completing
the
supporting
statement
that
is
submitted
to
OMB.

3(
c)
Consultations
In
addition
to
the
required
public
notice
and
comment
period
regarding
the
Agency's
proposal
to
renew
this
ICR
as
described
above,
the
Agency
often
uses
its
Forum
on
State
and
Tribal
Toxics
Action
(
FOSTTA)
to
communicate
with
state
and
tribal
toxics
environmental
managers
on
a
variety
of
toxics­
related
program
and
enforcement
issues.
In
previous
years,
the
Agency
has
used
the
FOSTTA
to
discuss
asbestos­
related
issues
such
as
implementation
of
the
MAP
rule.
The
FOSTTA
remains
a
viable
forum
to
consult
and
discuss
issues
related
to
these
rules
with
state
and
tribal
program
contacts.

AHERA
Rule:
The
1987
Asbestos­
Containing
Materials
in
Schools
Rule
was
developed
through
the
regulatory
negotiation
process.
Participants
included
representatives
of
national
educational
organizations,
labor
unions,
asbestos
product
manufacturers,
the
environmental
community,
asbestos
abatement
contractor
groups,
professional
associations
of
architects,
consulting
engineers,
industrial
hygienists,
and
the
EPA.

In
December
and
January
2004,
EPA
consulted
with
the
Agency
regional
asbestos
coordinators
and
State
regulatory
agencies
to
determine
if
any
additional
reporting
requirements
were
imposed
on
charter
schools
under
AHERA.
At
this
time,
insufficient
information
is
available
to
demonstrate
that
any
additional
reporting
burden
presently
exists.

MAP:
Consultations
occurred
with
various
respondents
since
development
work
on
the
MAP
Rule
revision
began
several
years
ago.
Exploratory
meetings
were
held
with
labor
unions
(
May
1991)
and
States
(
June
1991)
to
learn
of
their
interests
and
concerns.
EPA
published
its
proposed
changes
to
the
MAP
in
the
Federal
Register
on
May
13,
1992,
and
formally
invited
public
comment.
A
public
hearing
was
held
June
8,
1992.
Commenters
who
specifically
reacted
to
EPA's
proposals
regarding
recordkeeping
requirements
were
unanimously
supportive.
An
additional
hearing,
with
the
cooperation
of
the
National
Conference
on
State
Legislatures
(
NCSL),
occurred
on
June
9,
1992.
Collection
activities
were
discussed
with
State
participants
at
that
time.
They
continued
to
express
support
for
EPA's
MAP
proposals.

EPA
consulted
extensively
with
labor
unions,
the
States,
and
other
interested
parties
during
the
development
of
the
1994
Interim
Final
MAP.
And
for
the
past
four
years,
EPA
has
met
annually
with
the
States
to
discuss,
among
other
things,
implementation
of
the
MAP.
In
general,
States
are
supportive
of
the
regulation,
including
the
reporting
and
recordkeeping
provisions.

3(
d)
Effects
of
Less
Frequent
Collection
AHERA
Rule:
If
information
were
collected
less
frequently,
it
would
be
difficult
to
determine
whether
an
LEA
properly
inspected
for
asbestos­
containing
materials
and
developed
an
appropriate
management
plan,
and
kept
these
documents
up­
to­
date
including
ongoing
activities.

MAP:
The
revised
MAP
has
no
routine
or
repetitive
reporting
requirements.
Training
course
self­
certifications,
training
course
approval
applications
and
State
Program
approval
applications
are
one­
time
submissions.
Once
approved
they
do
not
expire.
No
less
frequent
collection
schedule
is
feasible.
Recordkeeping
requirements
are
tied
directly
to
training
courses
and
the
issuance
of
accreditation
certificates
to
students
successfully
completing
those
courses
and
passing
the
requisite
exams.
If/
when
training
providers
are
inactive
and
not
offering
courses,
no
new
record
generation
is
required
of
them.
4
3(
e)
General
Guidelines
Except
as
described
in
this
section,
the
collection
activities
in
this
ICR
adhere
to
the
guidelines
stated
in
the
Paperwork
Reduction
Act,
OMB's
implementing
regulations,
and
applicable
OMB
and
EPA
guidance.

AHERA
Rule:
The
rule
requires
that
the
asbestos
management
plans
be
maintained
as
a
living
document,
necessary
for
as
long
as
asbestos­
containing
building
materials
are
present
in
the
school
building.
When
all
asbestos
materials
have
been
removed
from
a
homogeneous
area,
records
pertaining
to
that
homogeneous
area
must
be
retained
for
three
years
after
the
next
reinspection
date.
As
a
result,
such
records
may
need
to
be
maintained
beyond
the
three
year
record
retention
period
recommended
in
5
CFR
1320.5(
d)(
2)(
iv).
EPA
believes,
however,
that
these
retention
requirements
are
necessary
to
satisfy
the
statutory
mandates
in
AHERA,
which
specifically
mandates
the
development
and
maintenance
of
asbestos
management
plans.
In
addition
to
ensuring
that
a
management
plan
is
available
for
public
inspection
as
required
by
AHERA,
maintaining
a
current
management
plan
is
necessary
and
critical
for
ensuring
the
proper
protection
of
human
health,
safety,
and
the
environment
as
required
by
AHERA.
Providing
up­
to­
date
information
about
the
location
and
status
of
asbestoscontaining
building
materials
that
remain
present
in
the
school
building
is
also
essential
for
ensuring
that
the
material
does
not
subsequently
become
unintentionally
disturbed
or
damaged
such
that
it
may
pose
an
unreasonable
risk
to
school
employees,
children
and
other
building
occupants
or
users.
In
accordance
with
5
CFR
1320.5(
d)(
2),
the
retention
period
beyond
the
recommended
three
year
period
is
necessary
and
appropriate.
5
In
approving
the
ICR
in
1998,
OMB
stated
the
following:
"
This
ICR
is
approved
for
3
years.
As
requested
in
previous
terms
of
clearance­
EPA
will
report
on
amendments
to
the
School
Rule
as
they
relate
to
record
retention
periods
and
reinspection
periods."
The
previous
terms
of
clearance
referenced
were
from
1995,
which
stated,
"
This
ICR
is
approved
for
three
years­
as
requested.
EPA
has
done
a
good
job
updating
labor
rates
for
school
employees.
EPA
shall
report
on
the
progress
of
the
Region
VII
lead
amendments
to
the
Schools
Rule
as
it
relates
to
record
retention
periods
­
beyond
3
years­
and
reinspection
periods
­
3
years­.
EPA
should
continue
to
separate
its
MAP
burden
estimates
for
the
schools
estimates."

As
reflected
in
the
1995
statement,
EPA
had
initiated
an
Agency
workgroup
in
1994
to
evaluate
the
AHERA
Rule
for
potential
amendments
related
to
enforcement,
and
this
effort
was
subsequently
expanded
to
include
the
consideration
of
potential
amendments
to
the
record
retention
and
reinspection
periods
as
OMB
requested.
This
workgroup
effort
did
not
result
in
any
proposed
revisions
to
the
AHERA
Rule
and
has
since
been
abandoned.

The
Agency
has
concluded
that
the
reinspection
interval
is
necessary
to
satisfy
the
statutory
mandates
in
AHERA,
which
specifically
mandates
the
periodic
surveillance
and
reinspection
of
asbestos­
containing
materials,
and
that
the
current
interval
is
appropriate
and
necessary
for
ensuring
that
the
asbestos­
containing
material
does
not
subsequently
become
disturbed
or
damaged
such
that
it
is
likely
to
become
a
potential
hazard
to
school
employees,
children
and
other
building
occupants
or
users.
The
existing
reinspection
period
is
consistent
with
the
provisions
in
5
CFR
1320.5(
d)(
2).

MAP:
There
are
no
exceptions
to
note.

3(
f)
Confidentiality
This
information
collection
does
not
include
questions
of
a
confidential
nature.

3(
g)
Sensitive
Questions
This
information
collection
does
not
include
questions
of
a
sensitive
nature.

4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes
AHERA
Rule
and
MAP:
There
are
three
types
of
respondents
for
this
information
collection
request.
Local
Education
Agencies
(
LEAs)
and
States
are
involved
in
recordkeeping
and
reporting
activities
associated
with
the
Schools
Rule,
while
training
providers
and
States
are
involved
in
recordkeeping
and
reporting
activities
related
to
the
MAP
Rule.
The
respondent
activities
are
different
for
each
respondent
type
and
are
discussed
in
turn.
The
respondents
to
this
information
collection
activity
are
elementary
and
secondary
school
districts
(
SIC
code
8211,
NAICS
code
61111),
and
all
states
(
SIC
code
9411,
NAICS
code
92311).
Additionally,
under
ASHARA,
the
Model
Accreditation
Plan
(
MAP)
affects
training
providers
(
SIC
code
8299,
NAICS
code
61143),
and
State
Asbestos
Accreditation
Programs
(
SIC
code
9431,
NAICS
code
92312).
These
respondents
are
included
because
they
are
the
providers
and
guarantors
of
accreditation,
respectively.

4(
b)
Information
Requested
6
(
i)
Data
Items
AHERA
Rule:
There
are
no
specific
data
collection
instruments
used
to
collect
information
for
this
activity.
The
AHERA
Rule
originally
included
a
reporting
requirement;
i.
e.,
management
plans
were
required
to
be
submitted
to
States
for
review.
This
requirement
was
met
by
all
respondents
in
the
first
year
of
the
rule.
Thus
the
AHERA
portion
of
this
ICR
no
longer
has
an
active
reporting
requirement.
The
rule
continues
to
require
recordkeeping.

MAP:
Training
providers
seeking
reapproval
for
their
existing
training
courses
based
upon
the
revised
MAP
standards,
or
initial
approval
for
new
training
programs
based
upon
the
increased
MAP
standards,
were
required
to
report
the
following
data
items:

­
a
self­
certification
letter
for
upgraded
approval
pursuant
to
Part
IV.
2
of
the
MAP;
or
­
an
application
for
a
new
training
course
approval
pursuant
to
Part
III.
a
of
the
MAP.

When
a
training
provider
offers
approved
training
programs
for
accreditation
purposes,
certain
records
must
be
maintained
for
a
three­
year
period
in
accordance
with
the
MAP
Part
I.
6.
e.
g.,

­
copies
of
all
instructional
materials
used;
­
copies
of
all
instructor
resumes
and
approvals;
­
copies
of
examinations
and
test
scores;
and
­
records
relating
to
accreditation
certificates.

A
State
seeking
reapproval
of
its
existing
accreditation
program
based
upon
the
new
MAP
standards,
or
initial
approval
of
its
State
accreditation
program
based
on
the
new
MAP
standards,
must
report
the
following
data
item:

­
an
application
for
EPA
approval
pursuant
to
Part
II
of
the
MAP.

There
are
no
recordkeeping
requirements
in
the
MAP
that
relate
to
State
programs.

(
ii)
Respondent
Activities
7
MAP:
Training
and
Accreditation
Under
AHERA,
LEAs
shall
use
trained,
accredited
persons
to
perform
asbestos­
related
tasks
as
defined
by
the
revised
MAP.
Specifically,
the
MAP
shall
be
used
as
a
tool
to
accredit
persons
who:
­
conduct
inspections
or
reinspections
for
asbestos­
containing
material
(
ACM);
­
prepare
and/
or
update
management
plans
for
elementary
and
secondary
schools;
and
­
design
or
carry
out
response
actions
with
respect
to
ACM
in
those
schools.

ASHARA
extended
that
requirement
to
similar
activities
in
public
and
commercial
buildings
as
well,
with
the
exception
of
the
preparation
of
asbestos
management
plans.

Respondents
who
are
training
entities
will
need
to
perform
certain
collection
activities:

­
read
the
regulation;
­
make
any
required
changes
to
training
programs;
­
prepare
and
submit
a
self­
certification
package
to
EPA;
­
retain
records/
materials
costs
(
usual
business
practice);
­
provide
reasonable
access
to
records
to
EPA
and/
or
the
State,
as
requested.

Waiver
for
State
Programs
The
AHERA
Rule
provides
a
procedure
to
allow
States
to
receive
a
waiver
from
some
or
all
of
the
requirements
of
the
rule
if
the
State
has
established
and
is
implementing,
or
intends
to
implement,
a
program
of
asbestos
inspection
and
management
at
least
as
stringent
as
the
requirements
of
the
rule.
The
rule
requires
specific
information
to
be
included
in
the
waiver
request
submitted
to
EPA.
Nine
States
have
currently
been
granted
this
waiver
under
the
AHERA
Rule.

Respondents
who
are
State
accreditation
programs
will
need
to
perform
the
following
collection
activities:

­
read
the
regulation;
­
compare
State
program
authority
and
the
minimum
requirements
of
the
regulation;
­
develop
State
legislative
analysis
and
adopt
new
legislation;
­
develop
State
regulatory
analysis
and
promulgate
a
new
State
regulation;
­
prepare
and
submit
to
EPA
an
application
for
program
approval;
and
­
implement
a
State
accreditation
program
that
is
not
less
stringent
than
the
regulation.

As
of
January
of
2004,
38
States
are
operating
state
accreditation
programs
under
the
MAP.
8
AHERA
Rule:

Local
Education
Agencies:
Local
education
agency
(
i.
e.,
school
or
school
district)
reporting
and
recordkeeping
under
the
Schools
Rule
may
be
divided
into
two
main
categories:
those
associated
with
the
management
plan,
and
those
associated
with
operations
and
maintenance
(
O&
M)
activities.
Most
of
the
LEA
recordkeeping
burden
involves
the
development
and
implementation
of
the
management
plan.

The
management
plan
burden
varies
by
school
type
as
well
as
by
the
type
of
ACM
found
in
a
school.
The
management
plan
recordkeeping
and
reporting
burden
items
include:

­
Development
and
submission
of
the
management
plan;
and
­
Implementation
of
the
management
plan,
including:
­­
Time
spent
by
the
program
manager
to
do
additional
activity
planning,
create
and
gather
new
information,
prepare
written
activity
reports,
and
record
and
review
that
information;
­­
Time
spent
by
custodians
and
clerical
personnel
to
gather,
record,
process
and
store
asbestos­
related
information;
and
­­
Annual
notification
of
parents
and
other
interested
parties
of
the
presence
of
ACM
in
a
school,
as
well
as
the
availability
of
the
management
plan
for
public
review.

The
development
and
submission
of
the
management
plan
was
a
one­
time
activity
that
occurred
for
most
schools
during
the
first
year
after
the
AHERA
regulations
went
into
affect.
This
activity
is
assumed
to
be
complete
for
all
schools
with
ACM,
and
is
therefore
no
longer
included
in
burden
estimates.
The
recordkeeping
activities
associated
with
the
management
plan
implementation,
however,
are
on­
going
and
are
therefore
included
in
burden
estimates.

Recordkeeping
Requirements:
The
recordkeeping
burden
associated
with
the
development
of
an
O&
M
activity
plan
was
largely
completed
in
the
first
year
of
AHERA
Rule
implementation.
On
an
ongoing
basis,
however
(
AHERA
regulations
also
require
LEAs
to
keep
known
or
assumed
ACBM
under
periodic
surveillance),
the
O&
M
plan
may
require
updating.

The
original
inspection
report
and
any
reinspection
reports
must
be
maintained
in
the
management
plan.
Management
planner
recommendations
and
response
actions
with
their
air
sampling
clearance
records
are
also
to
be
kept.
Records
required
by
the
rule
also
include
those
pertaining
to
fiber
release
episodes,
periodic
surveillance,
training
received
by
workers
performing
operation
and
maintenance
activities,
and
cleaning
activities
that
are
part
of
an
operations
and
maintenance
program.
The
rule
also
requires
LEAs
to
collect
and
retain
various
records
that
are
not
part
of
the
information
included
in
the
management
plan.

The
rule
requires
LEAs
to
have
accredited
inspectors
conduct
reinspections
at
least
once
every
three
years
after
the
management
plan
is
in
effect.
Results
of
this
reinspection
shall
be
recorded
in
the
school's
management
plan,
along
with
any
necessary
changes
in
response
actions
recommended
or
required.
The
rule
directs
the
LEA
to
select
and
implement
in
a
timely
manner
appropriate
response
actions
for
ACBM
that
are
assessed
by
the
accredited
inspector
and
management
planner.
The
rule
identifies
five
major
response
actions
­­
operations
and
maintenance
(
O&
M),
repair,
encapsulation,
enclosure,
and
removal
­­
and
describes
appropriate
conditions
under
which
they
may
be
selected
by
the
LEA.
The
rule
also
identifies
the
steps
that
shall
be
taken
to
properly
conduct
and
complete
the
response
actions.
9
After
performing
a
thorough
visual
inspection
of
the
area
in
which
the
response
action
was
conducted,
air
testing
is
performed
to
determine
whether
a
response
action
has
been
properly
completed.
The
rule
as
it
is
in
effect
at
this
time
(
2004)
requires
the
use
of
transmission
electron
microscopy
(
TEM)
for
all
removal,
enclosure,
encapsulation,
or
repair
response
actions
involving
more
than
260
linear
feet
or
more
than
160
square
feet
of
ACBM.
The
use
of
phase
contrast
microscopy
(
PCM)
is
allowed
by
the
rule
for
final
air
sampling
where
the
amounts
of
ACBM
are
less
than
the
limits
above
and
greater
than
for
small
projects
of
short
duration.

Response
actions
that
fail
to
meet
prescribed
air
sampling
standards
by
the
stipulated
sampling
methods
shall
have
the
areas
re­
cleaned
and
re­
sampled
before
being
released
for
reoccupancy.
Records
of
response
actions
and
subsequent
air
sampling
clearance
records
must
be
maintained
by
the
LEA.

The
rule
requires
each
LEA
to
maintain
a
copy
of
the
management
plan(
s)
in
its
administrative
office,
and
each
school
is
required
to
maintain
a
copy
of
its
specific
management
plan
in
its
administrative
office.
These
plans
are
to
be
made
available
for
inspection
by
the
public
without
cost
or
restriction.
LEAs
must
notify
parent,
teacher,
and
employee
organizations
of
the
availability
of
the
management
plans
upon
submission
of
the
management
plan
to
the
State
and
at
least
once
each
school
year.

States:
States
are
involved
in
both
the
Schools
Rule
and
the
MAP
Rule.
In
the
first
year
of
the
Schools
Rule,
State
governments
were
required
to
establish
teams
to
review
and
approve
management
plans
submitted
by
schools.
This
activity,
however,
is
assumed
to
have
been
completed,
and
is
therefore
no
longer
included
in
burden
estimates.

5
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
AHERA
Rule
and
MAP
include
the
following:

­
Distribute
guidance
to
LEAs,
State
designees,
and
others
on
interpretation
of
AHERA;
­
Collect
and
review
course
upgrade
self­
certification
certifications
from
training
providers;
­
Provide
written
notification
of
training
course
self­
certifications
to
EPA
Regions
and
State
programs;
­
Audit
training
provider
courses
and
records
for
compliance
monitoring
purposes;
­
Review
State
program
applications
packages
for
approval/
reapproval
as
they
are
received;
­
Maintain
and
revise
master
data
base
of
approved
training
providers
as
required
to
be
used
as
a
resource
for
the
public;
­
Revise
model
criteria
as
appropriate
and
develop
new
curricula
for
new
training
disciplines
as
required;
­
Provide
technical
assistance
to
LEAs
and
public
on
implementation
and
compliance
with
AHERA.

5(
b)
Collection
Methodology
and
Management
AHERA
Rule:
No
specific
collection
methodologies
or
management
techniques
are
required.
10
MAP:
The
rule
provides
explicit
instruction
to
training
providers
with
preexisting
approvals
who
wish
to
upgrade
and
continue
offering
asbestos
training
courses
under
the
revised
MAP
standards.
Providers
were
to
submit
a
one­
time
self­
certification
in
the
form
of
a
detailed
letter
to
EPA
describing
changes
made
to
their
courses
for
the
purpose
of
bringing
them
into
compliance
with
the
new
MAP.
This
was
required
to
be
done
within
six
months
of
the
revised
MAP
taking
effect.
Only
one
letter
was
required
from
each
training
entity.
EPA
then
compiled
a
listing
of
all
self­
certifications
received
by
the
deadline
and
entered
them
into
the
existing
data
base
of
approved
training
providers.
After
distribution
to
EPA
Regions
and
State
Program
offices,
compliance
and
program
audits
may
be
carried
out.
New
training
providers
are
to
follow
the
same
procedure.

The
MAP
Rule
also
prescribes
the
method
by
which
States
are
to
make
application
to
EPA
for
accreditation
program
approval
under
the
revised
MAP.
States
wishing
to
obtain
EPA
program
approval
must
make
a
one­
time
application
to
the
appropriate
EPA
Regional
Office,
demonstrating
how
the
State's
program
is
no
less
stringent
than
the
MAP.

5(
c)
Small
Entity
Flexibility
The
impact
of
the
AHERA
Rule
and
the
MAP
will
primarily
affect
small
asbestos
abatement
contracting
firms
or
accredited
consultants,
and
training
providers
that
qualify
for
"
small
business"
status.
Small
business
training
providers
have
a
one­
time
only
application
process
for
training
course
approval
that
allows
for
flexibility
in
the
way
information
is
prepared
and
presented.
A
small
business
abatement
contractor
is
required
to
keep
and
maintain
records
on
the
accreditation
status
of
supervisors
and
abatement
workers.
Accreditation
records
are
also
kept
and
maintained
by
consultants,
such
as
inspectors,
management
planners,
and
project
designers.
An
advantage
accruing
from
having
those
records
is
that
of
obtaining
and
retaining
eligibility
to
qualify
for
work
in
asbestos
control
and
abatement
in
schools
and
public
and
commercial
buildings.
With
regard
to
worker
protection,
AHERA
and
the
MAP
impose
no
additional
requirements
beyond
those
that
already
exist
in
the
OSHA
asbestos
standard
or
the
EPA
Worker
Protection
Rule.

5(
d)
Collection
Schedule
Not
applicable
for
AHERA
Rule.

MAP:
EPA's
receipt
of
a
complete
self­
certification
submission
from
a
provider
constituted
immediate
reapproval
of
the
training
courses.
Where
State
Legislatures
convened
in
January
1994,
a
180­
day
deadline
was
triggered
for
applying
to
EPA
for
new
program
approval,
if
needed.
States
not
applying
for
new
program
approval
by
the
end
of
the
180­
day
deadline
forfeited
their
previous
Program
approval,
and
they
must
then
reapply
in
order
to
re­
establish
their
State
Accreditation
Programs.

EPA­
approved
State
Programs
may
continue
to
receive
new
training
course
applications
indefinitely
into
the
future.
EPA
may
continue
to
receive
State
Program
applications
from
unapproved
States
until
all
States,
territories,
and
similar
entities
have
ultimately
obtained
approval.

6
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
11
The
original
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule
("
Schools
Rule")
based
its
burden
estimates
on
a
30­
year
projection
to
reflect
the
estimated
remaining
life
span
of
school
buildings
with
Asbestos­
Containing
Materials
(
ACM).
The
previous
ICR
renewal,
approved
in
2001,
updated
values
from
the
original
ICR.
This
ICR
renewal
further
updates
values
where
noted
in
the
sections
below.
Burden
estimates
based
on
the
Asbestos
Model
Accreditation
Plan
(
MAP)
Rule
were
also
included
in
the
last
ICR.
Those
values
are
also
updated.

There
are
three
types
of
respondents
for
this
ICR:
Local
Education
Agencies
(
LEAs)
involved
in
recordkeeping
and
reporting
activities
associated
with
the
Schools
Rule,
and
training
providers
and
States
involved
in
recordkeeping
and
reporting
activities
related
to
the
MAP
Rule.
The
respondent
activities
are
different
for
each
type
of
respondent
and
are
discussed
in
turn
in
the
following
section.

6(
a)
Estimating
Respondent
Burden
Local
Education
Agencies
Local
education
agency
(
i.
e.,
school
or
school
district)
reporting
and
recordkeeping
activities
under
the
Schools
Rule
may
be
divided
into
two
main
categories:
those
associated
with
the
management
plan
and
those
associated
with
operations
and
maintenance
(
O&
M)
activities.
Schools
with
friable
ACM
incur
burden
for
the
management
plan
and
O&
M
activities,
while
schools
with
nonfriable
ACM
incur
burden
only
for
the
management
plan.

The
management
plan
burden
varies
by
school
type
as
well
as
by
the
type
of
ACM
found
in
a
school.
Appendix
G
of
the
Final
Schools
Rule
Asbestos
Hazard
Emergency
Response
Act
Regulatory
Impact
Analysis
(
EPA,
1987a)
contains
time
and
cost
estimates
for
management
and
O&
M
plan
development
and
implementation
for
schools
with
friable
ACM
or
nonfriable
ACM.
Those
activities
incurring
burden
that
were
not
completed
during
the
initial
10
years
of
implementation
are
shown
in
Worksheet
1.

Worksheet
1
indicates
that
the
annual
estimated
recordkeeping
burden
for
schools
with
friable
ACM
is
approximately
35
hours
for
public
primary
schools
and
private
schools,
and
58
hours
for
public
secondary
schools.
For
schools
with
nonfriable
ACM
only,
the
annual
estimated
recordkeeping
burden
is
15
hours
for
public
primary
schools
and
private
schools
and
28
hours
for
public
secondary
schools.
12
Worksheet
1:
Annual
Respondent
Burden
per
Local
Education
Agency
(
Hours)

Burden
Hour
Elements
School
Type
Public
Primary
or
Private
Public
Secondary
Schools
With
Friable
Asbestos­
Containing
Materials
Implement
Management
Plan
Asbestos
program
manager
­
Activity
planning,
create
and
gather
information,
prepare
activity
reports,
record
and
review
information
10
15
Custodial
­
Gather,
record,
process
and
store
information
4
8
Clerical
­
Gather,
record,
process
and
store
information
16
30
Total
Management
Plan
30
53
Implement
Operations
and
Maintenance
(
O&
M)
Plan
Asbestos
program
manager
­
Activity
planning,
create
and
gather
information,
prepare
activity
reports,
record
and
review
information
2
2
Custodial
­
Gather,
record,
process
and
store
information
1
1
Clerical
­
Gather,
record,
process
and
store
information
2
2
Total
O&
M
Plan
5
5
Total
recordkeeping
burden
per
school
w/
Friable
ACM
35
58
Schools
With
Nonfriable
Asbestos­
Containing
Materials
Only
Implement
Management
Plan
Asbestos
program
manager
­
Activity
planning,
create
and
gather
information,
prepare
activity
reports,
record
and
review
information
5
8
Custodial
­
Gather,
record,
process
and
store
information
4
8
Clerical
­
Gather,
record,
process
and
store
information
6
12
Total
recordkeeping
burden
per
school
w/
Nonfriable
ACM
15
28
States
States
are
involved
in
both
the
Schools
Rule
and
the
MAP
Rule.
State
activities
related
to
the
Schools
Rule
were
completed
during
the
first
10
years
of
program
implementation.
The
MAP
Rule
went
into
effect
in
1994,
at
which
time
States
were
to
apply
to
EPA
for
new
program
approval.
For
the
purposes
of
this
analysis,
all
states
are
assumed
to
have
completed
accreditation
program
approval
during
previous
ICR
periods.
Therefore,
there
is
no
burden
for
initial
State
activities
included
in
this
ICR.

For
all
States
with
EPA­
approved
accreditation
programs,
an
on­
going
burden
associated
with
the
MAP
Rule
is
the
implementation
of
State
accreditation
programs.
Annual
burden
estimates
from
the
MAP
Rule
are
given
in
Worksheet
2
(
EPA,
1993).
These
estimates
assume
that
all
States
have
approved
accreditation
programs.
In
cases
where
a
State
does
not
have
an
approved
program,
the
burden
would
be
shifted
to
EPA.
This
assumption
provides
the
most
conservative
estimates
of
State
burdens.

Worksheet
2:
Annual
Respondent
Burden
per
State
or
Territory
(
Hours)

Burden
Hour
Elements
Labor
Category
Total
Hours
Management
Technical
Clerical
13
Annual
Activities
1.
Implement
a
State
accreditation
program
that
is
not
less
stringent
than
the
regulation
8
23
109
140
Total
annual
activities
8
23
109
140
Training
Providers
Training
providers
were
required
to
recertify
under
the
revised
MAP.
Providing
access
to
records
is
expected
to
take
5.5
hours
per
year
per
training
provider,
as
indicated
in
Worksheet
3,
while
the
retention
of
the
records
is
considered
customary
and
usual
business
practice.
Therefore,
no
additional
burden
is
associated
with
this
task.

Worksheet
3:
Annual
Respondent
Burden
per
Training
Provider
(
Hours)

Burden
Hour
Elements
Labor
Category
Freq/
Year
Total
Hours
Clerical
Annual
Activities
1.
Retain
records
0
N/
A
0
2.
Provide
reasonable
access
to
records
to
EPA
or
State
0.5
11
5.5
Total
annual
activities
0.5
11
5.5
6(
b)
Estimating
Respondent
Costs
The
cost
estimates
addressed
in
this
section
are
based
on
the
burden
estimates
discussed
above
and
additional
nonwage
costs
discussed
below.
Wage
rates
(
including
benefits)
have
been
increased
from
the
values
in
the
AHERA
RIA
(
EPA,
1987a),
the
Supplemental
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule
(
EPA,
1993),
and
the
previous
three
ICRs
(
EPA,
1994,
1997,
2001)
to
reflect
2003
levels.
Methods
for
updating
hourly
wage
rates
to
2003
levels
are
discussed
for
each
respondent
category.

Local
Education
Agencies
The
cost
to
LEAs
from
the
implementation
of
the
Schools
Rule
include
the
wages
associated
with
the
burden
estimates
in
Section
6(
a).
Wage
rates
were
updated
to
2003
using
mean
hourly
wage
rates
from
the
Bureau
of
Labor
Statistics'
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates,
the
Employment
Cost
Index
for
wages
and
salaries,
and
the
Employer
Costs
for
Employee
Compensation,
as
follows:
14
°
The
estimated
2002
school
asbestos
program
manager,
custodian,
and
clerical
staff
hourly
wages
were
$
21.15,
$
12.01,
and
$
12.99,
based
on
the
mean
hourly
wages
for
Occupational
Health
and
Safety
Specialists
and
Technicians,
Building
and
Grounds
Cleaning
and
Maintenance
Occupations,
Office
and
Administrative
Support
Occupations,
respectively.
These
wage
rates
are
specific
to
Elementary
and
Secondary
Schools
(
NAICS
611100)
and
are
based
on
data
from
both
public
and
private
schools
(
BLS,
2002).

C
According
to
the
Employment
Cost
Index,
wages
and
salaries
rose
by
3.1
percent
during
the
period
of
June
2002
to
September
2003
for
these
workers,
and
wages
and
salaries
were
inflated
by
this
amount
(
BLS,
2003a).

C
According
to
the
Employer
Costs
for
Employee
Compensation,
wages
and
salaries
accounted
for
69.7
percent
of
total
compensation
for
school
employees
as
of
September
2003.
Based
on
this
information,
a
loading
factor
of
1.435
(
or,
1/
0.697)
was
applied
to
the
mean
hourly
wage
rate
to
estimate
total
hourly
compensation
for
school
employees
(
BLS,
2003b).

C
The
updated
estimated
2003
total
hourly
compensation
for
school
asbestos
program
manager,
custodian,
and
clerical
staff
are
$
31.29,
$
17.77,
and
$
19.22,
respectively.

These
values
were
used
in
Worksheet
4
to
calculate
current
recordkeeping
and
reporting
costs
to
schools
with
friable
and/
or
nonfriable
ACM,
as
shown
below.
In
addition,
schools
are
required
to
provide
annual
notification
to
parents
and
other
interested
parties
of
the
presence
of
ACM,
as
well
as
the
availability
of
the
management
plan
for
public
review.
The
AHERA
RIA
estimated
the
annual
notification
cost
to
be
$
56
per
school
(
EPA,
1987a).
Previous
ICRs
have
updated
this
cost
using
the
implicit
price
deflator
for
the
Gross
Domestic
Product
(
GDP).
Using
this
same
approach,
this
cost
was
updated
to
$
81
in
2003
dollars.

Worksheet
4
indicates
that
the
annual
reporting
costs
for
schools
range
from
$
423
for
public
primary
schools
or
private
schools
with
only
nonfriable
ACM,
to
$
1,388
for
public
secondary
schools
with
friable
ACM.
15
Worksheet
4:
Annual
Cost
per
Local
Education
Agency
(
2003
$)

Activities
School
Type
Total
Hourly
Compensation
Public
Primary
and
Private
Public
Secondary
Schools
With
Friable
Asbestos­
Containing
Materials
Implement
Management
Plan
Asbestos
program
manager
­
Activity
planning,
create
and
gather
information,
prepare
activity
reports,
record
and
review
information
$
31.29
$
313
$
469
Custodial
­
Gather,
record,
process
and
store
information
$
17.77
$
71
$
142
Clerical
­
Gather,
record,
process
and
store
information
$
19.22
$
308
$
577
Total
Management
Plan
$
692
$
1,188
Implement
Operations
and
Maintenance
(
O&
M)
Plan
Asbestos
program
manager
­
Activity
planning,
create
and
gather
information,
prepare
activity
reports,
record
and
review
information
$
31.29
$
63
$
63
Custodial
­
Gather,
record,
process
and
store
information
$
17.77
$
18
$
18
Clerical
­
Gather,
record,
process
and
store
information
$
19.22
$
38
$
38
Total
O&
M
Plan
$
119
$
119
Estimated
Cost
per
School
$
892
$
1,388
Schools
With
Nonfriable
Asbestos­
Containing
Materials
Only
Implement
Management
Plan
Asbestos
program
manager
­
Activity
planning,
create
and
gather
information,
prepare
activity
reports,
record
and
review
information
$
31.29
$
156
$
250
Custodial
­
Gather,
record,
process
and
store
information
$
17.77
$
71
$
142
Clerical
­
Gather,
record,
process
and
store
information
$
19.22
$
115
$
231
Estimated
Cost
per
School
$
423
$
704
Cost
per
school
includes
$
81
for
Notification
Costs.

States
As
discussed
in
Section
6(
a),
States
have
no
further
costs
associated
with
the
Schools
Rule.
Under
the
MAP
Rule,
State
accreditation
programs
are
required
to
at
least
meet
the
standards
of
the
revised
MAP.
The
burden
estimates
associated
with
the
MAP
Rule
are
given
in
Section
6(
a).
No
additional
costs
for
materials
were
given
in
the
Supplemental
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule
(
ICR
#
1365)
(
EPA,
1993).
Worksheet
5
shows
the
estimated
annual
cost
of
State
compliance
with
the
MAP
Rule,
which
is
$
3,531.

Wage
rates
were
updated
to
2003
using
mean
hourly
wage
rates
from
the
Bureau
of
Labor
Statistics'
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates,
the
Employment
Cost
Index
for
wages
and
salaries,
and
the
Employer
Costs
for
Employee
Compensation,
as
follows:
16
°
The
estimated
2002
state
managerial,
technical,
and
clerical
staff
hourly
wages
were
$
31.12,
$
22.26,
and
$
14.92,
based
on
the
mean
hourly
wages
for
Management
Occupations,
Environmental
Scientists
and
Specialists,
Including
Health,
Office
and
Administrative
Support
Occupations,
respectively.
These
wage
rates
are
specific
to
State
Government
(
NAICS
999200)
(
BLS,
2002).

C
According
to
the
Employment
Cost
Index,
wages
and
salaries
rose
by
3.1
percent
during
the
period
of
June
2002
to
September
2003
for
these
workers,
and
wages
and
salaries
were
inflated
by
this
amount
(
BLS,
2003a).

C
According
to
the
Employer
Costs
for
Employee
Compensation,
wages
and
salaries
accounted
for
69.7
percent
of
total
compensation
for
state
employees
as
of
September
2003.
Based
on
this
information,
a
loading
factor
of
1.435
(
or,
1/
0.697)
was
applied
to
the
mean
hourly
wage
rate
to
estimate
total
hourly
compensation
for
school
employees
(
BLS,
2003b).

C
The
updated
estimated
2003
total
hourly
compensation
for
state
managerial,
technical,
and
clerical
staff
are
$
46.04,
$
32.93,
and
$
22.07,
respectively.

Worksheet
5
shows
the
estimated
annual
cost
of
State
compliance
with
the
MAP
Rule,
which
is
$
3,531
per
state.

Worksheet
5:
Annual
Cost
per
State/
Territory
(
2003
$)

Labor
Categories
Activities
Management
Technical
Clerical
Total
$
46.04
per
hour
$
32.93
per
hour
$
22.07
per
hour
Implement
a
State
accreditation
program
that
is
not
less
stringent
than
the
regulation
$
368
$
757
$
2,406
Estimated
Cost
per
State/
Territory
$
368
$
757
$
2,406
$
3,531
Training
Providers
The
reporting
and
recordkeeping
burden
under
the
MAP
Rule
for
asbestos
training
providers
is
described
in
Section
6(
a).
Providing
access
to
records
is
expected
to
take
5.5
hours
per
year
per
training
provider,
and
to
be
done
by
clerical
staff.
Wage
rates
were
updated
to
2003
using
mean
hourly
wage
rates
from
the
Bureau
of
Labor
Statistics'
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates,
the
Employment
Cost
Index
for
wages
and
salaries,
and
the
Employer
Costs
for
Employee
Compensation,
as
follows:

°
The
estimated
2002
training
provider
clerical
staff
hourly
wage
was
$
13.43
based
on
the
mean
hourly
wage
for
Administrative
Support
Occupations.
This
wage
rates
is
specific
to
Business
Schools
and
Computer
and
Management
Training
(
NAICS
611400)
(
BLS,
2002).

C
According
to
the
Employment
Cost
Index,
wages
and
salaries
rose
by
3.3
percent
during
the
period
of
June
2002
to
September
2003
for
these
workers,
and
wages
and
salaries
were
inflated
by
this
amount
(
BLS,
2003a).
17
C
According
to
the
Employer
Costs
for
Employee
Compensation,
wages
and
salaries
accounted
for
73.5
percent
of
total
compensation
for
employees
of
service
producing
private
industry
as
of
September
2003.
Based
on
this
information,
a
loading
factor
of
1.361
(
or,
1/
0.735)
was
applied
to
the
mean
hourly
wage
rate
to
estimate
total
hourly
compensation
for
training
provider
staff
(
BLS,
2003b).

C
The
updated
estimated
2003
total
hourly
compensation
for
training
provider
clerical
staff
is
$
18.88.

In
addition,
training
providers
are
expected
to
incur
materials
costs
associated
with
the
annual
recordkeeping
requirements
of
the
MAP
Rule.
These
were
estimated
to
be
$
436
in
the
MAP
Rule
(
EPA,
1993).
Previous
ICRs
have
updated
this
cost
using
the
implicit
price
deflator
for
the
Gross
Domestic
Product
(
GDP).
Using
this
same
approach,
this
cost
was
updated
to
$
544
per
training
provider
in
2003
dollars.

Worksheet
6
shows
the
estimated
annual
cost
of
training
provider
compliance
with
the
MAP
Rule,
which
is
$
648
per
training
provider.

Worksheet
6:
Annual
Cost
per
Training
Provider
(
2003
$)

Labor
Category
Freq/
Year
Total
Clerical
$
18.88
per
hour
Activities
1.
Retain
records
N/
A
N/
A
$
544
2.
Provide
reasonable
access
to
records
to
EPA
or
State
$
9.44
11
$
104
Estimated
Cost
per
Provider
$
9.44
11
$
648
6(
c)
Estimating
Agency
Burden
And
Cost
Agency
burden
and
cost
estimates
are
presented
in
Worksheets
7
and
8.
18
EPA
Burden
The
EPA
activities
associated
with
the
Schools
Rule
are
related
to
implementation
of
the
rule's
provisions.
In
the
AHERA
RIA
(
EPA,
1987a),
EPA
estimated
that
the
Federal
implementation
of
the
Schools
Rule
would
require
the
services
of
eight
full­
time
equivalent
(
FTEs)
employees
in
the
first
year,
four
FTEs
in
years
two
to
four,
and
two
FTEs
in
subsequent
years.
Because
the
rule
is
now
past
the
initial
four
year
period,
the
remaining
EPA
burden
from
implementing
the
Schools
Rule
is
two
FTEs
annually.
This
represents
an
annual
burden
of
4,160
hours.

In
addition,
an
estimated
220
hours
per
year
of
management
and
technical
labor
are
required
to
respond
to
questions
about
the
MAP
Rule.
The
annual
burden
from
both
rules
combined
is
estimated
to
be
4,380
hours
in
subsequent
years.

The
EPA
regional
burden
associated
with
auditing
training
provider
courses
and
records
is
expected
to
be
approximately
144
hours
per
year
per
regional
office.

Worksheet
7:
Annual
Agency
Burden
Estimates
for
EPA
Headquarters
and
Regional
Offices
(
Hours)

Activity
Labor
Category
Freq/
Year
Total
Management
Technical
EPA
Headquarters
1.
Perform
recordkeeping
tasks
under
the
Schools
Rule
0
4,160
N/
A
4,160
2.
Answer
respondent
questions
about
the
MAP
Rule
20
200
N/
A
220
Total
HQ
20
4,360
4,380
EPA
Regional
Offices
1.
Audit
training
provider
courses
and
records
for
compliance
monitoring
purposes
0
8
18
144
Total
per
Region
0
8
18
144
EPA
Costs
Consistent
with
previous
ICRs,
technical
tasks
are
expected
to
be
completed
by
staff
at
the
GS­
13
level
and
management
tasks
at
the
GS­
15
level.
The
2003
GS­
13
level,
step
5
hourly
compensation
was
$
60
for
technical
staff,
while
the
2003
GS­
15
level,
step
5
hourly
compensation
was
$
83.41
for
managerial
staff
(
OPM,
2003).
These
hourly
rates
include
the
standard
60
percent
loading
factor
for
EPA
personnel.

Estimates
incorporating
these
hourly
compensation
rates
and
the
burden
hour
estimates
from
the
previous
section
are
shown
in
Worksheet
8.
Total
annual
costs
for
EPA
Headquarters
are
estimated
at
$
263,268.
Total
annual
costs
for
EPA
Regional
Offices
are
estimated
at
$
8,640
per
region.
19
Worksheet
8:
Annual
Agency
Cost
Estimates
for
EPA
Headquarters
and
Regional
Offices
(
2003
$)

Activity
Labor
Category
Freq/
Year
Total
Management
Technical
$
83.41
per
hour
$
60.00
per
hour
EPA
Headquarters
1.
Perform
recordkeeping
tasks
under
the
Schools
Rule
$
0
$
249,600
N/
A
$
249,600
2.
Answer
respondent
questions
about
the
MAP
Rule
$
1,668
$
12,000
N/
A
$
13,668
Total
HQ
$
1,668
$
261,600
$
263,268
EPA
Regional
Offices
1.
Audit
training
provider
courses
and
records
for
compliance
monitoring
purposes
$
0
$
480
$
18
$
8,640
Total
per
Region
$
0
$
480
$
18
$
8,640
6(
d)
Bottom
Line
Burden
Hours
And
Costs
Table
4
and
Appendix
G
of
the
AHERA
RIA
(
EPA,
1987a),
and
Figure
Two,
Addendum
to
ICR
#
2070­
0091
Asbestos
in
Schools
Rule
(
EPA,
1987b)
estimate
the
change
in
number
of
schools
with
friable
and
nonfriable
ACM
over
the
implementation
period
of
the
rule.
The
intent
of
the
Schools
Rule
is
that
all
schools
with
ACM
have
a
management
plan,
and
that
schools
with
friable
ACM
also
have
an
O&
M
plan.
The
number
of
school
respondents
in
this
ICR
renewal
is
based
on
the
average
number
of
affected
schools
of
each
type
for
years
17
through
19
of
program
implementation,
which
is
an
extension
of
the
method
used
in
previous
ICRs.

As
in
previous
ICRs,
the
total
number
of
training
providers
is
estimated
using
the
latest
National
Directory
of
AHERA
Accredited
Courses.
According
to
the
2003
edition,
there
are
currently
769
accredited
training
providers.
This
is
a
slight
increase
from
the
last
ICR,
in
which
there
were
724
accredited
training
providers
listed.
Based
on
the
unit
burden
estimates
from
Section
6(
a)
and
the
unit
cost
estimates
from
Section
6(
b),
estimated
annual
recordkeeping
burden
for
all
training
providers
is
4,230
hours
and
the
estimated
annual
cost
is
$
498,312.

In
previous
ICRs,
the
total
number
of
states
was
50.
To
reflect
more
accurately
the
requirements
of
the
MAP
rule,
the
District
of
Columbia
and
the
US
territories
have
been
added
to
the
tally,
bringing
the
total
to
56.
Based
on
the
unit
burden
estimates
from
Section
6(
a)
and
the
unit
cost
estimates
from
Section
6(
b),
estimated
annual
recordkeeping
burden
for
all
states
and
territories
is
7,840
hours
and
the
estimated
annual
cost
is
$
197,736.

Based
on
these
estimates
of
numbers
of
respondents
and
estimates
of
unit
cost
and
burden,
the
total
respondent
and
EPA
tallies
are
shown
in
the
following
tables.
20
(
i)
The
respondent
tally
Average
Annual
Respondent
Aggregation
Table
Number
of
Entities
Unit
Burden
Total
Burden
Unit
Cost
Total
Cost
Local
Education
Agencies
Schools
with
Friable
ACM
Public
Primary
6,568
35
229,880
$
892
$
5,859,255
Public
Secondary
3,872
58
224,576
$
1,388
$
5,374,689
Private
3,312
35
115,920
$
892
$
2,954,606
Schools
with
Nonfriable
ACM
Public
Primary
44,524
15
667,860
$
423
$
18,837,711
Public
Secondary
26,246
28
734,888
$
704
$
18,479,577
Private
22,453
15
336,795
$
423
$
9,499,666
Subtotal
106,975
2,309,919
$
61,005,504
Training
Providers
769
5.5
4,230
$
648
$
498,312
States/
Territories
56
140
7,840
$
3,531
$
197,736
TOTAL
107,800
2,321,989
$
61,701,552
(
ii)
The
Agency
tally
Average
Annual
Agency
Aggregation
Table
Number
of
Entities
Unit
Burden
Total
Burden
Unit
Cost
Total
Cost
Headquarters
1
4,380
4,380
$
263,268
$
263,268
Regions
10
144
1,440
$
8,640
$
86,400
TOTAL
5,820
$
349,668
6(
e)
Reasons
For
Change
in
Burden
The
total
burden
estimate
for
respondents
has
increased
since
the
most
recently
approved
renewal
of
this
ICR
because
of
adjustments
for
each
respondent
type.
The
total
estimated
annual
burden
for
this
information
collection
currently
amounts
to
2,321,989
hours
per
year.
This
compares
with
an
average
annual
burden
of
2,212,151
hours
in
the
most
recently
approved
clearance
of
this
information
collection.

Changes
in
Respondent
Burden
Burden
Hour
Estimates
Reason
for
Change
Respondent
Type
Previous
Current
Difference
Local
Education
Agencies
2,201,169
2,309,919
108,750
Adjustment
Training
Providers
3,982
4,230
248
Adjustment
States/
Territories
7,000
7,840
840
Adjustment
Total
2,212,151
2,321,989
109,838
Most
of
the
increase
is
attributable
to
a
change
in
the
method
of
calculating
total
annual
burden
for
LEAs.
In
previous
ICRs,
total
burden
was
estimated
for
the
remainder
of
the
30­
year
implementation
period,
then
averaged
over
each
21
of
the
remaining
years
to
estimate
annual
burden.
Because
burden
is
expected
to
decline
over
time
as
schools
exit
the
respondent
universe,
this
method
produced
lower
annual
burden
estimates
for
the
earlier
years
in
the
period
(
i.
e.,
those
covered
by
the
ICR
renewal).
For
this
ICR
renewal,
the
average
number
of
schools
in
the
three
years
of
the
renewal
period
(
years
17­
19
of
the
implementation
period)
are
used
with
the
unit
burden
estimates
to
derive
an
annual
burden
estimate.
This
is
a
more
transparent
method
since
it
relies
on
simple
multiplication
of
the
estimated
number
of
respondents
by
the
unit
burden
associated
with
each.

There
is
also
some
increase
attributable
to
using
slightly
higher
numbers
of
respondents
for
training
providers
and
states/
territories.

6(
f)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0091,
is
estimated
to
be
21.6
hours
per
response
for
schools,
140
hours
per
response
for
states,
and
5.5
hours
per
response
for
training
providers.
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
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;
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
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
number
for
this
information
collection
appears
above.
In
addition,
the
OMB
control
numbers
for
EPA's
regulations,
after
initial
display
in
the
final
rule,
are
listed
in
40
CFR
part
9.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
Mail
Code
2822),
1200
Pennsylvania
Ave.,
NW.,
Washington,
D.
C.
20460.
Include
the
OMB
control
number
identified
above
in
any
correspondence.
Do
not
submit
the
completed
form
or
requested
information
to
this
address.
The
actual
information
or
form
should
be
submitted
in
accordance
with
the
instructions
accompanying
the
form,
or
as
specified
in
the
corresponding
regulations.
22
References
Bureau
of
Labor
Statistics.
2002.
Occupational
Employment
Statistics:
2002
National
Industry­
Specific
Occupational
Employment
and
Wage
Estimates.
Web
site
http://
www.
bls.
gov/
oes/
2002/
oessrci.
htm
Bureau
of
Labor
Statistics.
2003a.
Employment
Cost
Index,
Historical
Listing
(
1987
=
100).
October
30.
Web
site
http://
www.
bls.
gov/
web/
echistry.
pdf
Bureau
of
Labor
Statistics.
2003b.
Employer
Costs
for
Employee
Compensation
 
September
2003.
November
25.
Web
site
http://
www.
bls.
gov/
news.
release/
pdf/
ecec.
pdf
Office
of
Personnel
Management.
2003.
Salary
Table
2003­
DCB.
Web
Site
http://
www.
opm.
gov/
oca/
03tables/
html/
dcb_
h.
asp
U.
S.
EPA,
Office
of
Toxic
Substances,
Economics
and
Technology
Division.
1987a.
Asbestos
Hazard
Emergency
Response
Act
Regulatory
Impact
Analysis.
September.

U.
S.
EPA,
Office
of
Pesticides
and
Toxic
Substances.
1987b.
Addendum
to
ICR
#
2070­
0091
Asbestos­
In­
Schools
Rule.
October.

U.
S.
EPA.
1991.
ICR
Renewal
for
the
Asbestos
Hazard
Emergency
Response
Act
(
AHERA),
Title
II
of
the
Toxic
Substances
Control
Act
(
TSCA)
­
Asbestos­
Containing
Materials
in
Schools
Rule.
OMB
No.
2070­
0091.
EPA
ICR
#
1365.

U.
S.
EPA.
1993.
Supplemental
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule.
OMB
No.
2070­
0091.
EPA
ICR
#
1365.

U.
S.
EPA.
1994.
Renewal
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule.
OMB
No,
2070­
0091.
EPA
ICR
#
1365.

U.
S.
EPA.
1997.
Renewal
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule.
OMB
No,
2070­
0091.
EPA
ICR
#
1365.

U.
S.
EPA.
2001.
Renewal
ICR
for
the
Asbestos­
Containing
Materials
in
Schools
Rule.
OMB
No,
2070­
0091.
EPA
ICR
#
1365.

U.
S.
EPA,
Office
of
Pollution
Prevention
and
Toxics.
2003.
National
Directory
of
AHERA
Accredited
Courses.
November,
Web
site
http://
www.
epa.
gov/
asbestos/
ndaac.
html
ATTACHMENTS:
(
Note:
Electronic
copies
of
Attachments
A
through
E
are
available
as
part
of
the
electronic
file
for
this
supporting
statement.)
23
Attachment
A
Asbestos
Hazard
Emergency
Response
Act,
Section
203
Attachment
B
Asbestos
Hazard
Emergency
Response
Act,
Section
206
Attachment
C
Asbestos­
Containing
Materials
in
Schools
Rule
(
40
CFR
763,
Subpart
E)
Attachment
D
Model
Accreditation
Plan
(
40
CFR
763,
Subpart
E,
Appendix
C)
Attachment
E
­
Worksheet
A­
1:
Estimation
of
Change
in
Number
of
Schools
with
Friable
and
Nonfriable
ACM
over
Next
20
Years;
and
­
Worksheet
A­
2:
Per­
School
Annual
Cost
Estimates
Combined
with
Estimated
Change
in
Number
of
Schools
with
Friable
and
Nonfriable
ACM
over
Next
20
Years
as
Reported
in
Worksheet
A­
1
