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:
TSCA
Sections
402/
404
Training,
Certification,
Accreditation
and
Standards
for
Lead­
Based
Paint
Activities
EPA
ICR
No.:
1715.06
OMB
Control
No:
2070­
0155
1(
b)
Short
Characterization
This
information
collection
request
(
ICR)
updates
two
existing
ICRs
covering
the
reporting
and
recordkeeping
requirements
of
the
final
rulemaking
addressing
lead­
based
paint
activities
under
the
authority
of
sections
402
and
404
of
the
Toxic
Substances
Control
Act
(
TSCA).
The
first
of
these
is
identified
as
EPA
ICR
No.
1715.02
and
OMB
Control
No.
2070­
0155,
and
covers
the
reporting
and
recordkeeping
requirements
for
lead­
based
paint
professionals
conducting
lead­
based
paint
activities,
and
training
programs
providing
lead­
based
paint
activities
courses,
which
were
promulgated
under
the
authority
of
sections
402,
404,
and
407
of
TSCA.
The
second
of
these,
identified
as
EPA
ICR
1715.05,
amends
the
original
ICR
to
include
the
burden
associated
with
notification
provisions
recently
promulgated
under
the
final
rule
entitled
"
Lead:
Notification
Requirements
for
Lead­
based
Paint
Activities
and
Training."

The
Agency
requests
a
three­
year
renewal
approval
for
the
information
collection
requirements
contained
in
the
final
rule
addressing
training,
certification,
accreditation,
standards,
and
notification
for
lead­
based
paint
(
LBP)
activities
in
target
housing
and
child­
occupied
facilities
(
hereafter,
the
"
training
rule").
The
Agency
has
promulgated
this
rule
pursuant
to
sections
402
and
404
of
TSCA.
Section
404
allows
any
State
that
seeks
to
administer
and
enforce
standards
and
regulations
as
protective
as
those
developed
under
section
402
to
submit
an
application
to
EPA
for
authorization
of
a
State
program
(
Indian
Tribes
and
Alaskan
Native
Villages
may
also
submit
such
applications).

The
final
training,
certification,
accreditation
and
standards
regulation
requires
reporting
and/
or
recordkeeping
from
four
entities:
States/
Tribes/
Alaskan
Native
Villages
(
hereafter,
the
term
"
States"
includes
Tribes
and
Villages);
training
providers;
and
firms
and
individuals
engaged
in
LBP
activities.
The
following
sections
provide
a
general
overview
of
the
reporting
and
recordkeeping
requirements
for
each
entity,
discussed
in
more
detail
in
section
4(
b).
2
States.
Under
TSCA
section
404,
EPA
must
review
and
assess
State
submissions
to
determine
whether
to
grant
authorization
to
administer
a
program
addressing
training,
certification,
accreditation
and
standards
for
LBP
activities.
A
State
seeking
authorization
will
need
to
provide
information
to
EPA
so
the
Agency
may
determine
whether
its
program
is
at
least
as
protective
of
human
health
and
the
environment
as
the
Federal
program
and
whether
it
provides
adequate
enforcement.
Authorized
States
need
to
provide
a
report
to
EPA
on
their
activities.

Training
providers.
Training
programs
seeking
to
offer
training
in
LBP
activities
must
receive
EPA/
State
accreditation.
In
order
for
EPA/
States
to
have
the
information
necessary
to
evaluate
and
accredit
the
training
programs,
training
providers
need
to
prepare
and
submit
application
packages.
Training
programs
also
must
retain
certain
records
related
to
their
students
and
training
personnel
qualifications.
Training
programs
must
notify
the
Agency
1)
prior
to
providing
lead­
based
paint
activities
training
courses,
and
2)
following
completion
of
lead­
based
paint
activities
training
courses.
Training
programs
must
apply
for
re­
accreditation
every
three
years.
These
notification
requirements
are
necessary
to
provide
EPA
compliance
monitoring
and
enforcement
personnel
with
information
necessary
to
track
compliance
activity
and
to
prioritize
inspections.

Individuals/
Firms.
Individuals
and
firms
seeking
to
engage
in
LBP
activities
must
receive
certification
from
EPA/
States.
To
gain
certification,
an
individual
must
complete
an
accredited
training
course
and
receive
a
course
completion
certificate,
pass
a
thirdparty
certification
exam,
meet
specific
education/
experience
requirements,
and
demonstrate
this
to
EPA/
States.
A
firm
must
submit
a
letter
to
EPA/
States
certifying
that
it
will
employ
only
certified
individuals
and
conduct
LBP
activities
according
to
the
work
practice
standards.
Individuals/
firms
must
apply
for
re­
certification
every
three
years.
The
rule
also
requires
that
individuals/
firms
develop
and
retain
records
of
the
LBP
activities
they
undertake
to
demonstrate
compliance
with
standards
and
provide
a
written
record
for
future
reference.
Firms
must
notify
the
Agency
prior
to
commencement
of
lead­
based
paint
abatement
activities.
These
notification
requirements
are
necessary
to
provide
EPA
compliance
monitoring
and
enforcement
personnel
with
information
necessary
to
track
compliance
activity
and
to
prioritize
inspections.

2
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
Under
section
402(
a)(
1)
of
TSCA,
the
Agency
must
"...
promulgate
final
regulations
governing
lead­
based
paint
activities
to
ensure
that
individuals
engaged
in
such
activities
are
properly
trained;
that
training
programs
are
accredited;
and
that
contractors
engaged
in
such
3
activities
are
certified.
Such
regulations
shall
contain
standards
for
performing
lead­
based
paint
activities,
taking
into
account
reliability,
effectiveness
and
safety."

Section
402(
a)(
2)
states
that
"
Final
regulations
promulgated
under
[
section
402(
a)]
paragraph
(
1)
shall
contain
specific
requirements
for
the
accreditation
of
...
training
programs
...
including,
but
not
limited
to:

­
Minimum
requirements
for
the
accreditation
of
training
providers;
­
Minimum
training
curricula
requirements;
­
Minimum
training
hour
requirements;
­
Minimum
hands­
on
training
requirements;
­
Minimum
training
competency
and
proficiency
requirements;
­
Minimum
requirements
for
training
program
quality."

Section
404(
a)
of
TSCA
states
that
"[
a]
ny
State
which
seeks
to
administer
and
enforce
the
standards,
regulations,
or
other
requirements
established
under
section
402
may...
develop
and
submit
to
the
Administrator
an
application,
in
such
form
as
the
Administrator
shall
require,
for
authorization
of
such
a
State
program."
The
Agency
shall
approve
such
an
application,
if
it
finds
that
"...
the
State
program
is
at
least
as
protective
of
human
health
and
the
environment
as
the
Federal
program
under
section
402...
and
such
State
program
provides
adequate
enforcement."
The
statute
also
requires
the
Agency
to
implement
the
program
in
States
that
do
not
receive
authorization
within
two
years
after
the
effective
date
of
the
rule.

Section
407
of
TSCA
states
that
regulations
shall
include
such
recordkeeping
and
reporting
requirements
as
may
be
necessary
to
ensure
effective
implementation.
EPA
regulations
under
Subchapter
IV
of
TSCA
include
lead­
based
paint
activities
regulations,
codified
at
40
CFR
Part
745.

The
Agency's
final
training
rule
fulfills
these
statutory
mandates.

2(
b)
Use/
Users
of
the
Data
EPA
This
information
collection
will
provide
EPA
with
the
materials
necessary
to
authorize
State
programs
for
the
training
rule,
as
TSCA
Title
IV
directs,
and
to
serve
as
the
accrediting
and
certifying
body
in
States
without
authorized
programs,
discussed
further
below.

EPA/
States
This
collection
will
enable
EPA/
States
to
determine
compliance
with
and
enforce
the
requirements
for
training,
certification,
accreditation,
and
work
practice
standards.
Without
this
collection,
there
would
be
no
meaningful
way
of
ensuring
the
implementation
of
the
statutory
4
objective:
to
ensure
that
trained
individuals
perform
all
LBP
activities
to
minimize
harm
to
occupants
of
structures
and
other
parties.
The
work
practice
standards
in
the
rule
rely
on
reporting
and
recordkeeping
as
a
check
on
proper
performance
of
activities;
the
Agency
chose
this
approach
over
promulgating
prescriptive
standards
for
the
conduct
of
LBP
activities.
The
rulemaking
provides
flexibility
for
individuals
performing
the
activities,
by
relying
on
guidance
and
training
to
help
individuals
determine
the
best
approaches
and
on
documentation
as
a
"
standard
of
performance."
The
Agency
believes
this
is
the
best
method
for
accommodating
a
variety
of
LBP
hazards
and
site­
specific
conditions.

It
is
the
nature
of
certification
and
accreditation
that
an
entity
seeking
such
must
provide
materials
to
the
certifying
or
accrediting
body.
The
materials
the
Agency/
State
requires
for
these
activities
are
central
to
the
activity.

It
is
also
important
to
note
that
the
re­
certification
and
re­
accreditation
requirements
for
individuals
and
training
programs
are
meant
to
ensure
that
training
programs
incorporate
new
developments
and
technologies
in
their
courses
and
that
individuals
receive
training
in
them.
The
Agency
believes
this
ensures
that
individuals/
firms
perform
LBP
activities
in
the
safest
and
most
effective
manner
possible.

The
specific
data
elements
in
the
reports
individuals/
firms
conducting
LBP
activities
must
compile
and
retain
are
necessary
as
a
reference
for
building
owners/
residents,
EPA
or
authorized
entities.
The
records
demonstrate
that
individuals
conducting
the
activities
do
so
in
a
safe
and
effective
manner,
according
to
the
minimum
work
practice
standards
established
by
the
rule.
This
also
EPA's
enforcement
activities.

The
notification
requirement
is
necessary
to
permit
the
Agency
to
target
its
enforcement
activities
and
to
ensure
compliance
within
the
contracting
and
training
community.

3
NON­
DUPLICATION,
CONSULTATION
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
The
Agency's
collection
pursuant
to
the
TSCA
402/
404/
407
regulations
does
not
duplicate
any
other
collection.
There
is
no
other
model
program
for
LBP
activities
or
associated
State
program
approval
process,
and
there
are
currently
no
other
Federal
requirements
for
the
training
and
certification
of
individuals
engaged
in
these
activities,
for
the
accreditation
of
LBP
training
programs,
or
required
standards
for
the
conduct
of
these
activities.
5
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
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)
Consultation
To
be
completed.

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
individual
and
firm
must
obtain
certification
and
re­
certification,
each
training
program
must
obtain
accreditation
and
re­
accreditation
as
well
as
specific
notification
and
documentation
prior
to
commencement
and
upon
completion
of
each
lead­
based
paint
activity
course,
and
each
LBP
activity
is
a
separate
and
unique
event
requiring
specific
notification
and
documentation.
Program
approval
for
States
is
a
one­
time
activity,
although
there
is
ongoing
reporting.

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.
Authorized
States
report
once
a
year
for
the
first
three
years,
and
biannually
thereafter.

Training
programs
must
maintain
records
for
three
and
one­
half
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
5
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
the
three
and
one­
half
years
is
an
appropriate
period
for
the
retention
of
such
records.

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

3(
f)
Sensitive
Questions
This
information
collection
does
not
include
questions
of
a
sensitive
nature.
6
4
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
The
respondents
to
this
rule
include:
1)
Training
providers
for
LBP
activities;
2)
Individuals
and
firms
engaged
in
LBP
activities;
and
3)
State
agencies.

Specific
NAICS
codes
include:
23321
Single
Family
Housing
Construction
23331
Manufacturing
and
Industrial
Building
Construction
23332
Commercial
and
Institutional
Building
Construction
23521
Painting
and
Wall
Covering
Contractors
23542
Drywall,
Plastering,
Acoustical,
and
Insulation
Contractors
23551
Carpentry
Contractors
23561
Roofing,
Siding,
and
Sheet
Metal
Contractors
23594
Wrecking
and
Demolition
Contractors
23599
All
Other
Special
Trade
Contractors
611513
Apprenticeship
Training
611519
Other
Technical
and
Trade
Schools
611699
All
Other
Miscellaneous
Schools
and
Instruction
92312
Administration
of
Public
Health
Programs
92411
Administration
of
Air
and
Water
Resource
and
Solid
Waste
Management
Programs
92511
Administration
of
Housing
Programs
4(
b)
Information
Requested
(
i)
Data
Items
In
order
to
obtain
authorization
from
EPA
to
administer
and
enforce
a
program
under
section
404,
States
must
prepare:

­
a
notice
of
intent
to
seek
authorization,
and
­
an
application
for
authorization
identifying
the
agencies
responsible
for
implementation,
administration,
and
enforcement
of
the
program,
and
a
description
of
the
authority
and
responsibilities
vested
in
such
agencies.

States
authorized
for
the
lead­
based
paint
training
rule
must
submit
to
EPA
a
report
summarizing
implementation
and
enforcement
activities,
including
a
list
of
enforcement
actions
taken
and
any
changes
in
content,
administration,
or
enforcement
of
the
State
program.
7
To
gain
accreditation,
training
providers
must
submit
the
following
documents
to
EPA/
State:

­
an
accreditation
statement
that
clearly
indicates
how
the
training
program
meets
the
minimum
requirements
for
accreditation,
and
­
a
quality
control
plan,
which
outlines
procedures
for
periodic
revision
of
training
materials
and
exams,
annual
review
of
instructors,
and
adequacy
of
the
training
facilities.

To
gain
certification,
individuals
engaged
in
LBP
activities
are
required
to
submit
specific
materials
to
EPA/
State:

­
Inspectors,
Risk
Assessors,
Supervisors:
accredited
training
course
completion
certificate,
statement
certifying
the
individual
meets
the
education/
experience
prerequisites
proof
of
passage
of
the
third­
party
exam;
­
Project
Designers:
statement
certifying
individual
meets
the
education/
experience
requirements,
accredited
training
course
completion
certificate;
and
­
Workers:
accredited
training
course
completion
certificate.

In
the
performance
of
LBP
activities,
the
firms
and/
or
individuals
must
complete
and
retain
a
number
of
reports
(
contingent
on
the
activity
conducted),
including:

­
an
inspection
report
describing
the
surfaces
sampled
for
LBP
and
the
sampling
results;
­
a
lead
hazard
screen
report,
which
includes
an
accounting
of
any
paint
or
dust
sampling
results;
­
a
risk
assessment
report,
which
includes
an
accounting
of
paint,
dust,
or
soil
sampling
results
and
existing
hazards;
­
an
occupant
protection
plan
identifying
the
measures
that
will
be
taken
to
protect
building
occupants
from
LBP
hazards,
and
­
an
abatement
report
detailing
the
activities
undertaken
to
eliminate
the
hazard.

Prior
to
giving
a
lead­
based
paint
activity
training
course,
training
providers
must
provide
notification
to
the
Agency,
using
either
the
sample
form
entitled
"
Lead­
Based
Paint
Activities
Training
Course
Schedule"
or
a
similar
form
containing
the
required
information.
Training
providers
may
provide
electronic
submissions
using
the
Agency's
Central
Data
Exchange
(
CDX)
(
secure
internet
based
electronic
submission
of
data).
The
initial
notice
must
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;
8
­
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.

Training
providers
must
update
the
Agency
regarding
any
changes
to
training
dates,
course
locations,
course
cancellations,
or
other
changes
made
to
the
original
notice.

Following
completion
of
lead­
based
paint
activities
courses,
training
providers
must
provide
notice
using
either
the
sample
form,
entitled
"
Lead­
Based
Paint
Activities
Training
Course
Follow­
Up"
or
a
similar
form
containing
the
required
information.
Training
providers
may
provide
electronic
submissions
using
the
Agency's
Central
Data
Exchange
(
CDX).
The
notice
must
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:
­
Name
­
Address
­
Date
of
birth
­
Course
completion
certificate
number
­
Student
test
score;
and
­
Training
manager's
name
and
signature.

Certified
firms
must
notify
EPA
prior
to
beginning
lead­
based
paint
abatement
activities
(
except
in
emergency
situations)
and
provide
an
updated
notice
if
needed,
using
either
the
sample
form
entitled
"
Notification
of
Lead­
Based
Paint
Abatement
Activities"
or
a
similar
form
containing
the
required
information.
Certified
firms
may
provide
electronic
submissions
using
the
Agency's
CDX.
Notices
should
include
the
following
information:

­
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;
9
­
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.

(
ii)
Respondent
Activities.

The
rule
specifies
reporting
and
recordkeeping
for
authorized
States,
training
providers,
and
individuals/
firms
undertaking
LBP
activities.
The
rule
does
not
require
specific
forms
or
applications
for
submissions.

States
seeking
authorization
for
the
training
rule
perform
the
following
activities:
­
read
the
regulations;
­
compare
any
existing
State
program
requirements
to
the
minimum
requirements
of
the
Federal
regulation;
­
develop
and
adopt
new
legislation
as
necessary;
­
develop
and
promulgate
new
regulations
as
necessary;
­
publish
a
notice
of
intent
to
seek
authorization
and
provide
an
opportunity
for
public
hearing;
­
prepare
and
submit
to
EPA
an
application
for
program
approval;
­
maintain
program
application
availability
for
public
inspection
for
up
to
one
year
after
submission;
and
­
submit
an
annual
report
to
EPA.

Training
providers
perform
the
following
activities:
­
read
the
regulation;
­
prepare
and
submit
an
accreditation
application
to
accrediting
entity;
­
submit
an
initial
and,
if
needed,
amended
notification
of
courses
to
be
given;
­
provide
notice
of
completion
of
all
lead­
based
paint
activities
courses
offered;
­
retain
records;
and
­
provide
accrediting
entity
access
to
records
as
requested.

Individuals
seeking
certification
perform
the
following
activities:
­
read
the
regulation;
­
submit
a
proof
of
passage
of
third­
party
exam
and/
or
course
completion
certificate,
and
statement
certifying
individual
meets
education/
experience
requirements;
and
­
retain
records,
if
individual
is
incorporated
or
acting
as
a
firm.

Firms
perform
the
following
activities:
­
read
the
regulation;
­
submit
an
application
for
certification;
­
submit
notification
of
abatement
work,
and
10
­
retain
records.

5
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
EPA
performs
the
following
activities
in
order
to
authorize
States:
­
receives
applications;
­
reviews
applications
and
compares
them
with
the
Federal
program
at
40
CFR
part
745;
­
provides
applicants
with
notification
of
approval/
disapproval.

EPA
performs
the
following
activities
in
response
to
notifications:
­
Receives,
reviews
and
files
initial
notices
and
updates
received
from
training
providers;
­
Receives,
reviews
and
files
course
completion
notices
received
from
training
providers;
and
­
Receives,
reviews
and
files
notices
of
abatement
activities
from
lead
abatement
firms.

5(
b)
Collection
Methodology
and
Management
This
section
details
the
data
elements
for
each
type
of
respondent
and
for
each
reporting
or
recordkeeping
activity.
Note
that
EPA
is
cited
as
the
accrediting
and
certifying
body,
as
State
programs
may
not
necessarily
adopt
a
program
requiring
the
submission
or
retention
of
exactly
the
same
materials
as
in
the
Federal
program.
For
the
purposes
of
estimating
burden
in
Section
6
of
this
ICR,
however,
the
Agency
assumes
that
States
adopt
the
Federal
program
requirements
for
reporting
and
recordkeeping.
In
States
without
authorized
programs,
EPA
is
the
accrediting
and
certifying
body.

The
rule
provides
general
instructions
to
States
seeking
EPA
authorization
under
this
regulation.
A
State
may
submit
an
application
to
EPA
any
time.
The
elements
necessary
for
application
are
as
follows:

­
a
public
notice
of
intent
to
seek
authorization,
with
an
opportunity
for
public
hearing;
­
a
transmittal
letter
from
the
Governor
or
Tribal
equivalent
requesting
program
approval;
­
an
Attorney
General
or
Tribal
equivalent
statement
certifying
the
adequacy
of
the
State's
program
authority;
­
copies
of
all
applicable
State
statutes
and
regulations;
11
­
the
name
of
the
primary
agency
that
is
or
will
be
responsible
for
administering
and
enforcing
the
program
and
functions
of
any
other
agencies
involved
in
administering
the
program;
­
a
description
of
the
program
elements
and
an
analysis
of
how
these
elements
relate
to
the
Federal
program
elements
under
section
402;
and
­
a
description
of
the
resources
the
State
intends
to
devote
to
the
administration
and
enforcement
of
the
program.

States
authorized
for
this
rules
will
need
to
provide
a
report
(
or
separate
reports)
to
EPA
describing
any
significant
changes
in
the
programs
and
enforcement
activities.

The
rule
instructs
training
programs
seeking
accreditation
for
initial
training
programs
to
submit
a
one­
time
application
to
EPA
covering
the
following
elements:

­
the
training
program's
name,
address,
and
telephone
number;
­
a
list
of
courses
for
which
it
is
applying
for
accreditation;
­
a
statement,
signed
by
the
training
program
manager,
that
certifies
that
the
training
program
meets
the
minimum
requirements
(
e.
g.,
training
hours)
established
in
the
rule;
­
a
copy
of
the
test
blueprint,
which
describes
the
proportion
of
test
questions
devoted
to
each
major
course
topic;
­
a
detailed
description
of
the
facilities
and
equipment
available
for
lecture
and
hands­
on
training;
­
a
detailed
description
of
the
procedures
for
conducting
the
assessment
of
hands­
on
skills;
­
a
copy
of
the
program's
quality
control
plan;
and
­
for
programs
that
do
not
adopt
the
EPA
model
curriculum,
the
program
must
submit,
in
addition
to
the
above
materials,
a
copy
of
the
student
manuals
and
instructor
notebooks
to
be
used
for
each
course,
and
a
copy
of
the
course
agenda,
which
includes
the
time
allocated
for
each
course
topic.

Training
programs
must
submit
the
following
information
to
seek
accreditation
for
refresher
training
courses
(
note
that
applications
for
refresher
training
may
be
simultaneously
submitted
with
applications
for
full­
length
training
programs):

­
the
training
program's
name,
address,
and
telephone
number;
­
a
list
of
refresher
courses
for
which
it
is
seeking
accreditation;
­
a
copy
of
student
manuals
and
instructor
notebooks;
and
­
a
statement
signed
by
the
training
manager
certifying
compliance
with
rule
provisions.

Training
programs
must
also
seek
re­
accreditation
from
EPA
every
four
years.
In
order
to
receive
re­
accreditation,
the
training
program
must
submit:
12
­
the
training
program's
name,
address,
and
telephone
number;
­
a
list
of
courses
for
which
it
is
applying
for
re­
accreditation;
­
a
description
of
any
changes
or
updates
to
the
training
facility
or
equipment
that
would
adversely
affect
a
students
ability
to
learn,
since
its
last
application
was
approved;
and
­
a
statement
from
the
training
program
manager
that
the
training
program
complies
at
all
times
with
all
rule
requirements.

The
rule
specifies
that
training
programs
must
retain
the
following
records
for
three
years
and
six
months
and
make
them
available
upon
EPA
request:

­
qualifications
of
training
managers
and
work
practice
instructors;
­
current
curriculum/
course
materials,
and
documents
reflecting
any
changes
made
to
these
materials;
­
the
course
test
blueprint;
­
information
on
how
the
hands­
on
assessment
is
conducted;
­
the
quality
control
plan;
­
results
of
the
students'
hands­
on
skills
assessments
and
course
tests,
and
a
copy
of
each
student's
course
completion
certificate;
and
­
any
other
material
the
program
submitted
to
EPA
as
part
of
its
accreditation
application.

The
rule
provides
general
instructions
to
individuals
seeking
certification
to
perform
LBP
activities.
Individuals
must
submit
a
one­
time
application
to
EPA,
including
the
following
elements:

­
proof
of
training
(
for
all
individuals);
­
evidence
that
the
individual
meets
the
education
or
experience
prerequisites
(
applicable
to
all
but
workers
and
inspectors);
and
­
proof
of
completing
the
standardized
certification
exam
(
applicable
to
all
but
workers
and
project
designers).

Under
the
rule's
provisions,
individuals
must
seek
re­
certification
every
three
years
(
5
years
for
individuals
who
have
passed
a
proficiency
test
as
part
of
their
training),
submitting
to
EPA
a
copy
of
the
refresher
course
completion
certificate.

The
rule
provides
specific
requirements
for
firms
seeking
certification.
A
firm
must
submit
to
EPA
a
letter
indicating
that
the
firm
will
employ
only
certified
individuals
to
conduct
LBP
activities
and
follow
the
work
practice
standards.

The
rule
requires
that
individuals/
firms
prepare
reports
during
the
conduct
of
LBP
activities
and
maintain
the
reports
for
no
fewer
than
three
years.
The
requirements
are
specific
to
the
disciplines.
13
Following
the
conduct
of
an
inspection,
the
inspector
must
prepare
a
report
documenting
the
following:

­
date
of
inspection;
­
address
of
building
and
units;
­
date
of
construction
of
building
and
units;
­
unit
numbers
(
if
applicable);
­
name,
address,
and
telephone
number
of
the
owner
of
building
and
units;
­
name,
signature,
and
certification
number
of
each
certified
inspector
and/
or
risk
assessor
conducting
testing;
­
name,
address
and
telephone
of
the
certified
firm
employing
the
individual
(
if
applicable);
­
each
testing
method
and
device
and/
or
sampling
procedure
employed,
including
quality
control
data,
and,
if
used,
the
serial
number
of
the
XRF
device;
­
specific
locations
of
each
painted
component
tested
for
LBP;
and
­
result
of
the
inspection
expressed
according
to
the
particular
sampling
method.

For
a
risk
assessment:

­
date
of
risk
assessment;
­
address
of
residences
and
buildings;
­
date
of
construction
of
residences
and
buildings;
­
unit
numbers
(
if
applicable);
­
name,
address
and
telephone
number
of
the
owner
of
residences
and
buildings;
­
name,
signature,
and
certification
number
of
risk
assessor
conducting
the
assessment,
­
name,
address,
and
telephone
number
of
certified
firm
employing
the
risk
assessor
(
if
applicable);
­
results
of
visual
inspection;
­
name,
address,
and
telephone
of
each
recognized
laboratory
conducting
analyses
of
samples;
­
testing
methods
and
sampling
procedures
for
paint
analysis
employed;
­
specific
locations
of
each
painted
component
tested
for
the
presence
of
LBP;
­
all
data
collected
from
on­
site
testing;
­
all
results
of
laboratory
analyses
on
samples;
­
any
other
sampling
results;
­
any
background
information
collected
prior
to
the
activity;
­
an
evaluation
of
any
previous
inspections,
analyses,
or
assessments
of
LBP,
if
applicable;
­
description
of
the
location
and
type
of
identified
LBP
hazards;
and
­
description
of
options
for
addressing
any
LBP
hazards.
14
For
a
lead
hazard
screen:

­
first
15
items
on
the
risk
assessment
list
above;
and
­
recommendations
concerning
desirability
of
follow­
up
risk
assessment.

For
an
abatement
resulting
from
a
State
or
local
order
or
taking
place
in
a
child­
occupied
facility
or
multi­
family
dwelling,
the
individual/
firm
must
first
submit
to
EPA
prior
notification
of
abatement
activities.

Before
an
abatement,
the
individual/
firm
must
prepare
an
occupant
protection
plan
describing
the
measures
that
the
individual/
firm
will
take
during
the
abatement
to
protect
building
occupants
from
exposure
to
lead­
contaminated
dust
and
debris.

Following
the
abatement,
the
individual
or
supervisor
must
prepare
a
report
detailing
the
following:

­
start
and
completion
dates;
­
name
and
address
of
each
individual
or
firm
conducting
the
abatement(
s)
and
each
supervisor
assigned
to
the
project;
­
the
occupant
protection
plan;
­
name,
address,
and
signature
of
each
certified
risk
assessor
or
inspector
conducting
sampling
and
the
date
of
clearance
testing;
­
results
of
clearance
testing
and
all
soil
analyses,
and
name
of
laboratory
conducting
them;
and
­
a
detailed
description
of
the
abatement,
including
method
employed,
locations
of
rooms
and/
or
components,
reasons
for
selecting
abatement
methods
for
particular
components.

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
Central
Data
Exchange
(
CDX).
The
Environmental
Protection
Agency
is
establishing
a
single
portal
on
the
Web
for
environmental
data
entering
called
CDX.
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.
15
­
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
certification
requirements
are
very
simple.
A
firm
need
only
certify
to
the
accrediting
authority
that
it
is
employing
certified
individuals
and
that
it
will
comply
with
the
required
standards.
Individuals
must
take
a
refresher
training
course
every
three
years,
or
five
years
for
individuals
who
have
passed
a
proficiency
test
as
part
of
their
training.
The
Agency
also
permits
flexibility
in
the
way
information
is
prepared
and
presented
(
e.
g.,
there
are
no
forms
to
complete).
Post­
certification
and
accreditation,
firms
and
training
providers
need
only
notify
the
Agency
that
it
is
commencing
lead­
based
paint
abatement
activities
or
providing
a
lead­
based
paint
activity
training
course
(
with
relevant
information),
and
that
it
will
comply
with
the
required
standards.

5(
d)
Collection
Schedule
For
authorization,
certification,
and
accreditation,
collection
activities
will
occur
according
to
the
following
schedule:

­
States/
Tribes
may
submit
an
application
for
program
authorization
at
any
time;
­
training
programs
may
apply
to
become
accredited
at
any
time;
­
training
programs
must
seek
re­
accreditation
at
four­
year
intervals
following
initial
accreditation;
­
individuals
and
firms
may
apply
for
certification
at
any
time;
16
­
individuals
and
firms
must
seek
re­
certification
at
three­
year
intervals
(
five­
year
intervals
for
individuals
who
have
passed
a
proficiency
test
as
part
of
their
training)
following
initial
certification.

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
initial
notification
will
also
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
OF
THE
COLLECTION
This
section
estimates
the
incremental
burden
and
cost
associated
with
the
reporting
and
recordkeeping
requirements
of
sections
402
(
a)
and
404
of
TSCA,
and
also
with
the
notification
requirements
recently
promulgated,
as
discussed
earlier.
The
burden
estimates
provided
in
this
analysis
are
primarily
based
on
the
cost
estimates
developed
in
the
Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule
(
Fees
Rule
EA),
a
data
summary
from
the
nine
State
lead
accreditation
and
certification
program
survey,
and
the
level
of
certification
and
accreditation
and
renewal
activity
observed
over
the
first
five
years
of
the
program.
Burden
and
cost
estimates
are
provided
for
three
years
running
roughly
from
July
to
July:
2004/
05,
2005/
06,
and
2006/
07.
These
burden
and
cost
estimates
cover
both
initial
accreditations
and
certifications
and
also
re­
accreditation
and
re­
certification,
as
well
as
the
associated
notifications.

Sections
6(
a)
and
6(
b)
discuss
the
respondents'
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.
Each
of
sections
6(
a),
6(
b),
and
6(
c)
include
two
parts.
The
first
parts
of
each
section
consist
of
the
analysis
of
the
reporting
and
recordkeeping
and
training
program
elements
of
burden
and
cost
that
were
previously
covered
in
EPA
ICR
No.
1715.02.
The
second
parts
cover
the
notification
provisions
that
were
previously
covered
in
EPA
ICR
1715.05.
The
first
parts
will
be
referred
to
as
Accreditation
and
Certification.
The
second
parts
will
be
referred
to
as
Notification.
The
burden
and
cost
calculations
in
the
Notification
sections
are
based
on
the
numbers
of
entities
and
events
that
are
developed
in
the
Accreditation
and
Certification
sections,
as
well
as
on
estimates
included
in
the
previous
ICR
and
in
the
Fees
Rule
EA.
The
estimates
from
both
parts
of
sections
6(
a),
6(
b),
and
6(
c)
are
brought
together
in
the
summaries
in
sections
6(
d)
through
6(
f).
1
U.
S.
EPA.
Economic
Analysis
of
the
Final
TSCA
Section
402(
a)(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.
February
26,
1999.
(
Hereafter
referred
to
as
the
Fees
Rule
EA.)

17
6(
a)
Estimating
Respondent
Burden
Accreditation
and
Certification
Introduction
Four
types
of
respondents
will
be
affected
by
this
information
collection
request
(
ICR):
1)
training
providers,
2)
firms
performing
lead­
based
paint
activities,
3)
individual
lead­
based
paint
professionals,
and
4)
States.
The
burdens
and
costs
fall
into
one
of
the
following
categories:
1)
applying
for
authorization/
certification/
accreditation,
2)
applying
for
renewal
of
certification/
accreditation,
3)
annual
reporting
(
or
reporting
during
the
course
of
the
year),
and
4)
annual
recordkeeping
(
or
recordkeeping
during
the
course
of
the
year).
The
reporting
and
recordkeeping
burden
estimates
include
the
time
associated
with
completing
and
sending
the
reports
to
the
appropriate
authority,
as
well
as
the
time
required
to
collect
the
information
needed
to
complete
the
report.
The
recordkeeping
burden
estimates
include
the
time
associated
with
copying,
filing
and
maintaining
the
records.
In
addition,
some
States
and
the
Federal
government
will
be
affected
in
their
role
as
administrators
of
the
programs.

Sections
402/
404
allow
training
providers,
firms,
and
individuals
to
apply
for
accreditation/
certification
simultaneously
in
multiple
States.
Some
entities
file
multi­
State
applications,
but
this
is
unlikely
to
have
a
significant
effect
on
the
estimate
of
the
burden.
To
the
extent
that
applicants
take
advantage
of
the
relatively
low
cost
of
applying
in
additional
States,
this
analysis
may
have
overestimated
the
burden
to
these
entities.

Projected
Activities
Previous
Method
of
Projections
The
previous
ICR
was
based
on
projections,
since
data
on
the
rate
of
activities
were
not
available.
Those
projections
involved
the
following
steps1:

(
a)
Use
a
variety
of
data
sources
to
project
the
number
of
housing
units
with
damaged
lead­
based
paint
in
each
of
the
fifty
States
and
in
Tribal
areas.

(
b)
Collect
data
on
the
numbers
of
accredited
training
providers
and
certified
firms
and
individuals
in
those
States
that
had
accreditation
and
certification
programs.

(
c)
Use
the
relationship
between
(
a)
and
(
b)
to
estimate
a
general
relationship
between
the
number
of
housing
units
and
the
numbers
of
accredited
and
certified
entities,
and
use
that
relationship
to
project
the
expected
numbers
of
accredited
and
certified
entities
in
each
State
and
in
Tribal
areas.
2
Fees
Rule
EA.

18
(
d)
Partition
the
numbers
derived
in
(
c)
among
States
that
were
expected
to
administer
their
own
programs
and
those
that
were
expected
to
be
administered
by
EPA.
This
generated
estimates
of
the
expected
steady­
state
numbers
for
each
type
of
entity,
and
produced
the
number
of
entities
expected
to
be
accredited
or
certified
in
the
first
year
of
the
program.
These
projections
were
in
two
parts:
the
EPA­
administered
universe,
and
the
universe
of
authorized
States
and
Tribal
areas.

(
e)
Use
estimates
of
expected
turnover
rates
to
project
both
the
numbers
of
new
accreditations
and
certifications
in
future
years
and
the
number
of
re­
accreditations
and
recertifications
for
both
the
EPA­
administered
universe
and
for
the
universe
of
authorized
States
and
Tribal
areas.

Those
procedures
were
used
to
develop
the
following
projections
for
the
total
number
of
entities
in
the
national
universe,
and
also
the
total
number
of
entities
in
the
EPA­
administered
universe
over
a
period
of
five
years2.
The
changes
in
the
EPA­
administered
universe
reflect
the
progress
expected
over
time
in
the
number
of
approved
State
and
Tribal
area
programs.
The
projections
suggested
that
the
increase
in
approved
State
programs
would
reduce
the
size
of
the
EPA­
administered
universe
by
13
percent
from
the
first
year
to
the
third
year,
by
27
percent
from
the
first
year
to
the
fourth
year,
and
by
40
percent
from
the
first
year
to
the
fifth
year.

Type
of
Entity
National
Universe
EPA­
Administered
Universe
Year
1
Year
2
Year
3
Year
4
Year
5
Accredited
Training
Providers
177
51
51
44
37
30
Certified
Firms
4,069
1,167
1,167
1,011
856
700
Certified
Individuals
17,249
4,948
4,948
4,287
3,628
2,969
Total
Number
of
Entities
21,495
6,166
6,166
5,342
4,521
3,699
These
projections
in
turn
were
used
to
produce
estimates
of
activity
in
the
EPAadministered
universe
that
was
assumed
to
occur
because
of
turnover
(
the
exit
of
some
firms
and
individuals
over
time
and
their
replacement
by
others)
and
because
of
the
periodic
need
for
renewal
for
existing
entities.
The
assumption
was
made
that
the
number
of
entities
would
be
constant
over
time
(
except
for
the
movement
of
activities
from
EPA
administration
to
State
or
Tribal
administration),
so
that
each
exiting
entity
would
be
replaced
by
a
corresponding
new
entry.
The
rates
of
exit
and
entry
were
assumed
to
be
as
follows:

2
percent
per
year
for
training
providers
10
percent
per
year
for
certified
firms
30
percent
per
year
for
certified
workers
20
percent
per
year
for
supervisors
and
other
certified
professionals
19
Those
estimates
of
the
level
of
accredited
and
certified
entities
and
those
estimated
rates
of
turnover
were
then
used
to
produce
these
estimates
of
activity
in
the
EPA
universe:

Type
of
Activity
EPA­
Administered
Universe
Year
1
Year
2
Year
3
Year
4
Year
5
Training
Programs
­­
New
Accreditations
­­
Re­
accreditations
320
0
4
0
4
0
0
0
0
184
Firms
­­
New
Certifications
­­
Certification
Extensions
1,167
0
117
0
101
0
86
624
70
51
Individuals
­­
New
Certifications
­­
Re­
certifications
4,948
0
1,104
0
956
0
809
0
664
692
Totals
6,435
1,225
1,061
1,519
1,661
Data
on
EPA­
Administered
Activities
Those
projections
can
be
compared
to
data
on
the
level
of
activity
actually
observed
by
EPA.
The
data
are
in
a
form
that
is
not
in
exact
alignment
with
the
structure
of
the
projections,
due
to
the
way
the
program
has
been
administrated.
The
program
began
on
March
1,
1999.
EPA
subsequently
made
arrangements
to
have
a
contractor
handle
the
program.
That
contractor's
work
began
on
July
1,
1999
and
the
contract
has
been
renewed
annually
since
then.
As
a
result,
data
are
available
on
the
basis
of
contract
years,
spanning
the
period
from
July
1
to
the
following
June
30.
Data
are
also
available
for
the
first
four
months
of
the
program,
from
March
1
to
June
30,
1999.
Data
have
also
been
obtained
for
the
most
recent
six
months,
from
July
1,
2003
to
January
30,
2004.
One
difficulty
with
the
available
data
is
that
individual
certifications
are
not
all
broken
down
by
categories.
The
data
on
observed
activities
in
the
EPA­
administered
universe
are
shown
below:
20
EPA­
Administered
Activities,
March
1
1999
through
January
30
2004
Data
are
from
July
1
of
one
year
to
June
30
of
the
following
year,
unless
otherwise
specified
March
through
June
1999
1999/
2000
2000/
01
2001/
02
2002/
03
July
2003
through
January
2004
New
training
program
accreditations
34
120
50
11
28
7
Training
program
reaccreditations
88
95
New
firm
certifications
1
358
342
242
175
88
Firm
certification
extensions
293
92
New
individual
certifications
21
2,426
2,466
1,801
1,274
689
Individual
re­
certifications
505
511
Totals
56
2,904
2,858
2,054
2,363
1,482
In
comparing
the
initial
projections
to
the
observed
activity,
two
things
are
clear.
There
was
substantially
less
activity
in
the
initial
year
than
was
projected,
and
there
has
been
substantially
more
activity
than
projected
in
the
later
years,
at
least
with
regard
to
first­
time
accreditations
and
certifications.
The
first
point
suggests
either
that
the
steady­
state
number
of
entities
may
be
lower
than
anticipated,
or
that
it
took
more
than
one
year
to
reach
that
anticipated
steady­
state.
The
second
point
suggests
that
the
rates
of
entry
and
exit
are
higher
than
anticipated.
These
observations
are
especially
apparent
with
respect
to
the
entry
rate
of
new
training
providers.
The
number
of
new
training
programs
accredited
over
the
past
thirty
months
is
substantially
higher
than
would
be
expected
based
on
the
projected
total
number
of
training
providers
and
based
on
both
the
projected
and
observed
renewal
rates.
This
strongly
suggests
that
the
number
of
accredited
training
programs
in
EPA­
administered
areas
is
rising,
rather
than
reaching
a
stable
plateau
as
was
assumed
in
earlier
analyses.

Projections
of
EPA­
Administered
Activities
The
evidence
of
the
data
on
the
first
four
or
five
years
of
the
program
shows
that
the
actual
pattern
of
activities
does
not
agree
closely
with
the
initial
projections.
The
procedures
for
projecting
future
activities
for
the
purpose
of
this
ICR
are
similar
to
the
methods
in
the
initial
projections,
but
are
based
on
the
observed
data.
The
pattern
of
new
accreditations
and
certifications
will
be
based
on
observations
of
new
activities
over
the
most
recent
thirty
months.
The
pattern
of
renewals
or
extensions
of
accreditations
and
certifications
will
be
based
on
the
number
of
expiring
accreditations
and
certifications,
and
on
the
proportion
of
expiring
accreditations
and
certifications
that
have
been
renewed
in
the
past.
These
means
will
be
used
to
project
EPA­
administered
activities
over
the
six­
month
period
of
February
to
June
2004,
and
then
to
the
three
years
covered
by
this
ICR.
21
Another
shortcoming
here
is
that
our
projections
do
not
distinguish
among
the
different
categories
of
individual
certifications.
A
later
section
of
the
analysis
will
estimate
the
breakdown
of
the
projected
totals
to
those
professional
categories.

The
method
used
for
new
first­
time
accreditations
and
certifications
is
simply
to
estimate
the
rate
of
these
activities
over
the
last
thirty
months
of
data,
and
then
project
that
future
activities
will
occur
at
that
same
rate.

There
were
a
total
of
46
new
training
accreditations
over
the
last
30
months
of
data,
or
an
average
of
1.53
per
month
or
18.4
per
year.
Based
on
that,
we
project
that
there
will
be
18
new
training
accreditations
each
coming
year.
That
means
there
will
be
11
more
accreditations
in
the
next
six
months
and
then
18
in
each
subsequent
year.

There
were
a
total
of
505
new
firm
certifications
over
the
last
30
months
of
data,
or
an
average
of
16.83
per
month
or
202
per
year.
Based
on
that,
we
project
that
there
will
be
200
new
firm
certifications
each
coming
year.
That
means
there
will
be
112
more
firm
certifications
in
the
next
six
months
and
then
200
in
each
subsequent
year.

There
were
a
total
of
3764
new
individual
certifications
over
the
last
30
months
of
data,
or
an
average
of
125.47
per
month
or
1505.6
per
year.
Based
on
that,
we
project
that
there
will
be
1500
new
individual
certifications
each
coming
year.
That
means
that
there
will
be
811
new
individual
certifications
in
the
next
six
months
and
then
1500
in
each
subsequent
year.

The
projections
of
training
renewals
are
made
by
multiplying
the
rate
of
renewals
that
we
see
to
date
by
the
number
of
expiring
accreditations
and
certifications.

Training
certification
must
be
renewed
every
four
years.
Over
the
past
18
months
we
have
observed
a
total
of
183
training
renewals.
These
renewals
must
be
associated
with
the
training
programs
that
were
accredited
in
the
first
burst
of
activity,
which
would
include
the
first
four
months
of
the
program
and
the
subsequent
two
years.
There
were
a
total
of
204
training
programs
that
were
accredited
in
that
initial
period.
That
suggests
that
183
out
of
204
initial
accreditations
have
been
renewed.
That
represents
a
renewal
rate
of
roughly
90
percent.
There
might
be
some
additional
renewals
in
the
next
six
months,
but
90
percent
is
already
a
high
percentage
and
it
seems
unlikely
that
the
renewal
percentage
could
be
much
higher
than
that.
So
for
the
purposes
of
these
projections
we
assume
a
90
percent
rate
of
training
renewals,
with
no
additional
training
renewals
occurring
in
the
next
six
months.
Since
there
were
50
new
training
programs
accredited
in
year
two
of
the
program,
we
project
that
45
(
90
%
of
50)
will
renew
in
year
six
of
the
program.
Similarly,
we
project
10
training
renewals
in
year
seven
(
90%
of
11)
and
104
renewals
in
year
eight
(
90%
of
28
+
88).

Firm
certification
must
be
renewed
every
three
years.
In
the
first
16
months
of
the
program
we
observed
359
new
certifications.
Three
years
later,
in
the
July
2002
to
June
2003
period,
we
have
observed
293
renewals.
That
is
a
renewal
rate
of
81.6
percent.
Therefore
we
estimate
a
renewal
rate
of
82
percent
in
subsequent
periods.
Since
82
percent
of
342
is
280,
we
22
project
188
renewals
over
the
next
six
months
(
280
­
92).
Since
242
new
firm
certifications
occurred
in
year
3,
we
project
198
renewals
in
year
six.
Since
there
was
a
total
of
468
new
and
renewed
certifications
in
year
four,
we
project
384
firm
renewals
in
year
seven.
Since
we
project
a
total
of
200
new
firm
certifications
and
280
firm
renewals
in
year
five,
we
project
394
firm
renewals
in
year
eight.

Individual
certifications
must
be
renewed
every
three
years
(
unless
they
do
the
5­
year
plan,
which
apparently
has
not
been
utilized).
There
were
2447
individual
certifications
in
the
first
16
months
of
the
program,
and
then
505
renewals
in
the
year
from
July
2002
to
June
2003.
That
suggests
a
renewal
rate
of
about
21
percent.
But
in
only
the
first
six
months
of
the
July
2003
to
June
2004
period
we
already
see
511
renewals
in
comparison
to
2466
individual
certifications
in
year
two
of
the
program.
That
is
a
renewal
rate
of
about
21
percent,
with
just
the
first
six
months
of
renewals.
Either
there
will
be
no
more
individual
renewals
over
the
next
six
months,
or
the
renewal
rate
observed
from
program
year
2000/
2001
to
program
year
2003/
04
will
be
higher
than
the
rate
from
year
1999/
2000
to
year
2002/
03.
There
is
no
way
to
know
what
we
will
observe
over
the
next
six
months,
but
it
seems
extreme
to
assume
absolutely
no
more
renewals.
This
analysis
assumes
that
there
will
be
some
additional
renewals,
so
that
the
observed
renewal
rate
in
year
five
will
be
greater
than
observed
in
year
four.
For
the
sake
of
simplicity,
this
analysis
assumes
a
renewal
rate
of
25
percent
for
individual
certifications
for
purposes
of
these
projections.
That
means
that
the
analysis
projects
a
total
of
616
individual
renewals
in
the
period
from
July
2003
to
June
2004
(
25
%
of
2466),
so
that
one
can
expect
to
see
an
additional
105
renewals
in
the
six
months
from
February
to
June
2004
(
616
­
511).
Then
the
analysis
projects
450
individual
renewals
in
the
2004/
05
year
(
25%
of
1801);
445
renewals
in
the
2005/
06
year
(
25%
of
1274
+
505);
and
529
renewals
in
the
2006/
2007
year
(
25%
of
1500
+
616).

The
following
table
includes
both
the
data
on
activities
up
through
January
2004
and
projections
from
February
2004
through
June
2007.
23
EPA­
Administered
Accreditation
and
Certification
and
Renewal
Activities
Data
from
March
1999
to
January
2004
and
Projections
from
February
2004
to
June
2007
Data
are
from
July
1
of
one
year
to
June
30
of
the
following
year,
unless
otherwise
noted
.
Data
on
EPA­
Administered
Activities
Projections
of
EPA­
Administered
Activities
March
through
June
1999
1999/
2000
2000/
2001
2001/
2002
2002/
2003
July
2003
through
January
2004
February
2004
through
June
2004
2004/
2005
2005/
2006
2006/
2007
New
training
accreditations
34
120
50
11
28
7
11
18
18
18
Training
renewals
88
95
0
45
10
104
Firm
new
certifications
1
358
342
242
175
88
112
200
200
200
Firm
renewals
293
92
188
198
384
394
New
individual
certifications
21
2,426
2,466
1,801
1,274
689
811
1,500
1,500
1,500
Individual
renewals
505
511
105
450
445
529
Totals
56
2,904
2,858
2,054
2,363
1,482
1,227
2,411
2,557
2,745
These
projections
show
a
substantially
greater
rate
of
activity
than
was
initially
projected,
particularly
in
regard
to
the
high
rate
of
first­
time
accreditations
and
certifications.
In
the
case
of
certifications,
this
probably
reflects
a
higher
rate
of
turnover
rather
than
a
higher
stock
of
certified
firms
and
individuals.
As
discussed
earlier,
the
unexpectedly
high
rate
of
new
training
program
accreditations
in
combination
with
the
high
rate
of
accreditation
renewals
suggests
that
the
number
of
such
programs
is
rising.
The
methods
used
in
making
these
projections
assumes
that
the
trends
of
the
recent
past
continue
over
the
next
few
years.
If
this
assumption
is
incorrect
and
the
number
of
training
programs
reaches
a
plateau,
then
this
analysis
will
have
overestimated
the
burden
associated
with
training
program
accreditations.

It
may
be
helpful
in
understanding
these
projections
to
look
at
the
relationships
between
the
turnover
rate
and
the
renewal
rate
that
would
exist
if
the
total
numbers
of
accredited
and
certified
entities
were
to
remain
constant.
For
example,
if
we
start
with
100
training
providers
who
are
accredited
in
year
one,
and
if
2.5
percent
of
them
leave
the
business
each
year,
then
after
four
years
there
will
be
90
entities
who
remain
in
business
and
therefore
renew
their
accreditation.
This
means
that
a
turnover
rate
of
2.5
percent
per
year
is
consistent
with
a
renewal
rate
of
90
percent.
Through
a
similar
calculation,
we
find
that
a
renewal
rate
of
82
percent
for
certified
firms
is
consistent
with
a
turnover
rate
of
6.4
percent.
This
is
because
93.6%
x
93.6%
93.6%
=
0.82.
Similarly,
a
renewal
rate
of
25
percent
for
certified
individuals
is
consistent
with
a
turnover
rate
of
37
percent
per
year.
We
can
compare
these
turnover
rates
that
have
been
derived
from
the
24
data
on
observed
activities
to
the
turnover
rates
that
were
estimated
in
the
Fees
Rule
EA.
The
comparison
is
not
exact
because
the
Fees
Rule
EA
separately
estimated
the
turnover
rates
for
lead
paint
abatement
workers
and
for
the
other
categories
of
professionals.

Turnover
Rate
Estimates
for
EPA­
Administered
Activities
Estimates
from
the
Fees
Rule
EA
Estimates
Based
on
Observed
Data
1999
to
January
2004
Accredited
training
providers
2
percent
2.5
percent
Certified
firms
10
percent
6.4
percent
Certified
workers
30
percent
37
percent
Other
certified
workers
20
percent
It
is
not
clear
from
the
data
whether
the
assumption
of
a
steady­
state
number
of
accredited
and
certified
entities
is
accurate.
But
in
the
absence
of
better
information,
these
estimates
can
be
used
not
only
in
projections
of
activities
in
the
EPA­
administered
areas,
but
also
in
projections
of
activities
in
State
and
Tribal­
administered
areas.

The
available
data
represent
not
only
the
pattern
of
activities
in
EPA­
administered
areas,
but
also
the
reduction
in
those
activities
due
to
the
transfer
of
some
States
and/
or
Tribes
from
EPA­
administration
to
their
own
programs.
Making
adjustments
to
the
data
to
account
for
the
changing
size
of
the
EPA­
administered
universe
might
improve
the
accuracy
of
the
projection.
But
it
would
be
difficult
to
separate
out
the
portion
of
activity
transferred
from
EPA
to
State
or
Tribal
administration.
For
example,
the
Fees
Rule
EA
estimated
that
by
the
fourth
year
the
number
of
certified
firms
would
fall
by
27
percent
due
to
State
program
approvals.
But
the
renewal
rate
of
firms
observed
in
the
fourth
year
was
81.6
percent.
Those
two
numbers
are
clearly
inconsistent.
For
simplicity
and
in
the
absence
of
a
better
alternative,
this
analysis
disregards
these
changes
in
administration
and
assumes
that
the
scope
of
EPA
administration
is
constant
over
both
the
time
represented
by
the
data
and
the
time
period
of
projections.
It
is
not
clear
how
this
assumption
would
bias
the
estimates
of
the
level
of
activities
under
EPA
administration,
and
thus
our
projections
could
be
either
an
under
or
over
estimate
of
the
burden
and
costs
of
the
program
in
those
areas.

The
methods
for
projecting
EPA­
administered
activities
have
focused
on
the
numbers
of
renewals
and
on
the
numbers
of
new
entries
each
year.
For
some
purposes
in
this
analysis,
it
will
be
helpful
to
also
have
an
estimate
of
the
total
numbers
of
entities
that
are
active
and
accredited
or
certified
in
a
given
year.
These
numbers
can
be
calculated
based
on
the
already
developed
numbers
of
activities
in
conjunction
with
the
estimates
of
the
turnover
rates.
The
method
for
these
calculations
starts
with
the
numbers
in
the
first­
year
cohorts
that
have
already
been
identified
in
the
data
(
through
January
2004)
or
projected.
The
size
of
these
cohorts
is
then
tracked
over
time
based
on
the
estimated
turnover
rates.
25
The
method
proceeds
in
the
manner
illustrated
in
this
example.
The
first­
year
cohort
of
certified
firms
in
the
year
July
2003
to
June
2004
consists
of
the
number
of
firms
that
either
renew
their
certifications
or
are
certified
for
the
first
time.
From
the
earlier
table
the
number
of
newly
certified
firms
in
that
year
is
estimated
to
be
200
and
the
number
of
renewals
is
estimated
to
be
280,
for
a
total
cohort
size
of
480
certified
firms.
The
turnover
rate
for
firms
is
estimated
to
be
6.4
percent.
We
then
calculate
the
size
of
that
cohort
in
2004/
05
will
be
449
(
480
­
31),
and
during
that
year
that
group
will
be
the
second­
year
cohort.
In
2005/
06
it
will
be
the
third­
year
cohort
and
will
include
420
firms
(
449
­
29).
The
firms
in
the
third­
year
cohort
will
be
due
for
renewal
of
their
certifications,
so
in
the
following
year
(
2006/
07)
the
firms
that
do
renew
will
be
a
part
of
the
first­
year
cohort.

Estimated
Numbers
of
Certified
Firms
in
EPA­
Administered
Areas
(
turnover
rate
of
6.4
%,
fractions
in
overall
totals
only
rounded
to
whole­
numbers)

First­
year
numbers
taken
from
earlier
table
2002/
2003
2003/
2004
2004/
2005
2005/
2006
2006/
2007
First­
year
cohort
New
175
200
200
200
200
Renewed
293
280
198
384
394
First­
year
totals
468
480
398
584
594
Second­
year
cohort
­
­
438.05
449.28
372.53
546.62
Third­
year
cohort
­
­
­
­
410.01
420.53
348.69
Total
n/
a
n/
a
1,257
1,377
1,489
For
clarity
in
subsequent
calculations,
the
numbers
of
projected
certified
firms
are
rounded
to
whole
numbers,
and
cohort
numbers
are
adjusted
if
necessary
to
preserve
the
overall
totals.

Estimated
Numbers
of
Certified
Firms
in
EPA­
Administered
Areas
(
all
fractions
rounded
to
whole­
numbers
and
adjusted
to
preserve
totals)

2004/
2005
2005/
2006
2006/
2007
First­
year
cohort
New
200
200
200
Renewed
198
384
394
First­
year
totals
398
584
594
Second­
year
cohort
449
372
546
Third­
year
cohort
410
421
349
Total
1,257
1,377
1,489
26
Estimated
Numbers
of
Accredited
Training
Providers
in
EPA­
Administered
Areas
(
turnover
rate
of
2.5
%,
fractions
in
overall
totals
only
rounded
to
whole­
numbers)

First­
year
numbers
taken
from
earlier
table
2001/
2002
2002/
03
2003/
04
2004/
05
2005/
06
2006/
07
First­
year
cohort
New
11
28
18
18
18
18
Renewed
0
88
95
45
10
104
First­
year
totals
11
116
113
63
28
122
Second­
year
cohort
­
­
8.25
87.00
84.75
47.25
21.00
Third­
year
cohort
­
­
­
­
6.19
65.25
63.56
35.44
Fourth­
year
cohort
­
­
­
­
­
­
4.64
48.94
47.67
Overall
totals
n/
a
n/
a
n/
a
218
188
226
For
clarity
in
subsequent
calculations,
the
numbers
of
projected
accredited
training
providers
are
rounded
to
whole
numbers.

Estimated
Numbers
of
Accredited
Training
Providers
in
EPA­
Administered
Areas
(
all
fractions
rounded
to
whole­
numbers)

2004/
05
2005/
06
2006/
07
First­
year
cohort
New
18
18
18
Renewed
45
10
104
First­
year
totals
63
28
122
Second­
year
cohort
85
47
21
Third­
year
cohort
65
64
35
Fourth­
year
cohort
5
49
48
Overall
totals
218
188
226
27
Estimated
Numbers
of
Certified
Individuals
in
EPA­
Administered
Areas
(
turnover
rate
of
37
%,
fractions
in
overall
totals
only
rounded
to
whole­
numbers)

First­
year
numbers
taken
from
earlier
table
2002/
2003
2003/
2004
2004/
2005
2005/
2006
2006/
2007
First­
year
cohort
New
1,274
1,500
1,500
1,500
1,500
Renewed
505
616
450
445
529
First­
year
totals
1,779
2,116
1,950
1,945
2,029
Second­
year
cohort
­
­
1,120.77
1,333.08
1,228.50
1,225.35
Third­
year
cohort
­
­
­
­
706.09
839.84
773.95
Total
n/
a
n/
a
3,989
4,013
4,028
For
clarity
in
subsequent
calculations,
the
numbers
of
projected
certified
individuals
are
rounded
to
whole
numbers,
and
then
cohort
numbers
are
adjusted
if
necessary
to
preserve
the
overall
totals.

Estimated
Numbers
of
Certified
Individuals
in
EPA­
Administered
Areas
(
all
fractions
rounded
to
whole­
numbers
and
adjusted
to
preserve
totals)

2004/
2005
2005/
2006
2006/
2007
First­
year
cohort
New
1,500
1,500
1,500
Renewed
450
445
529
First­
year
totals
1,950
1,945
2,029
Second­
year
cohort
1,333
1,228
1,225
Third­
year
cohort
706
840
774
Total
3,989
4,013
4,028
It
may
be
interesting
to
compare
these
projections
to
the
estimates
that
were
included
in
prior
analyses.
The
Fees
Rule
EA
provided
estimates
of
the
numbers
of
entities
in
the
fifth
year
of
the
program.
The
following
table
reproduces
those
numbers
next
to
the
estimates
above.
3
U.
S.
EPA.
Economic
Analysis
of
the
Final
TSCA
Section
402(
a)(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.
February
26,
1999.

28
Comparison
of
Estimates
of
Numbers
of
Accredited
or
Certified
Entities
Previous
estimate
from
1999
Fees
Rule
EA
Estimates
used
in
this
analysis
2004/
05
2005/
06
2006/
07
Accredited
training
providers
30
218
188
226
Certified
firms
700
1,257
1,377
1,489
Certified
individuals
2,969
3,989
4,013
4,028
Total
number
of
entities
3,699
5,464
5,578
5,743
It
is
apparent
from
this
table
that
the
estimates
made
in
this
analysis
suggest
a
much
larger
number
of
entities
in
the
EPA­
administered
areas
than
were
projected
in
the
earlier
analysis.
In
particular,
the
predicted
number
of
certified
firms
is
much
larger,
and
the
predicted
number
of
accredited
training
programs
is
very
much
larger.
There
is
little
reason
to
doubt
the
current
estimates
and
to
prefer
the
1999
estimates,
since
we
know
from
the
data
on
activities
that
a
total
of
218
training
providers
has
either
been
accredited
or
renewed
their
accreditation
in
the
last
eighteen
months,
in
comparison
to
the
1999
estimate
of
a
total
of
30
training
providers
under
EPA
administration.

Projections
of
State
and
Tribal­
Administered
Activities
The
projections
for
EPA­
administered
areas
in
this
analysis
draw
on
data
available
to
the
Agency
on
the
pattern
of
activities
observed
in
those
areas
over
the
past
five
years.
Those
data
were
used
not
only
to
estimate
the
number
of
accredited
and
certified
entities,
but
also
the
yearto
year
pattern
of
new
entry,
exit,
and
renewals
of
accreditations
and
certifications.

EPA
does
not
have
similar
data
from
the
State
and
Tribal
programs.
In
the
Fees
Rule
Economic
Analysis3,
EPA
estimated
the
numbers
of
entities
and
activities
in
non­
EPA
areas
based
on
estimates
of
the
number
of
States
and
Tribes
that
would
be
approved
to
manage
their
own
programs,
estimates
of
the
number
of
housing
units
with
damaged
lead­
based
paint
in
those
areas,
and
the
estimated
relationship
between
those
housing
numbers
and
the
number
of
abatement
firms
and
workers.
The
Fees
Rule
EA
included
estimates
for
the
total
number
of
accredited
and
certified
entities
in
the
entire
U.
S.
It
also
assumed
that
this
numbers
would
be
constant
over
time.
The
share
of
those
totals
under
EPA
administration
was
expected
to
diminish
over
time
as
more
State
programs
were
approved.
As
the
totals
under
EPA
administration
declined,
similar
totals
in
State
and
Tribal
areas
would
increase.

The
Fees
Rule
EA
estimated
that
number
of
State­
approved
programs
would
reach
39
in
year
five
of
the
program.
As
of
January
2004,
there
are
39
authorized
State
programs
and
three
authorized
Tribal
programs.
These
numbers
are
sufficiently
close
to
the
earlier
estimate
that,
in
29
the
absence
of
any
additional
information,
this
analysis
will
use
those
year
five
estimates
for
the
number
of
accredited
and
certified
entities
in
the
non­
EPA
areas.
The
information
available
to
the
Agency
on
the
pattern
of
activities
in
EPA­
administered
areas
is
used
in
conjunction
with
the
previous
estimates
of
the
number
of
entities
to
project
the
pattern
of
activities
in
the
State
and
Tribal­
administered
areas
over
the
next
three
years.
Thus,
while
the
method
of
projection
in
the
non­
EPA
areas
is
quite
different
from
the
method
used
for
the
EPA
areas,
this
non­
EPA
area
method
has
relied
as
much
as
possible
on
the
same
data
that
were
used
to
project
activities
in
the
EPA
areas.

Estimates
of
the
Total
Numbers
of
Accredited
and
Certified
Entities
in
Year
Five
of
the
Program
from
the
1999
Fees
Rule
EA
Type
of
Entity
National
Universe
EPA­
Administered
Non­
EPA­
Administered
Accredited
Training
Providers
177
30
147
Certified
Firms
4,069
700
3,369
Certified
Individuals
17,249
2,969
14,280
Total
Number
of
Entities
21,495
3,699
17,796
For
the
numbers
of
accredited
and
certified
entities
to
be
constant,
the
numbers
of
new
entries
must
equal
the
number
of
exits.
In
addition,
the
number
of
renewals
should
equal
the
total
number
of
new
and
renewing
entities
either
three
or
four
years
earlier,
adjusted
downward
to
reflect
the
number
of
exiting
entities
from
that
cohort.
The
projection
method
used
to
estimate
future
activities
in
State
and
Tribal­
administered
areas
is
based
on
the
mathematical
relationships
defined
by
those
two
conditions.
A
short
explanation
of
the
mathematical
derivation
follows.

Assume
that
some
constant
fraction
of
entities
leaves
the
business
and
drops
out
from
each
cohort
each
year.
That
is
the
turnover
rate.
Let
that
fraction
equal
 .
Then
the
fraction
that
remain
in
the
business
is
1
­
 .
Define
 
=
1
­
 
as
the
retention
rate.
Now
let
the
total
number
of
entities
be
at
a
steady
state,
constant
from
period
to
period,
with
a
total
of
T
entities.
So
in
any
given
cycle
we
find
that
 T
entities
drop
out,
and
there
will
be
 T
new
entities
to
replace
them,
as
well
as
 T
that
remain
in
business.

Assume
that
each
cohort
must
renew
their
certification
after
three
years,
if
they
have
not
dropped
out
of
the
business.
Define
each
cohort
by
the
number
of
years
remaining
before
they
need
to
be
recertified.
The
largest
cohort
will
include
some
entities
that
have
just
been
certified
for
the
first
time
and
some
other
entities
that
have
just
renewed
their
certification.
As
each
year
passes
these
two
groups
progress
together
in
the
same
cohort.
In
this
way,
each
cohort
will
be
a
mixture
of
firms
that
entered
the
business
in
different
cycles,
but
all
will
have
the
same
number
of
years
remaining
before
they
need
to
renew
their
certification.

The
largest
cohort
will
include
entities
who
have
just
been
accredited
for
the
first
time
and
entities
who
have
just
renewed
their
accreditation.
Both
groups
will
have
three
years
till
they
30
need
recertification.
Call
this
group
"
A,"
and
let
the
term
A
also
represent
the
number
of
entities
in
that
cohort.
Since
the
population
is
in
a
steady
state,
there
will
be
a
cohort
"
A"
in
every
period
that
is
the
same
size.
In
the
following
period
the
cohort
will
be
reduced
by
attrition
to
a
size
 A.
Call
this
second­
year
cohort
B,
and
again
let
the
term
B
also
represent
the
number
of
entities
remaining
in
that
cohort
in
the
second
year,
so
that
B
=
 A.
Then
the
third­
year
cohort
(
referred
to
as
"
C")
will
again
be
reduced
by
attrition
by
the
factor
 ,
so
that
C
=
 B
=
 
2A.
The
total
is
simply
the
sum
of
the
cohorts,
so
that
T
=
A
+
B
+
C,
or
T
=
A
(
1
+
 
+
 
2).
In
other
words,
A
=
T/(
1
+
 
+
 
2).
For
a
given
retention
rate
 
and
a
given
total
number
of
entities
T,
we
can
now
calculate
the
size
of
each
of
the
cohorts.
In
addition,
we
can
project
that
 C
will
be
the
portion
of
entities
that
renew
their
accreditation
each
period.
Since
A
is
the
cohort
that
is
either
new
or
has
renewed
their
certification,
we
know
that
the
number
of
new
entities
each
period
will
be
A
­
 C.
But
we
know
that
C
=
 
2A,
so
that
the
number
of
new
entities
in
any
period
will
be
A
(
1
­
 
3).
This
allows
us
to
project
both
the
number
of
new
entities
and
the
number
of
renewals
each
period,
based
on
our
estimate
of
the
turn­
over
rate
and
the
steady­
state
number
of
entities.

The
calculation
process
can
be
summarized
in
three
equations:

2
T
First­
year
cohort
=
A
=
1
 
 
+
+

3
2
1
New
certifications
per
year
=
T
1
 
 
 


 


+
+


3
2
Certification
renewals
per
year
=
T
1
 
 
 




+
+


This
process
must
be
modified
to
project
the
number
of
newly
accredited
training
programs
and
the
number
of
program
accreditation
renewals
each
period.
The
training
programs
need
to
be
reaccredited
every
four
years
rather
than
three,
resulting
in
slightly
different
equations.

4
2
3
1
New
training
providers
per
year
=
T
1
 
 
 
 


 


+
+
+


4
2
4
Training
program
reaccreditations
per
year
=
T
1
 
 
 
 




+
+
+


In
estimating
the
number
of
activities
in
the
non­
EPA
universe,
we
use
the
previous
estimates
from
the
Fees
Rule
EA
to
get
estimates
of
the
total
number
of
entities
in
each
group.
31
The
Fees
Rule
estimated
a
growth
in
the
State
and
Tribal­
administered
programs,
and
the
fifth
year
data
best
reflect
the
current
number
of
approved
programs.

Numbers
of
Entities
in
the
Non­
EPA
Universe,
as
Estimated
in
the
Fees
Rule
EA
Year
1
Year
2
Year
3
Year
4
Year
5
Accredited
Training
Providers
126
126
133
140
147
Certified
Firms
2902
2902
3058
3213
3369
Certified
Individuals
12301
12301
12962
13621
14280
Total
Number
of
Entities
15329
15329
16153
16974
17796
We
use
the
fifth­
year
estimates
of
numbers
of
entities,
and
the
turn­
over
rates
estimated
from
the
EPA
universe
data.
These
data
and
formulas
yield
the
following
projections:

Projections
of
Activities
in
the
Non­
EPA
Universe
Training
providers
renew
after
4
years;
certified
entities
renew
after
3
years
Total
number
of
entities
3
or
4
year
renewal
rate
Annual
turnover
rate
(
 )
Annual
retention
rate
(
 )
Annual
number
of
new
entities
Annual
number
of
renewals
Training
providers
147
90
%
2.6
%
97.4
%
4
34
Firms
3,369
82
%
6.4
%
93.6
%
216
982
Individuals
14,280
25
%
37.0
%
63.0
%
5,284
1,761
These
are
the
estimated
annual
numbers
of
activities
in
the
non­
EPA
universe
that
will
be
used
in
this
analysis.
Since
it
is
expected
that
a
large
proportion
of
accredited
and
certified
entities
entered
the
program
within
the
first
year
or
two,
the
actual
pattern
of
new
and
renewal
actions
probably
varies
substantially
from
year
to
year.
But
the
numbers
generated
in
this
steadystate
analysis
are
expected
to
be
a
good
representation
of
the
average
level
of
activity
over
time.

The
formulas
that
were
used
in
deriving
those
projections
can
also
be
used
to
divide
the
total
numbers
of
accredited
and
certified
entities
into
year­
class
cohorts.
4
Personal
Communication,
Doreen
Cantor,
National
Program
Chemicals
Division,
EPA.

32
Estimates
of
the
Numbers
of
Accredited
and
Certified
Entities
in
Non­
EPA­
Administered
Areas
By
Year­
class
Cohorts
(
rounded
to
whole
numbers
so
that
totals
agree)

Type
of
Entity
Totals
Year
1
Year
2
Year
3
Year
4
Accredited
Training
Providers
147
38
37
36
36
Certified
Firms
3,369
1,198
1,121
1,050
n/
a
Certified
Individuals
14,280
7,045
4,439
2,796
n/
a
Proportions
of
Certified
Individuals
The
projections
above
do
not
distinguish
among
the
the
five
professional
classifications
for
which
EPA
provides
certification.
A
time­
series
break
down
of
all
the
data
on
activities
by
discipline
was
not
available.
However,
we
do
have
data
on
5815
certifications
and
renewals
by
discipline4.
We
assume
that
all
individual
certification
and
renewal
activity
is
divided
among
these
disciplines
in
the
same
proportions
as
in
that
set
of
5815
activities.
We
expect
that
the
renewal
rate
for
abatement
workers
will
be
lower
than
for
the
other
professions,
and
that
consequently
the
estimates
will
be
biased.
The
number
of
renewals
by
abatement
workers
will
be
overestimated
and
the
number
of
first­
time
certifications
for
abatement
workers
will
be
underestimated.
Conversely,
the
number
of
renewals
by
the
other
categories
will
be
underestimated
and
the
number
of
first­
time
certifications
for
the
other
categories
will
be
overestimated.
The
estimates
of
burden
hours
per
individual
differ
across
professions,
but
the
burden
hours
per
individual
are
the
same
for
first­
time
and
renewals,
so
on
balance
the
biases
in
estimates
produced
with
this
approach
will
cancel
out
and
produce
an
estimate
of
the
total
burden
hours
and
costs
that
is
more
accurate
than
the
estimates
broken
down
by
categories.

Numbers
and
Proportions
of
Certification
Activities
by
Discipline
National
Universe
of
Certified
Individuals
as
Estimated
in
the
Fees
Rule
EA
Observed
Numbers
of
Certifications
and
Renewals
in
the
Available
Data
(
Under
EPA
Administration)

Discipline
Numbers
Proportions
Numbers
Proportions
Inspectors
5,175
30.0
%
688
11.8
%

Risk
Assessors
4,140
24.0
%
1,287
22.1
%

Supervisors
3,795
22.0
%
1,299
22.3
%

Workers
3,967
23.0
%
2,462
42.4
%

Project
Designers
172
1.0
%
76
1.4
%
33
As
seen
in
that
table,
the
proportions
of
risk
assessors,
supervisors
and
project
designers
observed
in
the
data
are
very
close
to
those
predicted
in
the
Fees
Rule
EA.
However,
we
see
a
substantially
smaller
proportion
of
inspectors
and
a
much
larger
proportion
of
workers
in
the
data.

The
proportions
that
we
obtained
from
the
available
data,
broken
down
by
discipline,
can
be
combined
with
previous
estimates
of
individual
accreditation
activities
to
give
estimates
of
activities
by
year
and
by
discipline.

Numbers
of
Certification
Activities
by
Discipline
and
by
Year
(
estimates
rounded
to
whole
numbers
so
that
totals
agree)

EPA­
Administered
Areas
State
and
Tribal
Areas
2004/
2005
2005/
2006
2006/
2007
2004/
2005
2005/
2006
2006/
2007
New
inspectors
177
177
177
624
624
624
Inspector
renewals
53
53
63
208
208
208
New
risk
assessors
331
331
331
1168
1168
1168
Risk
assessor
renewals
100
98
117
389
389
389
New
supervisors
335
335
335
1178
1178
1178
Supervisor
renewals
100
99
118
393
393
393
New
abatement
workers
636
636
636
2240
2240
2240
Abatement
workers
renewals
191
189
224
747
747
747
New
project
designers
21
21
21
74
74
74
Project
designer
renewals
6
6
7
24
24
24
Training
Providers
Initial
Accreditation
A
training
program
may
seek
accreditation
to
offer
courses
in
any
of
the
following
disciplines:
inspector,
risk
assessor,
project
designer,
supervisor,
or
worker.
However,
before
training
providers
can
apply
for
accreditation,
they
must
familiarize
themselves
with
the
specific
requirements
of
the
rule,
as
well
as
compare
the
contents
of
their
current
training
courses
(
if
any)
to
the
requirements
specified
in
the
rule.
Included
in
this
burden
estimate
is
the
managerial
time
spent
in
deciding
if
the
training
provider
should
offer
lead­
based
paint
training.
Based
on
estimates
provided
in
the
Regulatory
Impact
Analysis
of
the
Interim
Rule
to
Revise
the
Asbestos
Model
Accreditation
Plan
(
MAP)
(
EPA,
1993),
this
analysis
assumes
a
total
burden
of
8
hours
associated
with
rule
familiarization
and
determination
of
applicability.
34
If
the
training
provider
decides
to
apply
for
accreditation,
an
application
must
be
submitted
to
EPA
containing
the
following
information:


the
training
provider's
name,
address,
and
telephone
number,


a
list
of
courses
for
which
it
is
applying
for
accreditation,


a
statement
signed
by
the
training
program
manager
that
clearly
indicates
how
the
training
program
meets
the
minimum
requirement
for
accreditation,
or
a
statement
that
indicates
that
the
training
program
will
use
the
EPA­
developed
curriculum
if
available,


a
copy
of
the
course
test
blueprint,
a
description
of
the
activities
and
procedures
for
conducting
the
assessment
of
hands­
on
skills,
and
a
description
of
the
facilities
and
equipment
for
lecture
and
hands
on
training,
and

a
quality
control
plan,
which
outlines
procedures
for
periodic
revision
of
training
materials
and
exams
and
annual
reviews
of
instructors.

The
burden
of
completing
the
accreditation
statement
varies
depending
on
whether
the
training
provider
adopts
the
EPA­
developed
curriculum
or
chooses
to
use
their
own
training
curriculum.
The
burden
associated
with
implementing
a
non­
EPA
curriculum,
and
providing
documentation
demonstrating
that
the
curriculum
meets
certain
minimum
requirements,
is
significantly
greater
than
adopting
the
EPA
curriculum.
Given
the
similarity
between
requirements,
data
collected
to
assess
the
burden
of
preparing
an
accreditation
statement
for
training
approval
under
the
Asbestos
MAP
were
used
to
estimate
the
burden
of
the
training
provider
approval
process
required
by
this
rule.
Based
on
the
Asbestos
MAP,
the
burden
associated
with
adoption
of
the
EPA
curriculum
is
estimated
to
be
4
hours,
or
40
hours
if
training
providers
use
their
own
curriculum.
At
this
time,
there
is
no
firm
basis
for
estimating
the
proportion
of
training
providers
that
will
adopt
the
EPA
curriculum
versus
those
that
will
use
their
own.
This
analysis
assumes
that
most
training
providers
(
90
percent)
will
adopt
the
EPA
curriculum,
resulting
in
an
average
burden
of
7.6
hours
((
0.90*
4
hours)
+
(
0.10*
40
hours))
of
professional
time
for
completion
of
the
accreditation
statement.
The
analysis
further
assumes
two
hours
of
clerical
time
required
for
completion
of
the
accreditation
statement.

The
burden
associated
with
developing
the
quality
control
plan
is
the
same
for
all
training
providers
whether
they
adopt
the
EPA
curriculum
or
develop
their
own.
Similar
data
for
estimating
the
quality
control
plan
burden
were
not
available
in
the
Asbestos
MAP.
Due
to
data
limitations,
this
analysis
assumes
that
the
preparation
of
the
quality
control
plan
will
take
8
hours
of
professional
time
and
2
hours
of
clerical
time.

Quadrennial
Reporting
Training
provider
accreditations
are
valid
for
a
period
of
4
years.
Training
providers
seeking
re­
accreditation
are
required
to
submit
an
application
to
the
approving
authority
containing:
35

the
training
provider's
name,
address,
and
telephone
number,


a
list
of
courses
for
which
it
is
applying
for
re­
accreditation,


a
description
of
any
changes
or
updates
to
the
training
facility,
equipment,
or
course
materials
that
would
adversely
affect
the
students'
ability
to
learn,


a
statement
signed
by
the
program
manager
certifying
that
the
program
complies
with
all
of
the
requirements
of
this
rule
including
recordkeeping
and
reporting
requirements.

Limited
data
are
available
regarding
the
burden
of
re­
accreditation.
Therefore,
this
analysis
makes
the
simplifying
assumption
that
it
will
take
one­
half
of
the
time
it
took
to
apply
for
initial
certification
(
i.
e.,
4.8
hours).
An
audit
may
also
be
performed
by
the
approving
authority
to
verify
the
certification
statement
and
the
contents
of
the
application.
At
this
time,
the
proportion
of
applicants
audited
is
unknown.
This
analysis
assumes
that
10
percent
of
all
programs
applying
for
re­
accreditation
will
be
audited
in
a
given
year.
Total
burden
for
a
training
provider
to
prepare
for
and
participate
in
an
audit
is
assumed
to
be
2
hours
professional
and
4
hours
of
clerical
time
because
much
of
the
work
will
be
assembling
files
for
the
auditor.

Annual
Recordkeeping
There
are
significant
first
year
and
subsequent
year
recordkeeping
requirements
burdens
for
training
providers.
Sections
402(
a)
and
404
of
TSCA
require
that
training
providers
keep
records
on:


qualifications
of
the
training
manager
and
principal
instructors,


curriculum/
course
materials,
and
documents
reflecting
any
changes
made
to
these
materials,


course
test
blueprint,


hands­
on
skills
assessment
methodology,


quality
control
plan,


student
files
(
including
hands­
on
skills
assessments,
course
test
results),
and

any
other
materials
that
were
submitted
to
the
EPA
as
part
of
the
program's
application
for
accreditation.

These
reports
must
be
held
for
a
minimum
period
of
three
and
one­
half
years.
Chapter
9
of
the
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis
estimates
that,
in
total,
training
provider
records
will
be
11
pages
plus
two
pages
for
each
of
their
students.
The
filing
burden
is
calculated
as
a
per
report/
file
burden,
and
is
not
affected
by
the
number
of
pages
in
the
report;
the
number
of
pages
only
affects
the
cost
of
materials.
Therefore,
the
recordkeeping
burden
estimates
for
training
providers
include
labor
associated
with
the
filing
and
maintenance
of
the
records
only
(
one
hour
of
clerical
time).

This
analysis
estimates
the
burden
for
all
training
providers
in
the
year
2004/
05
to
be
413
hours
for
training
providers
in
State­
administered
programs
and
916
hours
for
training
providers
36
in
EPA­
administered
programs.
The
total
reporting
and
recordkeeping
burden
for
all
training
providers
in
year
2004/
05
is
estimated
to
be
1,329
hours.
Similarly,
the
burden
for
all
training
providers
in
the
year
2005/
06
is
413
hours
in
State
programs
and
703
hours
under
EPA
administration,
for
a
total
of
1,116
hours.
The
burden
for
training
providers
in
2006/
07
is
413
hours
in
State
programs
and
1,241
hours
under
EPA
administration,
for
a
total
of
1,654
hours.
These
estimates
all
assume
that
the
burden
per
entity
and
per
activity
is
the
same
in
both
EPA
and
State­
administered
programs,
so
that
the
burden
in
any
area
for
a
given
year
depends
only
on
the
estimated
numbers
of
entities
and
activities
in
that
area
for
that
year.
Exhibit
6.1.
below
summarizes
the
burden
of
reporting
and
annual
recordkeeping
requirements
for
training
providers.
37
Exhibit
6.1.
Training
Providers:
Reporting
and
Recordkeeping
Burden
Estimates
Burden
Element
Professional
Hours
Clerical
Hours
Burden
Hours
Per
Training
Provider
Accreditation
Rule
Familiarization
8.00
0.00
8.00
Accreditation
Statement
7.60
2.00
9.60
Quality
Control
Plan
8.00
2.00
10.00
Annual
Burden
Recordkeeping
0.00
0.81
0.81
Reaccreditation
Burden
(
In
Addition
to
the
Annual
Burden)
Re­
accreditation
3.80
1.00
4.80
Audit*
0.20
0.40
0.60
Burden
Per
Training
Provider
Year
of
Initial
Accreditation
28.41
Second,
Third,
and
Fourth
Year
of
Operation
0.81
Year
of
Accreditation
Renewal
6.21
Training
Providers
Per
Year
Number
of
State­
Administered
Entities
Number
of
EPA­
Administered
Entities
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
New
Accreditations
4
4
4
18
18
18
Second
Year
Cohort
37
37
37
85
47
21
Third
Year
Cohort
36
36
36
65
64
35
Fourth
Year
Cohort
36
36
36
5
49
48
Accreditation
renewals
34
34
34
45
10
104
Burden
Per
Year
State­
Administered
Entities
EPA­
Administered
Entities
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
Burden
in
Hours
413
413
413
916
703
1241
Burden
Summary
Per
Year
2004/
05
2005/
06
2006/
07
Total
Burden
in
Hours
1329
1116
1654
*
This
analysis
assumes
that
10
percent
of
all
programs
applying
for
re­
accreditation
will
be
audited.
Estimates
of
burden
hours
per
event
taken
from
the
Fees
Rule
EA
and
the
previous
ICR
renewal.

Firms
Performing
Lead­
based
Paint
Activities
Initial
Certification
In
order
to
perform
the
lead­
based
paint
activities
that
are
regulated
under
sections
402(
a)
and
404,
firms
performing
lead­
based
paint
activities,
such
as
inspections
and
abatements,
38
are
required
to
seek
certification
from
the
approving
authority.
Similar
to
training
providers,
these
firms
must
first
familiarize
themselves
with
the
specific
requirements
of
the
rule.
They
must
also
determine
if
it
is
profitable
to
enter
the
market
for
lead­
based
paint
activities.
This
analysis
assumes
that
it
will
take
only
6
hours
for
firms,
as
opposed
to
8
hours
for
training
providers,
for
rule
familiarization
because
firms
do
not
need
to
compare
and
contrast
as
much
information.
If
a
firm
decides
to
enter
the
market,
a
certification
letter
must
be
sent
to
the
approving
authority
indicating
that
the
firm
will
follow
the
standards
set
forth
in
the
rule
and
will
employ
only
certified
employees.
The
cost
of
certifying
individuals
is
discussed
in
a
later
section.
The
professional
burden
estimate
of
one
hour
and
the
clerical
burden
estimate
of
0.5
hours
for
initial
certification
are
taken
from
Chapter
9
of
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis.

Annual
Reporting
and
Recordkeeping
While
performing
lead­
based
paint
activities,
firms
are
required
to
complete
and
maintain
a
number
of
reports
including:


inspection
report
describing
the
areas
inspected
and
the
results
of
the
inspection,


risk
assessment/
lead
hazard
screen
report,
which
includes
the
sampling
results
and
the
associated
hazards,


occupant
protection
plan
identifying
the
areas
requiring
abatement
and
the
methods
that
will
be
employed
to
remediate
the
hazard
and
protect
workers,
and

abatement
report
detailing
the
activities
undertaken
to
eliminate
the
hazard.

This
analysis
adopts
the
estimates
of
events
per
firm
developed
in
the
previous
ICRs.
The
total
numbers
of
events
are
calculated
by
multiplying
those
numbers
of
events
per
firm
by
the
number
of
firms
estimated
in
this
ICR.
The
estimates
for
the
burden
per
event
and
burden
per
firm
are
those
developed
in
the
previous
ICRs.

The
analysis
in
the
TSCA
Title
IV
Sections
402(
a)
and
404:
Target
Housing
and
Child­
Occupied
Facilities
Final
Rule
Regulatory
Impact
Analysis
makes
two
assumptions
about
the
certification
and
reporting
requirements
of
firms
performing
lead­
based
paint
activities.
First,
because
it
is
current
industry
practice
to
report
and
maintain
the
records
from
a
lead
inspection,
there
is
no
incremental
reporting/
recordkeeping
burden
associated
with
this
activity.
Additionally,
there
are
no
incremental
costs
associated
with
the
reporting
and
recordkeeping
of
lead
hazard
screens
as
defined
by
this
rule.
Second,
since
the
various
reports
will
be
completed
by
the
inspector,
risk
assessor,
project
designer,
or
supervisor,
no
clerical
support
will
be
required
for
the
reporting
requirements;
clerical
support
will
be
needed
for
the
recordkeeping
requirements.

The
burden
of
completing
the
reports
mentioned
above
varies
by
report
and
is
indicated
in
Exhibit
6.2.
The
reporting
burden
estimates
include
the
time
associated
with
collecting
the
information
needed
to
complete
the
reports.
In
the
upper
portions
of
that
exhibit,
the
professional
burden
per
firm
is
the
reporting
burden
per
event
multiplied
by
the
estimated
39
average
number
of
each
particular
event
per
firm.
Similarly,
the
clerical
burden
per
firm
is
the
recordkeeping
burden
per
report
multiplied
by
the
number
of
events
per
firm.
The
burden
hours
per
firm
is
then
the
sum
of
the
profession
and
clerical
burdens.

This
analysis
estimates
the
total
reporting
and
recordkeeping
burden
to
all
firms
in
year
2004/
05
to
be
374,519
hours.
The
burden
for
2005/
06
is
estimated
at
383,384
hours,
and
for
2006/
07
to
be
392,563
hours.
In
each
year
the
share
of
that
burden
in
EPA­
administered
areas
is
about
30
percent
of
the
total,
with
70
percent
in
non­
EPA­
administered
areas.
Exhibit
6.2.
below
summarizes
the
burden
of
the
reporting
and
annual
recordkeeping
requirements
to
firms.

Exhibit
6.2.
Firms:
Reporting
and
Recordkeeping
Burden
Estimates
Category
Number
of
Events
per
Firm
Reporting
Burden
per
Event
Professional
Burden
per
Firm
Recordkeeping
Burden
Per
Report
Clerical
Burden
per
Firm
Burden
Hours
Per
Firm
Certification
Rule
familiarization
1.00
6.00
6.00
0.000
0.000
6.00
Certification
letter
1.00
1.5*
1.50
0.008
0.008
1.51
*
Includes
0.5
hours
clerical
time.

Target
Housing
(
including
soil
abatements)
Risk
assessment
and
lead
hazard
screen
reports
16.11
1.86
29.96
0.008
0.134
30.09
Pre­
abatement
notifications
4.51
0.50
2.25
0.008
0.037
2.29
Occupant
protection
plan
13.97
1.00
13.97
0.008
0.116
14.08
Post­
abatement
reports
13.97
2.00
27.94
0.008
0.000
27.94
Child­
Occupied
Facilities
(
including
soil
abatements)
Risk
assessment
reports
0.12
1.09
0.14
0.008
0.001
0.14
Pre­
abatement
notifications
0.12
0.50
0.06
0.008
0.001
0.06
Occupant
protection
plan
0.12
1.00
0.12
0.008
0.001
0.13
Post­
abatement
reports
0.12
2.00
0.25
0.008
0.001
0.25
Burden
per
Firm
Firms
in
year
of
initial
certification
82.49
Firms
in
second­
year
cohort
74.98
Firms
in
third­
year
cohort
74.98
Firms
in
year
of
recertification
76.49
40
Firms
per
Year
Number
of
State­
Administered
Entities
Number
of
EPA­
Administered
Entities
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
Initial
certification
year
216
216
216
200
200
200
Second
year
cohort
1121
1121
1121
449
373
547
Third
year
cohort
1050
1050
1050
410
421
349
Recertifying
firms
982
982
982
198
384
394
Burden
per
Year
State­
Administered
Entities
EPA­
Administered
Entities
Burden
in
hours
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
Initial
certification
year
17,818
17,818
17,818
16,498
16,498
16,498
Second
year
cohort
84,053
84,053
84,053
33,666
27,968
41,014
Third
year
cohort
78,729
78,729
78,729
30,742
31,567
26,168
Recertifying
firms
75,113
75,113
75,113
15,145
29,372
30,137
Total
burden
per
year
255,713
255,713
255,713
96,051
105,405
113,817
Burden
Summary
by
Year
2004/
05
2005/
06
2006/
07
Total
Burden
in
hours
351,764
361,118
369,530
Individual
Abatement
Professionals
Burden
Initial
Certification
In
order
to
become
certified
to
perform
lead
abatement
activities,
individuals
must
apply
to
the
certifying
authority.
The
reporting
requirements
for
certification
are
the
same
for
inspectors,
risk
assessors,
and
supervisors;
and
for
workers
and
project
designers.
Certifications
are
generally
valid
for
a
period
of
three
years.
In
the
fourth
year,
individuals
trained
in
the
first
year
who
are
still
active
will
need
to
take
refresher
training
and
get
recertified.
The
time
associated
with
re­
certification
is
the
same
as
initial
certification.

The
requirements
for
certification
for
inspectors,
risk
assessors,
and
supervisors
include
submitting
proof
of:


completion
of
a
training
course,


passing
the
course
test,


meeting
the
educational
and/
or
experience
requirements
(
if
applicable),
and

passing
the
third
party
exam.

It
is
estimated
that
it
will
take
one
hour
to
gather
and
send
these
documents
per
individual.
41
The
requirements
for
project
designers
and
workers
include
proof
of:


completion
of
a
training
course,
and

meeting
the
educational
and/
or
experience
requirement
(
if
applicable)

It
is
estimated
that
it
will
take
one­
half
hour
to
gather
and
send
this
document
per
individual.

This
analysis
estimates
the
total
reporting
and
recordkeeping
burden
to
all
certified
individuals
in
each
year
covered
by
this
ICR
to
be
about
7,000
hours.
Approximately
20
percent
of
this
total
burden
is
incurred
by
individuals
in
EPA­
administered
programs.
Exhibit
6.3.
details
the
total
reporting
and
recordkeeping
burden
to
the
individual
subgroups
(
e.
g.
inspectors,
risk
assessors,
and
workers)
and
summarizes
the
individual
burden.
42
Exhibit
6.3.
Individual:
Reporting
and
Recordkeeping
Burden
Estimates
Burden
per
Individual
Inspectors,
Risk
Assessors,
and
Supervisors
Workers
and
Project
Designers
Year
of
Initial
Certification
1.0
0.5
Second
and
Third
Year
of
Operation
0.0
0.0
Year
of
Certification
Renewal
1.0
0.5
Individuals
per
Calender
Year
Number
of
State­
Administered
Entities
Number
of
EPA­
Administered
Entities
2004/
2005
2005/
2006
2006/
2007
2004/
2005
2005/
2006
2006/
2007
Inspectors
Initial
certification
624
624
624
177
177
177
Year
2
cohort
524
524
524
157
145
145
Year
3
cohort
330
330
330
83
99
91
Certification
208
208
208
53
53
63
Risk
Assessors
Initial
certification
1,168
1,168
1,168
331
331
331
Year
2
cohort
981
981
981
295
272
271
Year
3
cohort
618
618
618
156
186
171
Certification
389
389
389
100
98
117
Supervisors
Initial
certification
1,178
1,178
1,178
335
335
335
Year
2
cohort
990
990
990
297
274
273
Year
3
cohort
624
624
624
157
187
173
Certification
393
393
393
100
99
118
Workers
Initial
certification
2,240
2,240
2,240
636
636
636
Year
2
cohort
1,882
1,882
1,882
565
521
520
Year
3
cohort
1,186
1,186
1,186
299
356
328
Certification
747
747
747
191
189
224
Project
Designers
Initial
certification
74
74
74
21
21
21
Year
2
cohort
62
62
62
19
17
17
Year
3
cohort
39
39
39
10
12
11
Certification
24
24
24
6
6
7
Burden
per
Year
2004/
05
2005/
06
2006/
07
Inspectors
1062
1062
1072
Risk
Assessors
1988
1986
2005
Supervisors
2006
2005
2024
Workers
1907
1906
1923.5
Project
Designers
62.5
62.5
63
Total
Individual
Burden
in
Hours
7025.5
7021.5
7087.5
43
State
Burden
Initial
Authorization
As
of
January
2004
there
are
39
authorized
State
programs
and
three
authorized
Tribal
programs.
This
analysis
assumes
that
no
additional
States
or
Tribes
will
request
authorization
during
the
period
covered
by
this
ICR.
Based
on
this
assumption,
any
burden
associated
with
obtaining
authorization
has
already
been
incurred.
While
additional
States
may
seek
authorization
in
the
future,
information
is
not
available
at
this
time
upon
which
to
estimate
how
many
and
which
States
may
seek
authorization.
Thus,
the
number
of
entities
to
be
administered
in
these
States
is
also
not
known.

Reporting
and
Recordkeeping
The
previous
version
of
this
ICR
estimated
the
burden
to
States
of
program
authorization,
but
did
not
assume
administration
of
entities
to
be
a
burden
of
this
rule.
However,
this
revised
version
does
include
a
burden
estimate
for
the
State
and
Federal
administration
of
training
providers,
firms
and
individuals
by
using
State­
level
survey
data
collected
for
the
Economic
Analysis
of
the
Final
TSCA
Section
402(
a)(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule.

The
State­
level
survey
data
provide
burden
hours
for
the
following
activities
for
both
the
certification
and
re­
certification
of
State­
administered
training
providers,
firms,
and
individuals:

°
Application
processing
and
recordkeeping
°
Certification
exam
processing
and
recordkeeping
°
Training
course
audits
°
Fee
transactions
and
waivers
°
Issuance
of
certification
documents
°
Public
assistance/
outreach
°
Reporting
(
to
overseeing
agencies)
°
Other
management
This
analysis
multiplied
these
State­
level
survey
data
burden
hours
by
the
number
of
Stateadministered
training
providers,
firms,
and
individuals
found
in
the
Economic
Analysis
of
the
Final
TSCA
Section
402(
a)(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule
in
order
to
estimate
the
total
burden
to
all
States
of
administering
training
providers,
firms,
and
individuals.

The
total
reporting
and
recordkeeping
burden
to
all
States
with
authorized
programs
is
estimated
to
be
48,813
hours
in
each
year
covered
by
this
analysis.
This
estimate
should
be
regarded
as
the
average
burden
over
those
three
years.
It
is
likely
that
the
burden
will
vary
from
year
to
year
due
to
the
fluctuating
pattern
of
new
entries,
exits,
and
renewals.
This
analysis
does
not
capture
that
fluctuation,
but
it
does
represent
our
best
estimate
of
the
average
burden
over
this
period.
Exhibit
6.4
details
the
total
reporting
and
recordkeeping
burden
associated
with
each
44
type
of
State
and
Tribal­
administered
entity
(
e.
g.,
training
provider,
firm,
and
individual)
and
summarizes
the
burden
to
States
and
Tribes
for
program
administration.

Exhibit
6.4.
State:
Reporting
and
Recordkeeping
Burden
Estimates
State
Program
Administration
Burden
per
Entity
Type
Clerical
Hours
Technical
Hours
Managerial
Hours
Certify
Re­
certify
Certify
Re­
certify
Certify
Re­
certify
Training
Providers
3.36
1.40
28.37
10.13
8.93
7.63
Firms
0.61
0.44
4.73
4.25
2.90
2.90
Individuals
1.56
1.36
3.15
1.80
1.32
0.76
Entities
per
Year
Number
of
Activities
in
State
and
Tribal­
Administered
Areas
2004/
2005
2005/
2006
2006/
2007
Training
Providers
Accreditations
4
4
4
Re­
accreditations
34
34
34
Firms
Initial
certifications
216
216
216
Renewals
982
982
982
Individuals
Initial
certifications
5,284
5,284
5,284
Renewals
1,761
1,761
1,761
State
Program
Administration
Burden
per
Year
State
Burden
by
Entity
Type
2004/
05
2005/
06
2006/
07
Training
Providers
814
814
814
Firms
9,233
9,233
9,233
Individuals
38,766
38,766
38,766
Total
State
Burden
in
Hours
48,813
48,813
48,813
Notification
Introduction
Three
types
of
respondents
will
be
affected
by
this
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.
5Economic
Analysis
of
the
Final
TSCA
Section
402
(
a)
(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule
6
Personal
communications
with
Training
Providers.
45
Training
Providers
Under
the
rule,
pre­
course
notification
is
required
at
least
7
business
days
prior
to
the
start
of
a
lead­
based
paint
activities
course.
Re­
notification
is
required
if
the
course
date
changes.
Within
10
days
of
course
completion,
training
providers
are
required
to
submit
a
post­
course
notification.
The
information
training
providers
are
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
6.5.
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
year5
by
an
estimated
average
class
size6
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
document,
was
determined
by
calling
a
sample
of
training
providers
distributed
across
the
U.
S.
The
number
of
training
providers
and
their
levels
of
activity
were
estimated
in
the
Accreditation
and
Certification
sections
of
this
analysis.

Recordkeeping
The
training
provider
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.
46
Annual
Burden
Hours
As
presented
below
in
Exhibit
6.5.,
this
analysis
estimates
the
notification
burden
for
all
training
providers
to
be
1,351
hours
in
the
year
2004/
05,
1,350
hours
in
the
year
2005/
06,
and
1361
hours
in
2006/
07.

Exhibit
6.5.
Training
Providers:
Notification
Burden
Estimates
Category
Events
per
Training
Provider
Reporting
Hours/
Event
Recordkeeping
Hours/
Event
Total
Hours/
Event
2004/
05
2005/
06
2006/
07
Notification
Pre­
notification
2.16
2.35
2.13
0.15
0.01
0.16
Re­
notification
.19
.21
.19
0.15
0.01
0.16
Post­
notification
2.16
2.35
2.13
1.54
0.01
1.54
Annual
Total
4.51
4.91
4.45
Burden
Hours
per
Training
Provider
2004/
05
2005/
06
2006/
07
3.70
4.03
3.65
Training
Providers
per
Year
State­
Administered
EPA­
Administered
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
147
147
147
218
188
226
Total
Burden
Hours
per
Year
2004/
05
2005/
06
2006/
07
1,351
1,350
1,361
Firms
Under
the
rule,
pre­
abatement
notification
is
required
at
least
5
business
days
prior
to
the
start
of
lead­
based
paint
abatement
activities.
Re­
notification
is
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
are
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
6.6.
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
per
firm
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
firms
was
estimated
in
the
Accreditation
and
Certification
section
of
this
analysis.
The
number
of
re­
notifications
was
7
Personal
communications
with
Massachusetts
firms.
47
calculated
using
a
re­
notification
rate
of
9
percent7.
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.

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
6.6.,
this
amendment
estimates
the
notification
burden
for
all
firms
to
be
16,284
hours
in
the
year
2004/
05,
16,709
in
2005/
06,
and
17,104
in
2006/
07.

Exhibit
6.6.
Firms:
Notification
Burden
Estimates
Category
Events
per
Firm
Reporting
Hours/
Event
Record
keeping
Hours/
Event
Hours
per
Firm
Notification
Pre­
notification
14.09
0.22
0.01
3.23
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
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
3,369
3,369
3,369
1,257
1,378
1,490
Total
Burden
Hours
per
Year
2004/
05
2005/
06
2006/
07
16,284
16,709
17,104
State
Burden
Under
the
proposed
rule,
notifications
submitted
by
training
providers
and
abatement
firms
would
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
6.7.
presents
the
estimation
of
State
burden
for
the
proposed
notification
rule.
48
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
hard
copy
forms.

Annual
Burden
As
presented
below
in
Exhibit
6.7.,
this
analysis
estimates
the
notification
recordkeeping
burden
for
all
States
in
the
year
2004/
05
to
be
4,730
hours.
The
notification
recordkeeping
burden
for
all
States
is
estimated
to
be
4,736
hours
in
2005/
06
and
4,729
hours
in
2006/
07.

Exhibit
6.7.
States:
Notification
Burden
Estimates
Category
Notifications
per
Entity
Clerical
Hours/
Notification
2004/
05
2005/
06
2006/
07
Firms
15.36
15.36
15.36
0.09
Training
Providers
4.51
4.91
4.45
0.11
Entities
per
Year
2004/
05
2005/
06
2006/
07
Firms
3,369
3,369
3,369
Training
Providers
147
147
147
Notification
Burden
Hours
per
Year
2004/
05
2005/
06
2006/
07
Firms
4,657
4,657
4,657
Training
Providers
73
79
72
Total
Burden
4,730
4,736
4,729
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
personnel
are
derived
with
methods
and
from
sources
either
identical
to
or
very
similar
to
those
used
in
the
Fees
Rule
EA
and
the
previous
ICR.

The
following
fringe
and
overhead
factors
from
the
Fees
Rule
EA
and
the
Comprehensive
Assessment
Information
Rule
(
CAIR)
were
applied:
49
­
Government
Employees
1.6
(
fees
rule)
­
Managerial
Non­
government
1.64
(
CAIR)
­
Technical
Non­
government
1.65
(
CAIR)
­
Clerical
Non­
government
1.66
(
CAIR).

Non­
governmental
wages
are
drawn
from
the
full
time
mean
hourly
earnings
data
in
the
Bureau
of
Labor
Statistics
(
BLS)
National
Compensation
Survey:
Occupational
Wages
in
the
United
States,
July
2002,
Table
2­
2
(
Private
industry,
selected
occupations,
mean
hourly
earnings).
Those
hourly
wages
are
adjusted
upward
by
4.7
percent
to
account
for
inflation
from
July
2002
to
July
2004.
The
BLS
Consumer
Price
Index
for
February
2002
(
1982
­
84
=
100)
was
177.8.
The
same
index
was
186.2
in
February
2004,
for
a
two­
year
increase
of
4.7
percent.
It
is
assumed
that
this
is
a
reasonable
representation
of
the
inflation
adjustment
for
wages
from
July
2002
to
July
2004.
The
BLS
occupational
categories
used
here
may
in
some
cases
be
somewhat
different
from
the
categories
used
in
the
previous
ICR.
An
attempt
was
made
to
match
those
categories
as
closely
as
possible
to
the
ICR
labor
categories.

Wage
Rate
Calculations
for
Non­
Government
Workers
ICR
Labor
Category
BLS
Occupation
Category
2002
Wage
Rate
Wage
Inflated
by
4.7%
Wage
with
Fringe
and
Overhead
Non­
government
professional
Professional
specialty
and
technical
$
29.34
$
30.72
$
50.59
Non­
government
clerical
Administrative
support,
including
clerical
$
13.64
$
14.28
$
23.71
Inspector
Construction
inspectors
$
23.45
$
24.55
$
40.51
Risk
Assessor
Chemical
technicians
$
20.35
$
21.31
$
35.16
Project
designer
Designers
$
22.88
$
23.96
$
39.53
Supervisor
Supervisors,
painters,
paperhangers,
and
plasterers
$
19.86
$
20.79
$
34.10
Abatement
worker
Painters,
construction
and
maintenance
$
13.30
$
13.93
$
22.98
The
wage
rates
for
State
and
Federal
government
employees
are
taken
from
the
Federal
Government's
GS
Salary
Table
for
hourly
wages,
effective
January
2004.
The
wages
for
EPA
headquarters
workers
are
taken
from
the
table
including
locality
pay
for
the
Washington­
Baltimore
area.
The
wages
for
all
others
are
taken
from
table
including
locality
pay
for
"
Rest
of
US."
50
Wage
Rate
Calculations
for
Government
Workers
Labor
Category
Wage
Rate
Source
Hourly
Wage
Rate
Wage
with
Fringe
and
Overhead
States
Managerial
GS
13,
step
1
$
33.43
$
53.49
States
Technical
GS
11,
step
1
$
23.45
$
37.52
States
Clerical
GS
6,
step
1
$
14.26
$
22.82
EPA
Headquarters
Managerial
GS
13,
step
1;
Washington
DC
area
$
34.55
$
55.28
EPA
Headquarters
Technical
GS
11,
step
1;
Washington
DC
area
$
24.24
$
38.78
EPA
Headquarters
Clerical
GS
6,
step
1;
Washington
DC
area
$
14.74
$
23.58
EPA
Regional
Managerial
GS
13,
step
1;
"
Rest
of
US"
area
$
33.43
$
53.49
EPA
Regional
Technical
GS
11,
step
1;
"
Rest
of
US"
area
$
23.45
$
37.52
EPA
Regional
Clerical
GS
6,
step
1;
"
Rest
of
US"
area
$
14.26
$
22.82
Accreditation
and
Certification
Training
Providers
Based
on
the
burden
estimates
provided
in
section
6(
a)
and
the
wage
rates
discussed
above,
this
analysis
estimates
the
cost
to
training
providers
in
the
year
2004/
05
at
$
15,988
for
training
providers
in
State­
administered
programs
and
$
37,985
for
those
in
EPA­
administered
programs.
The
total
reporting
and
recordkeeping
cost
for
all
training
providers
in
the
year
2004/
05
is
estimated
to
be
$
53,972.82.
In
the
year
2005/
06
the
total
reporting
and
recordkeeping
cost
for
all
training
providers
drops
to
$
45,152,
and
then
rises
to
$
68,024
in
2006/
07.
The
main
factor
in
this
year­
to­
year
variation
is
the
number
of
program
re­
accreditations
in
the
EPAadministered
areas.
Exhibit
6.8.
below
summarizes
the
cost
of
the
reporting
and
annual
recordkeeping
requirements
for
training
providers.
51
Exhibit
6.8.
Training
Providers:
Reporting
and
Recordkeeping
Cost
Estimates
Cost
Element
Professional
($
50.59/
hr)
Clerical
($
23.71/
hr)
Burden
Hours
Cost
($)
Per
Training
Provider
Accreditation
Rule
Familiarization
8.00
0.00
8.00
$
404.72
Accreditation
Statement
7.60
2.00
9.60
$
431.90
Quality
Control
Plan
8.00
2.00
10.00
$
452.14
Annual
Cost
Recordkeeping*
0.00
0.81
0.81
$
19.21
Quadrennial
Cost
(
In
Addition
to
Annual
Cost)
Re­
accreditation
3.80
1.00
4.80
$
215.95
Audit**
0.20
0.40
0.60
$
19.60
Cost
Per
Training
Provider
Year
of
Initial
Accreditation
$
1307.97
Second,
Third
and
FourthYear
of
Operation
$
19.21
Year
of
Re­
accreditation
$
254.76
Cost
Per
Year
State­
Administered
Entities
EPA­
Administered
Entities
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
New
accreditations
5,231.88
5,231.88
5,231.88
23,543.46
23,543.46
23,543.46
Second
year
cohort
710.77
710.77
710.77
1,632.85
902.87
403.41
Third
year
cohort
691.56
691.56
691.56
1,248.65
1,229.44
672.35
Fourth
year
cohort
691.56
691.56
691.56
96.05
941.29
922.08
Re­
accreditations
8,661.84
8,661.84
8,661.84
11,464.20
2,547.60
26,495.04
Cost
for
all
training
providers
$
15,987.61
$
15,987.61
$
15,987.61
$
37,985.21
$
29,164.66
$
52,036.34
Cost
Summary
Per
Year
2004/
05
2005/
06
2006/
07
Total
Cost
$
53,972.82
$
45,152.27
$
68,023.95
*
Recordkeeping
burden
estimate
adopted
from
the
previous
ICR.
**
This
analysis
assumes
that
10
percent
of
all
programs
applying
for
re­
accreditation
will
be
audited.

Costs
for
Firms
Performing
Lead­
based
Paint
Activities
The
recordkeeping
costs
fall
under
two
categories:
labor
and
materials.
The
cost
estimates
used
in
this
analysis
rely
heavily
on
the
burden
estimates
developed
for
the
analysis
of
section
406
(
USEPA,
1993c).
Recordkeeping
labor
costs
consist
of
the
time
associated
with
the
actual
filing
of
the
records.
The
analysis
of
section
406
estimates
that
the
time
associated
with
filing
each
report,
regardless
of
size,
is
0.5
minutes
or
0.0083
hours.
Copying
costs
are
calculated
based
on
$
0.06
per
copy
multiplied
by
the
total
number
of
pages
to
be
copied;
only
one
copy
is
required.
52
As
detailed
in
section
6(
a),
the
total
number
of
events
are
based
on
the
prior
ICR.
The
wage
rates
used
to
represent
professional
and
clerical
labor
costs
are
the
same
as
those
detailed
above
for
training
providers.

Based
on
the
burden
estimates
provided
in
section
6(
a)
and
the
professional
and
clerical
wage
rates
described
earlier,
this
analysis
estimates
the
cost
to
all
firms
in
the
year
2004/
05
at
$
9,157,863
for
firms
in
State­
administered
programs
and
$
3,449,384
for
firms
in
EPAadministered
programs.
The
total
reporting
and
recordkeeping
cost
to
all
firms
for
the
year
2004/
05
is
estimated
to
be
about
$
12
million.
In
years
2004/
05
and
2005/
06,
the
total
annual
reporting
and
recordkeeping
cost
for
all
firms
is
estimated
to
be
somewhat
higher,
around
$
13
million.
Exhibit
6.9.
below
summarizes
the
cost
of
the
reporting
and
annual
recordkeeping
requirements
for
firms.
53
Exhibit
6.9.
Firms:
Reporting
and
Recordkeeping
Cost
Estimates
Category
Discipline
(
for
wage
rate
determination)
Average
Reporting
Cost
Per
Firm
Average
Recordkeeping
Cost
Per
Firm*
Total
Number
of
Pages
Per
Firm
Material
cost
(@
$
0.06per
page)
Average
Cost
Per
Firm
Certification
Rule
Familiarization
($
50.59/
hr)
professional
$
303.54
0
$
303.54
Certification
letter
($
50.59/
hr)
professional
$
75.89
$
0.09
1.39
$
0.08
$
76.15
Target
Housing
(
including
Soil
Abatements)
Risk
Assessment
and
lead
hazard
screen
reports
($
35.16/
hr)
risk
assessor
$
1,053.39
$
3.18
64.43
$
3.87
$
1,060.44
Pre­
Abatement
Notifications
($
34.10/
hr)
supervisor
$
76.73
$
0.88
9.03
$
0.54
$
78.14
Occupant
Protection
Plan
($
39.53/
hr)
designer
$
552.23
$
2.75
41.86
$
2.51
$
557.49
Post­
Abatement
Reports
($
34.10/
hr)
supervisor
$
952.75
0
41.86
$
2.51
$
955.26
Child­
Occupied
Facilities
(
including
Soil
Abatements)
Risk
Assessment
and
lead
hazard
screen
reports
($
35.16/
hr)
risk
assessor
$
4.92
$
0.02
0.49
$
0.03
$
4.98
Pre­
Abatement
Notifications
($
34.10/
hr)
supervisor
$
2.05
$
0.02
0.25
$
0.01
$
2.08
Occupant
Protection
Plan
($
39.53/
hr)
designer
$
4.74
$
0.02
0.25
$
0.01
$
4.78
Post­
Abatement
Reports
($
34.10/
hr)
supervisor
$
8.53
$
0.02
0.25
$
0.01
$
8.56
Cost
Per
Year
Year
of
Initial
Certification
$
3,051.43
Second
and
Third
Year
of
Operation
$
2,671.73
Year
of
Certification
Renewal
$
2,747.89
Cost
Per
Year
State­
Administered
Entities
EPA­
Administered
Entities
2004/
2005
2005/
2006
2006/
2007
2004/
2005
2005/
2006
2006/
2007
Cost
$
9,157,863
$
9,157,863
$
9,157,863
$
3,449,384
$
3,786,829
$
4,086,825
Cost
Summary
Per
Year
2004/
05
2005/
06
2006/
07
Total
Cost
$
12,607,247
$
12,944,692
$
13,244,687
*
.0083
hours
of
non­
governmental
clerical
burden
per
report
@
$
23.71/
hr
54
Individuals
Performing
Lead
Abatement
Based
on
the
cost
estimates
provided
in
section
6(
a)
and
the
wage
rates
developed
earlier,
this
analysis
estimates
the
total
reporting
and
recordkeeping
cost
to
all
individuals
in
year
2004/
05
to
be
$
227,618.
Approximately
22
percent
of
this
total
cost
is
incurred
by
individuals
in
EPAadministered
programs.
Both
the
total
cost
and
the
distribution
of
costs
between
EPA
and
non­
EPA
areas
are
very
similar
in
each
of
the
three
years
under
analysis.
Exhibit
6.10.
details
the
total
reporting
and
recordkeeping
cost
to
the
individual
subgroups
(
e.
g.,
inspectors,
risk
assessors,
and
workers)
and
summarizes
the
individual
cost.

Exhibit
6.10.
Individuals:
Reporting
and
Recordkeeping
Cost
Estimates/
Cost
per
Year
2004/
05
2005/
06
2006/
07
Inspectors
($
40.51/
hr.)
$
43,022
$
43,022
$
43,427
Risk
Assessors
($
35.16/
hr.)
$
69,898
$
69,828
$
70,496
Supervisors
($
34.10/
hr.)
$
68,405
$
68,371
$
69,018
Abatement
Workers
($
22.98/
hr.)
$
43,823
$
43,800
$
44,202
Project
Designers
($
39.53/
hr.)
$
2,471
$
2,471
$
2,490
Total
Individual
Cost
$
227,618
$
227,490
$
229,633
State
Costs
The
reporting/
recordkeeping
requirement
costs
include
the
wages
associated
with
the
burden
estimated
in
Section
6(
a).
The
methods
used
to
establish
wage
rates
are
covered
earlier
in
this
analysis.
Those
wage
rates
are
$
53.49
for
managerial
staff,
$
37.52
for
technical
staff
and
$
22.82
for
clerical
staff.

The
total
reporting
and
recordkeeping
cost
to
all
States
with
authorized
programs
in
each
year
of
the
analysis
is
estimated
to
be
$
1,858,856.
As
discussed
earlier,
each
year
in
State
and
Tribal­
administered
areas
is
assumed
to
be
identical,
for
ease
of
modeling.
It
is
likely
that
the
actual
costs
will
vary
from
year
to
year.
These
estimates
are
intended
to
represent
the
average
annual
costs.
Exhibit
6.11.
details
the
total
reporting
and
recordkeeping
cost
to
each
type
of
Stateadministered
entity
(
e.
g.,
training
provider,
firm,
and
individual).

Exhibit
6.11.
States:
Reporting
and
Recordkeeping
Cost
Estimates
2004/
05
2005/
06
2006/
07
Training
Providers
$
34,360
$
34,360
$
34,360
Firms
$
393,625
$
393,625
$
393,625
Individuals
$
1,430,871
$
1,430,871
$
1,430,871
Total
State
Cost
$
1,858,856
$
1,858,856
$
1,858,856
55
Notification
The
cost
estimates
addressed
in
this
section
are
based
on
the
burden
estimates
discussed
in
section
6(
a).

Training
Providers
The
fully
loaded
wage
rate
used
to
estimate
training
providers'
notification
costs
is
the
nongovernment
clerical
rate,
$
23.71
per
hour.
Additionally,
training
provider
costs
include
a
$
0.37
postage
stamp
for
mailing
the
notification
and
$
0.06
for
a
one
page
copy
of
the
notification
for
the
firm's
records.

Annual
Costs
As
presented
below
in
Exhibit
6.12.,
based
on
the
burden
estimates
provided
in
section
6(
a)
and
the
wage
rates
discussed
above,
this
analysis
estimates
the
notification
costs
for
all
training
providers
in
the
year
2004/
05
at
$
32,936.
The
total
notification
cost
for
all
training
providers
in
2005/
06
is
$
32,893,
and
$
33,194
in
2006/
07.

Exhibit
6.12.
Training
Providers:
Notification
Cost
Estimates
Category
Events
per
Training
Provider
Reporting
Cost/
Event
Recordkeeping
Cost/
Event
Materials
Cost/
Event
Total
Cost/
Event
($
23.71/
hr)
2004/
05
2005/
06
2006/
07
Notification
Pre­
notification
2.16
2.35
2.13
$
3.56
$
0.24
$
0.43
$
4.22
Re­
notification
.19
.21
.19
$
3.56
$
0.24
$
0.43
$
4.22
Post­
notification
2.16
2.35
2.13
$
36.51
$
0.24
$
0.43
$
37.18
Cost
per
Training
Provider
2004/
05
2005/
06
2006/
07
$
90
$
98
$
89
Training
Providers
per
Year
State­
Administered
EPA­
Administered
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
147
147
147
218
188
226
Total
Cost
per
Year
2004/
05
2005/
06
2006/
07
$
32,936
$
32,893
$
33,194
56
Firms
Performing
Lead­
based
Paint
Activities
Costs
The
fully
loaded
wage
rate
used
to
estimate
certified
firms'
notification
costs
is
the
nongovernment
clerical
rate,
$
23.71
per
hour.
Additionally,
training
provider
costs
include
a
$
0.37
postage
stamp
for
mailing
the
notification
and
$
0.06
for
a
one
page
copy
of
the
notification
for
the
firm's
records.

Annual
Costs
As
presented
below
in
Exhibit
6.13.,
based
on
the
burden
estimates
provided
in
section
6(
a)
and
the
wage
rates
discussed
above,
this
analysis
estimates
the
costs
associated
with
notification
for
all
firms
in
the
year
2004/
05
at
$
428,516.
The
notification
cost
for
all
firms
is
estimated
to
be
$
429,373
in
2005/
06
and
$
439,505
in
2006/
07.

Exhibit
6.13.
Firms:
Notification
Cost
Estimates
Cost
Element
Events
per
Firm
Reporting
Cost/
Event
Recordkeeping
Cost/
Event
Materials
Cost/
Event
Cost
per
Firm
($
23.71/
hr)

Notification
Pre­
notification
14.09
$
5.22
$
0.24
$
0.43
$
82.99
Re­
notification
1.27
$
5.22
$
0.24
$
0.43
$
7.48
Annual
Total
15.36
$
90.47
Firms
per
Year
State­
Administered
EPA­
Administered
2004/
05
2005/
06
2006/
07
2004/
05
2005/
06
2006/
07
3,369
3,369
3,369
1,257
1,377
1,489
Total
Cost
per
Calender
Year
2000
2001
2002
$
428,516
$
429,373
$
439,505
State
Costs
As
indicated
above,
the
fully
loaded
wage
rate
for
State
government
clerical
staff
is
$
22.82.

Annual
Costs
As
presented
below
in
Exhibit
6.14.,
this
analysis
estimates
the
notification
cost
for
all
States
combined
in
the
year
2004/
05
to
be
$
107,944.
The
notification
cost
for
all
States
is
estimated
to
be
$
108,192
in
2005/
06,
and
$
107,922
in
2006/
07.
57
Exhibit
6.14.
States:
Notification
Cost
Estimates
for
All
States
Combined
Category
Notifications
per
Entity
Clerical
Cost/
Notification
($
22.82/
hr)
2004/
05
2005/
06
2006/
07
Firms
15.36
15.36
15.36
$
2.05
Training
Providers
4.51
4.91
4.45
$
2.51
Entities
per
Year
2004/
05
2005/
06
2006/
07
Firms
3,369
3,369
3,369
Training
Providers
147
147
147
Cost
per
Year
2004/
05
2005/
06
2006/
07
Firms
$
106,280
$
106,280
$
106,280
Training
Providers
$
1,664
$
1,812
$
1,642
Total
Burden
$
107,944
$
108,092
$
107,922
6(
c)
Estimating
Agency
Burden
and
Cost
Accreditation
and
Certification
EPA
Burden
Although
sections
402(
a)
and
404
do
not
require
that
States
develop
a
lead
program,
it
is
encouraged.
As
discussed
in
section
6(
a)
of
this
ICR,
39
States
and
three
Tribal
areas
have
sought
and
been
granted
authorization
to
administer
their
own
programs
under
TSCA
Section
402.
This
ICR
assumes
that
programs
for
the
remaining
States
will
be
administered
by
EPA.
Thus
the
burden
on
EPA
due
to
reviewing
and
approving
State
applications
to
administer
their
own
programs
has
already
been
incurred.
If
additional
States
seek
authorization,
the
cost
to
EPA
of
reviewing
and
approving
these
applications
will
be
offset
by
the
reduction
in
EPA
hours
used
to
administer
the
programs.

This
analysis
estimates
the
agency
burden
of
administering
training
providers,
firms,
and
individuals
in
unauthorized
States
by
using
State­
level
survey
data
collected
for
the
Economic
Analysis
of
the
Final
TSCA
Section
402(
a)(
3)
Lead­
Based
Paint
Accreditation
and
Certification
Fee
Rule
and
assumes
that
the
EPA
Regional
Offices
will
play
the
major
role
in
administering
the
Section
402
requirements
in
States
without
their
own
programs,
while
EPA
Headquarters
will
coordinate
the
regional
activities,
provide
public
assistance
and
perform
other
activities.

Based
on
these
assumptions
and
data,
the
total
burden
to
EPA
regions
in
year
2004/
05
is
estimated
to
be
6,509
hours.
In
2005/
06
the
total
reporting
and
recordkeeping
burden
to
EPA
regions
is
estimated
to
be
7,230,
and
9,437
in
2006/
07.
Exhibit
6.15.
details
the
total
reporting
and
recordkeeping
burden
to
each
type
of
EPA­
administered
entity
(
e.
g.,
training
provider,
firm,
and
individual).
58
In
addition
the
annual
burden
to
EPA
Headquarters
is
estimated
to
be
728
hours
for
each
calender
year
of
the
analysis
(
See
Exhibit
6.16.).
Thus
the
total
EPA
burden
in
the
year
2004/
05
is
6,237,
then
7,958
in
2005/
06
and
10,165
hours
in
2006/
07.

Exhibit
6.15.
EPA
Regions:
Reporting
and
Recordkeeping
Burden
Estimates
for
Accreditation
and
Certification
Activities
EPA
Region
Burden
per
Entity
Type
Clerical
Hours
Technical
Hours
Managerial
Hours
Certify
Re­
certify
Certify
Re­
certify
Certify
Re­
certify
Training
Providers
3.36
1.40
28.37
10.13
8.93
7.63
Firms
0.61
0.44
4.73
4.25
2.90
2.90
Individuals
1.56
1.36
3.15
1.80
1.32
0.76
Entities
per
Year
Number
of
EPA­
Administered
Entities
2004/
05
2005/
06
2006/
07
Training
Providers
New
accreditations
18
18
18
Second
year
cohort*
85
47
21
Third
year
cohort*
65
64
35
Fourth
year
cohort*
5
49
48
re­
accreditations
45
10
104
Firms
New
certifications
200
200
200
Second
year
cohort*
449
372
546
Third
year
cohort*
410
421
349
Re­
certifications
198
384
394
Individuals
New
certifications
1500
1500
1500
Second
year
cohort*
1,333
1,228
1,225
Third
year
cohort*
706
840
774
Re­
certifications
450
445
529
Burden
per
Year
2004/
05
2005/
06
2006/
07
Training
Providers
1,594
923
2,725
Firms
3,151
4,563
4,638
Individuals
1,764
1,744
2,074
Total
EPA
Regional
Burden
6,509
7,230
9,437
*
No
reporting
and
recordkeeping
burden/
cost
incurred.
59
Exhibit
6.16.
EPA
Headquarters:
Reporting
and
Recordkeeping
Burden
Estimates
for
Accreditation
and
Certification
Activities
Annual
EPA
Headquarters
Burden
Hours
Clerical
Burden
Technical
Burden
Managerial
Burden
Coordinate
with
Regions*
0.00
104.00
0.00
Public
Assistance*
104.00
104.00
0.00
Other*
104.00
104.00
208.00
Annual
Burden
to
Headquarters
728
*
HQ
administrative
burden
from
the
Fees
Rule
EA;
for
all
EPA­
administered
States
EPA
Cost
The
burden
on
EPA
associated
with
the
administration
of
the
States
and
Tribal
areas
that
have
not
been
approved
to
administer
their
own
programs
were
estimated
above.
The
labor
rates
and
overhead
and
fringe
loadings
were
discussed
earlier.
Based
on
these
estimates,
the
reporting
and
recordkeeping
cost
to
EPA
regions
in
year
2004/
05
is
estimated
to
be
$
598,864.
In
2005/
06
the
total
reporting
and
recordkeeping
cost
to
EPA
regions
rises
to
$
629,842,
and
then
rises
again
to
$
721,877.
These
increases
are
due
to
the
year­
to­
year
variability
in
accreditation
and
certification
activities,
and
do
not
necessarily
represent
a
trend.
Exhibit
6.17.
details
the
total
reporting
and
recordkeeping
cost
to
each
type
of
EPA­
administered
entity
(
e.
g.,
training
provider,
firm,
and
individual).
The
annual
cost
to
EPA
Headquarters
is
estimated
to
be
$
28,501
for
each
year
of
the
analysis
(
See
Exhibit
6.18.).
Thus
the
total
EPA
cost
in
year
2004/
05
is
$
627,365,
$
658,343
in
year
2005/
06,
and
$
750,378
in
year
2006/
07.

There
will
be
additional
costs
involved
in
transitioning
from
an
existing
Federal
program
to
an
authorized
State
program
in
States
that
receive
authorization
after
the
Federal
program
has
been
fully
established.
Currently,
we
do
not
have
a
way
of
estimating
the
additional
burden,
nor
the
number
of
State
programs
potentially
affected.
Such
changes
would
also
reduce
the
annual
burden
on
EPA.
No
such
transitions
are
anticipated
during
the
period
of
this
ICR.

Exhibit
6.17.
EPA
Regions:
Reporting
and
Recordkeeping
Cost
Estimates
for
Accreditation
and
Certification
Activities
2004/
05
2005/
06
2006/
07
Training
Providers
$
66,045
$
37,340
$
114,434
Firms
$
133,577
$
193,957
$
197,203
Individuals
$
399,242
$
398,545
$
410,240
Total
EPA
Regional
Cost
$
598,864
$
629,842
$
721,877
60
Exhibit
6.18.
EPA
Headquarters:
Reporting
and
Recordkeeping
Cost
Estimates
for
Accreditation
and
Certification
Activities
Annual
EPA
Headquarters
Cost
Clerical
($
23.58/
hr.)
Technical
($
38.78/
hr.)
Managerial
($
55.28/
hr.)
Coordinate
with
Regions
$
0.00
$
4,033
$
0.00
Public
Assistance
$
2,452
$
4,033
$
0.00
Other
$
2,452
$
4,033
$
11,498
Annual
Cost
to
Headquarters
$
28,501
Notification
Agency
Burden
Under
the
rule,
notifications
submitted
by
training
providers
and
abatement
firms
will
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
proposed
rule
is
detailed
in
section
4
of
this
document.
The
following
sections
discuss
how
the
recordkeeping
burden
estimates
were
developed.
Exhibit
6.19.
presents
the
estimation
of
EPA
burden
for
the
notification
rule.

Recordkeeping
The
number
of
notification
events
per
entity
is
the
sum
of
pre­
course,
post­
course,
and
renotifications
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
hard
copy
forms.
The
number
of
entities­
administered
by
the
EPA
program
was
estimated
in
section
6(
a)
of
this
analysis.

Annual
Burden
As
presented
below
in
Exhibit
6.19.,
this
analysis
estimates
the
notification
recordkeeping
burden
for
EPA
in
the
year
2004/
05
to
be
1,846
hours.
The
notification
recordkeeping
burden
for
EPA
is
estimated
to
rise
slightly
to
2,006
hours
during
the
year
2005/
06,
and
then
rise
slightly
again
to
2,169
in
2006/
07.
61
Exhibit
6.19.
EPA:
Notification
Burden
Estimates
Category
Notifications
per
Entity
Clerical
Hours/
Notification
2004/
05
2005/
06
2006/
07
Firms
15.36
15.36
15.36
0.09
Training
Providers
4.51
4.91
4.45
0.11
Entities
per
Year
2004/
05
2005/
06
2006/
07
Firms
19,308
21,151
22,871
Training
Providers
218
188
226
Burden
Hours
per
Year
2004/
05
2005/
06
2006/
07
Firms
1,738
1,904
2,058
Training
Providers
108
102
111
Total
Burden
1,846
2,006
2,169
Agency
Cost
The
notification
costs
are
based
on
the
burden
estimated
in
Section
6(
a)
and
the
EPA
Regional
clerical
wage
rate
estimated
earlier.
The
final
loaded
wage
rate
is
$
22.82
for
EPA
Regional
clerical
staff.

Annual
Cost
As
presented
below
in
Exhibit
6.20.,
this
analysis
estimates
the
EPA
cost
associated
with
notifications
in
the
year
2004/
05
to
be
$
42,123.
That
cost
is
expected
to
rise
slightly
to
$
45,757
in
2005/
06,
and
then
rise
slightly
again
to
$
49,498
in
2006/
07.

Exhibit
6.20.
EPA:
Notification
Cost
Estimates
Category
Notifications
per
Entity
Clerical
Cost/
Notification
($
22.82/
hr)
2004/
05
2005/
06
2006/
07
Firms
15.36
15.36
15.36
$
2.05
Training
Providers
4.51
4.91
4.45
$
2.51
Entities
per
Year
2004/
05
2005/
06
2006/
07
Firms
19,308
21,151
22,871
Training
Providers
218
188
226
Cost
per
Year
2004/
05
2005/
06
2006/
07
Firms
$
39,655
$
43,440
$
46,973
Training
Providers
$
2,468
$
2,317
$
2,525
Total
Annual
Cost
$
42,123
$
45,757
$
49,498
62
6(
d)
Bottom
Line
Burden
Hours
and
Cost
(
i)
Respondent
Tally
Respondent
Burden
and
Cost
Accreditation
and
Certification
Burden
and
Cost
2004/
05
2005/
06
2006/
07
Burden
Hours
Costs
Burden
Hours
Costs
Burden
Hours
Costs
Training
Providers
1,329
$
53,973
1,116
$
45,152
1,654
$
68,024
Firms
Performing
Lead­
based
Paint
Activities
351,764
$
12,607,247
361,118
$
12,944,692
369,530
$
13,244,825
Individuals
7,026
$
227,618
7,022
$
227,490
7,088
$
229,633
States
48,813
$
1,858,856
48,813
$
1,858,856
48,813
$
1,858,856
Total
408,932
$
14,747,694
418,069
$
15,076,190
427,085
$
15,401,338
Notification
Burden
and
Cost
2004/
05
2005/
06
2006/
07
Burden
Hours
Costs
Burden
Hours
Costs
Burden
Hours
Costs
Training
Providers
1,351
$
32,936
1,350
$
32,893
1,361
$
33,194
Firms
Performing
Lead­
based
Paint
Activities
16,284
$
428,516
16,709
$
429,373
17,104
$
439,505
States
4,730
$
107,944
4,736
$
108,092
4,729
$
107,922
Total
22,365
$
569,396
22,795
$
570,358
23,194
$
580,621
Over­
All
Total
431,297
$
15,317,090
440,864
$
15,646,548
450,279
$
15,981,959
The
respondent
burden
and
cost
for
the
collection
of
this
information
in
the
year
2004/
2005
is
estimated
to
be
2,680
hours
and
$
86,909
for
the
estimated
365
training
providers;
368,048
hours
and
$
13,055,763
for
the
estimated
4,626
firms
performing
lead­
based
paint
activities;
7,026
hours
and
$
227,618
for
the
18,269
individual
lead
abatement
personnel;
and
53,543
hours
and
$
1,966,800
for
the
States.
That
is
an
average
burden
of
7.34
hours
per
training
provider,
79.56
hours
per
certified
firm,
and
0.38
hours
per
certified
individual.
The
overall
burden
and
cost
for
this
year
for
all
respondents
is
431,297
hours
and
$
15,317,090.

The
respondent
burden
and
cost
for
the
collection
of
this
information
in
the
year
2005/
2006
is
estimated
to
be
2,466
hours
and
$
78,045
for
the
estimated
335
training
providers;
377,827
hours
and
$
13,374,065
for
the
estimated
4,746
firms
performing
lead­
based
paint
activities;
7,022
hours
and
$
227,490
for
the
18,293
individual
lead
abatement
personnel;
and
53,543
hours
and
$
1,966,948
for
the
States.
That
is
an
average
burden
of
7.36
hours
per
training
provider,
79.61
hours
per
certified
firm,
and
0.38
hours
per
certified
individual.
The
overall
burden
and
cost
for
this
year
for
all
respondents
is
440,864
hours
and
$
15,646,548.

The
respondent
burden
and
cost
for
the
collection
of
this
information
in
the
year
2006/
2007
is
estimated
to
be
3,015
hours
and
$
101,218
for
the
estimated
373
training
providers;
386,634
hours
63
and
$
13,684,330
for
the
estimated
4,858
firms
performing
lead­
based
paint
activities;
7,088
hours
and
$
229,633
for
the
18,308
individual
lead
abatement
personnel;
and
53,543
hours
and
$
1,966,778
for
the
States.
That
is
an
average
burden
of
8.08
hours
per
training
provider,
79.59
hours
per
certified
firm,
and
0.39
hours
per
certified
individual.
The
overall
burden
and
cost
for
this
year
for
all
respondents
is
450,279
hours
and
$
15,981,959.

The
average
overall
annualized
burden
and
cost
for
the
three
years
covered
by
this
ICR
for
all
respondents
is
440,813
hours
and
$
15,648,532.

(
ii)
Agency
Tally
Agency
Burden
and
Cost
EPA
Accreditation
and
Certification
Burden
and
Cost
2004/
2005
2005/
2006
2006/
2007
Burden
Hours
Costs
Burden
Hours
Costs
Burden
Hours
Costs
Regions
6,509
$
598,864
7,230
$
629,842
9,437
$
721,877
Headquarters
728
$
28,501
728
$
28,501
728
$
28,501
Total
7,237
$
627,365
7,958
$
658,343
10,165
$
750,378
EPA
Notification
Burden
and
Cost
2004/
2005
2005/
2006
2006/
2007
Burden
Hours
Costs
Burden
Hours
Costs
Burden
Hours
Costs
1,846
$
42,123
2,006
$
45,757
2,169
$
49,498
Over­
All
Totals
9,083
$
669,488
9,964
$
704,100
12,334
$
799,876
The
Agency
burden
and
cost
for
the
collection
of
this
information
is
estimated
to
be
9,083
hours
and
$
669,488
in
the
year
2004/
2005;
9,964
hours
and
$
704,100
in
2005/
2006;
and
12,334
hours
and
$
799,826
in
2006/
2007.

The
average
overall
annualized
burden
and
cost
for
the
Agency
for
the
three
years
covered
by
this
ICR
is
10,460
hours
and
$
724,488.

6(
e)
Reasons
for
Change
in
Burden
This
request
reflects
an
increase
in
the
total
estimated
burden
of
49,639
hours
(
from
391,174
hours
to
440,813
hours)
from
that
currently
in
the
OMB
inventory.
This
increase
represents
an
adjustment
in
the
number
of
respondents
and/
or
the
number
of
activities
or
events
for
which
respondents
must
provide
information,
based
on
EPA's
experience
since
the
approval
of
the
most
recent
ICR.

The
burden
in
this
ICR
covers
the
activities
that
were
reported
in
two
previous
ICRs.
In
this
section
the
Accreditation
and
Certification
portions
of
this
ICR
will
be
compared
to
those
same
activities
as
reported
in
1999.
Then
a
comparison
will
be
made
between
the
Notification
portions
of
this
ICR
and
an
earlier
ICR
that
covered
those
same
activities.
64
Accreditation
and
Certification
The
previous
ICR
covering
Accreditation
and
Certification
activities
was
developed
before
data
on
the
numbers
of
activities
were
available,
and
relied
on
burden
estimates
developed
in
the
TSCA
402/
404
Regulatory
Impact
Analysis
and
experience
with
other
similar
rules,
such
as
the
Asbestos
MAP.
Data
are
now
available
on
the
level
of
activities
under
EPA
administration,
permitting
a
more
direct
projection
of
activities
over
the
period
of
this
ICR.

It
is
difficult
to
directly
compare
the
burden
projected
by
the
previous
ICR
and
this
one,
since
the
previous
ICR
projected
extreme
year­
to­
year
variability
in
the
accreditation
and
certification
activity
projected
in
the
previous
ICR.
That
variability
was
due
to
the
expected
high
level
of
activity
at
the
beginning
of
the
program
caused
by
the
initial
wave
of
accreditation
and
certification.
However,
it
is
possible
to
make
comparisons
to
the
average
burdens
and
also
to
look
at
specific
elements
that
determine
burden.

Comparison
of
Average
Annual
Burden
Estimates
over
Three
Years,
Accreditation
and
Certification
Only,
1991
and
2004
ICRs
Burden
Hours
Percent
Increase
Absolute
Increase
Share
of
Increase
1999
ICR
2004
ICR
Training
providers
742
1,366
84
%
624
1.3
%

Certified
firms
317,328
360,804
14
%
43,476
92.9
%

Certified
individuals
7,216
7,045
­
2
%
­
171
­
0.4
%

States
45,928
48,813
6
%
2,885
6.2
%

Total
371,214
418,029
13
%
46,814
The
largest
share
of
the
burden
increase,
about
93%,
is
in
the
burden
on
certified
firms.
The
estimates
of
burden
per
firm
are
the
same
in
this
ICR
as
in
the
previous
one.
This
ICR
estimates
that
there
will
be
about
1,375
certified
firms
on
average
in
EPA­
administered
areas,
and
an
average
of
3,370
in
non­
EPA
areas,
for
a
total
of
4,745.
The
previous
ICR
projected
1,170
firms
in
EPAadministered
areas
and
2,900
in
non­
EPA
areas,
for
a
total
of
about
4,070.
That
is
an
increase
of
about
16
percent.
The
percentage
burden
increase
in
burden
hours
was
a
bit
smaller
at
13
percent.
This
minor
discrepancy
was
probably
due
to
the
reduction
in
the
numbers
of
first­
time
certifications
after
the
initial
wave
associated
with
the
program
start­
up.
Except
for
that
small
discrepancy,
the
increase
in
the
total
burden
on
firms
is
due
to
a
larger
estimate
of
the
number
of
firms
engaged
in
abatement
activities.

The
burden
on
training
providers
is
a
small
part
of
the
overall
burden,
but
it
went
up
by
a
substantial
percentage.
This
is
due
to
the
fact
that
first­
time
accreditations
of
training
providers
are
running
at
a
higher
rate
in
the
EPA­
administered
areas
than
had
been
anticipated.
65
The
burden
on
States
has
gone
up
about
6
percent.
This
increase
is
primarily
due
to
the
increase
in
the
number
of
approved
State
and
Tribal­
administered
programs.
The
previous
ICR
was
based
on
an
assumption
of
32
approved
State
programs.
This
ICR
is
based
on
the
39
State
programs
that
were
projected
to
be
approved
by
the
fifth
year
of
this
ICR,
as
projected
in
the
Fees
Rule
EA.
This
is
a
close
match
to
the
39
States
and
three
Tribes
that
have
been
authorized
as
of
January
2004.

The
average
annual
cost
of
this
burden
is
about
$
15
million,
in
comparison
to
the
$
12
million
average
annual
cost
estimated
in
the
previous
ICR.
That
represents
an
increase
of
25
percent.
This
is
due
to
the
13
percent
increase
in
burden
hours
along
with
the
increase
in
hourly
labor
costs.

Notification
The
notification
portion
of
this
ICR
estimates
that
the
burden
on
training
providers,
firms,
and
States
will
be
roughly
22,000
to
23,000
hours
per
year.
The
previous
ICR
estimated
a
burden
of
about
18,000
to
20,000
hours
per
year.
Therefore
the
estimated
total
burden
for
these
activities
is
about
3,000
to
4,000
hours
more
per
year
than
the
earlier
ICR.
Since
the
burden
per
activity
or
event
was
assumed
to
be
the
same
in
both
ICRs,
this
difference
is
due
to
a
higher
estimate
of
the
number
of
expected
activities
or
events.
This
difference
is
in
turn
due
to
the
method
used
to
estimate
the
frequency
of
activities.
The
earlier
ICR
was
based
on
projections
made
prior
to
the
start
of
any
of
these
activities.
The
estimates
in
this
ICR
are
based
at
least
in
part
on
the
data
on
activities
that
EPA
has
accumulated
over
the
past
five
years.

6(
f)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0155,
is
estimated
to
range
between
0.4
hours
and
79.6
hours
per
response,
depending
on
the
type
of
respondent.
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
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.

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,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OPPT­
2004­
0081,
which
is
available
for
public
viewing
at
the
Pollution
Prevention
and
Toxics
66
Docket
in
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
1544
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
EPA
Dockets
(
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
EPA
Docket
ID
No.
OPPT­
2004­
0081
and
OMB
control
number
2070­
0155
in
any
correspondence.
