Supporting
Statement
for
a
Request
for
OMB
Review
under
the
Paperwork
Reduction
Act
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title:
Lead­
Based
Paint
Pre­
Renovation
Information
Dissemination
­
TSCA
Sec.
406(
b)

EPA
ICR
No.:
1669.04
OMB
Control
No.:
2070­
0158
1(
b)
Short
Characterization
Section
406(
b)
of
Title
IV
of
the
Toxic
Substances
Control
Act
(
TSCA)(
15
U.
S.
C.
2686,
see
Appendix
1)
requires
the
U.
S.
Environmental
Protection
Agency
(
EPA)
to
promulgate
regulations
requiring
certain
persons
who
perform
renovations
of
target
housing
for
compensation
to
provide
a
lead
hazard
information
pamphlet
(
developed
under
section
406(
a)
of
TSCA)
to
the
owner
and
occupant
of
such
housing
prior
to
commencing
the
renovation.
Target
housing
is
defined
as
any
housing
constructed
prior
to
1978,
except
housing
for
the
elderly
or
persons
with
disabilities
(
unless
any
child
who
is
less
than
six
years
of
age
resides
or
is
expected
to
reside
in
such
housing
for
the
elderly
or
persons
with
disabilities)
or
any
zero­
bedroom
dwelling
(
section
401(
17)
of
TSCA,
15
U.
S.
C.
2681).
Those
who
fail
to
provide
the
pamphlet,
as
required,
may
be
subject
to
both
civil
and
criminal
sanctions
under
section
16
of
TSCA.

Pursuant
to
Title
IV
of
TSCA,
EPA
promulgated
regulations
applicable
to
all
renovations
of
target
housing
performed
for
compensation,
except
as
otherwise
specified,
at
40
CFR
part
745,
subpart
E
(
see
Attachment
2).
Under
these
regulations,
renovators
must
provide
the
owner
and
occupant
of
any
residential
dwelling
unit
or
multi­
family
housing
with
a
lead
hazard
information
pamphlet
(
see
Attachment
3).
After
providing
the
pamphlet
to
the
owner
and
occupant
and
obtaining
written
acknowledgment,
the
renovator
must
keep
acknowledgment
records
on
file
for
three
years
after
completion
of
work.

The
regulations
at
40
CFR
part
745,
subpart
E,
apply
to
any
person
who
performs
renovations
at
target
housing
for
compensation.
However,
a
designated
representative
(
e.
g.,
a
landlord,
rental
property
manager)
may
deliver
the
pamphlet
and
obtain
the
acknowledgment.
When
using
a
designated
representative,
the
renovator
remains
responsible
for
compliance
with
the
regulations
(
63
FR
29914;
June
1,
1998).
For
purposes
of
this
ICR,
EPA
assumes
that
all
activities
associated
with
distribution
of
the
lead
hazard
information
pamphlet
are
undertaken
by
renovators.

This
ICR
examines
the
respondent
paperwork
requirements
and
associated
hour
and
cost
burden
of
the
regulations
at
40
CFR
part
745,
subpart
E.
Sections
1
through
5
of
the
ICR
describe
the
paperwork
requirements
associated
with
the
distribution
of
the
lead
hazard
­
2
­
information
pamphlet
prior
to
commencing
renovations
of
target
housing
for
compensation.
Section
6
estimates
the
annual
hour
and
cost
burden
to
respondents
in
complying
with
these
paperwork
requirements.

Note
that
this
ICR
does
not
address
hour
and
cost
burden
to
recipients
of
the
lead
hazard
information
pamphlet
(
i.
e.,
owners
and
occupants
of
target
housing)
because
the
pamphlet
is
originally
supplied
by
the
Federal
government.
Under
5
CFR
1320.3(
c)(
2),
"
the
public
disclosure
of
information
originally
supplied
by
the
Federal
government
to
the
[
respondent]
for
the
purpose
of
disclosure
to
the
public
is
not
included"
as
a
"
collection
of
information."
In
addition,
because
the
acknowledgment
of
receipt
obtained
by
the
renovator
only
involves
"
that
burden
necessary
to
identify
the
respondent,
the
date,
the
respondent's
address,
and
the
nature
of
the
instrument,"
completion
of
the
acknowledgment
form
by
the
owner
and
occupant
of
the
target
housing
is
not
considered
to
be
"
information"
under
5
CFR
1320.3(
h)(
1).

The
following
paragraphs
describe
the
activities
that
renovators
would
take
under
40
CFR
part
745,
subpart
E.

Exemption
from
Information
Distribution
Requirements
Under
40
CFR
745.82(
b),
renovators
performing
renovations
of
target
housing
for
compensation
are
not
subject
to
the
regulations
in
40
CFR
part
745,
subpart
E
if
the
renovation
activities
are
limited
to:
(
i)
minor
repair
and
maintenance
activities
(
including
minor
electrical
work
and
plumbing)
that
disrupt
two
square
feet
or
less
of
painted
surface
per
component;
(
ii)
emergency
renovation
operations;
or
(
iii)
renovations
in
target
housing
in
which
a
written
determination
has
been
made
by
an
inspector
(
certified
pursuant
to
either
Federal
regulations
at
40
CFR
745.226
or
a
State
or
Tribal
certification
program
authorized
pursuant
to
40
CFR
745.324)
that
the
components
affected
by
the
renovation
are
free
of
paint
or
other
surface
coatings
that
contain
lead
equal
to
or
in
excess
of
1.0
milligram
per
square
centimeter
or
0.5
percent
by
weight,
where
the
renovator
has
obtained
a
copy
of
the
determination.

Information
Distribution
Requirements
for
Renovations
in
Dwelling
Units
Under
40
CFR
745.85(
a),
no
more
than
60
days
before
beginning
renovation
activities
in
any
residential
dwelling
unit
of
target
housing,
a
renovator
must
provide
the
owner
of
the
dwelling
unit
with
a
lead
hazard
information
pamphlet,
and
must
comply
with
the
procedures
specified
at
section
745.85(
a)(
1)(
i)
or
(
ii).
In
addition,
if
the
owner
does
not
occupy
the
dwelling
unit,
the
renovator
must
provide
an
adult
occupant
of
the
unit
with
the
pamphlet,
and
comply
with
the
procedures
specified
at
section
745.85(
a)(
2)(
i)
or
(
ii).

Information
Distribution
Requirements
for
Renovations
in
Common
Areas
Under
40
CFR
745.85(
b),
no
more
than
60
days
before
beginning
renovation
activities
in
common
areas
of
multi­
family
housing,
a
renovator
must
provide
the
owner
of
the
multi­
family
­
3
­
housing
with
a
lead
hazard
information
pamphlet,
and
must
comply
with
the
procedures
specified
at
section
745.85(
b)(
1)(
i)
or
(
ii).

In
addition,
the
renovator
must
notify
in
writing,
or
ensure
written
notification
of,
each
affected
unit
of
the
multi­
family
housing
and
make
the
pamphlet
available
upon
request
prior
to
start
of
the
renovation.
Such
notification
must
be
accomplished
by
distributing
written
notice
to
each
affected
unit.
The
notice
must
describe
the
general
nature
and
locations
of
the
planned
renovation
activities;
the
expected
starting
and
ending
dates;
and
a
statement
of
how
the
occupant
can
obtain
the
pamphlet,
at
no
charge,
from
the
renovator
(
section
745.85(
b)(
2)).

The
renovator
also
must
prepare,
sign,
and
date
a
statement
describing
the
steps
performed
to
notify
all
occupants
of
the
intended
renovation
activities
and
to
provide
the
pamphlet
(
section
745.85(
b)(
3)).
If
the
scope,
locations,
or
expected
starting
and
ending
dates
of
the
planned
renovation
activities
change
after
the
initial
notification,
the
renovator
must
provide
further
written
notification
to
the
owners
and
occupants
providing
revised
information
on
the
ongoing
or
planned
activities.
This
subsequent
notification
must
be
provided
before
the
renovator
initiates
work
beyond
that
which
was
described
in
the
original
notice
(
section
745.85(
b)(
4)).

Recordkeeping
Requirements
Under
40
CFR
745.86(
a),
renovators
must
retain
and,
if
requested,
make
available
to
EPA
all
records
necessary
to
demonstrate
compliance
with
the
requirements
of
40
CFR
part
745,
subpart
E,
for
a
period
of
three
years
following
completion
of
the
renovation
activities
in
target
housing.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need
and
Authority
for
the
Collection
Section
406(
b)
of
Title
IV
of
TSCA
requires
EPA
to
promulgate
regulations
requiring
certain
persons
who
perform
renovations
of
target
housing
for
compensation
to
provide
a
lead
hazard
information
pamphlet
to
the
owner
and
occupant
of
such
housing
prior
to
commencing
the
renovation.
Regulations
promulgated
under
the
authority
of
section
406(
b)
ensure
that
owners
and
occupants
of
target
housing
are
provided
information
concerning
potential
hazards
of
leadbased
paint
exposure
before
certain
renovations
are
begun
on
that
housing.
The
Agency
believes
that
the
distribution
of
the
pamphlet
will
help
to
reduce
the
exposures
that
cause
serious
lead
poisonings,
especially
in
children
under
age
six,
who
are
particularly
susceptible
to
the
hazards
of
lead.
­
4
­
2(
b)
Practical
Utility
and
Users
of
the
Data
Owners
and
occupants
of
target
housing
must
be
provided
with
a
lead
hazard
information
pamphlet
before
any
renovation
commences.
Information
contained
in
the
lead
hazard
information
pamphlet
may
be
used
by
owners
and
occupants
of
target
housing
to
take
appropriate
precautions
to
avoid
exposure
to
lead­
contaminated
dust
and
lead­
based
paint
debris
that
are
sometimes
generated
during
renovations.

In
addition,
the
recordkeeping
requirements
under
40
CFR
part
745,
subpart
E
enable
EPA,
State,
and
local
regulators
and
the
courts
to
determine
initial
compliance
and
monitor
continued
compliance
with
the
provisions
of
section
406(
b)
of
TSCA.
The
record
of
compliance
could
also
serve
as
a
crucial
piece
of
information
in
civil
actions
to
establish
liability.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
EPA
has
determined
that
no
other
Federal
agency
collection
satisfies
the
statutory
requirements
of
section
406(
b)
of
TSCA.

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)
Consultations
Following
the
publication
of
the
proposed
rule,
EPA
received
thirty
comments
during
the
60­
day
comment
period
on
the
proposed
rule.
In
addition,
EPA
has
met
with
key
constituency
groups
to
discuss
the
proposal
and
key
areas
of
concern.
These
groups
include:
The
Alliance
to
End
Childhood
Lead
Poisoning,
the
Institute
of
Real
Estate
Management,
and
the
National
Multi­
Housing
Council.
EPA
has
also
met
with
many
state
and
Tribal
officials
involved
in
the
Forum
on
State
and
Tribal
Toxics
Action
(
FOSTTA),
including
officials
from
California
and
Massachusetts.

3(
d)
Effects
of
Less
Frequent
Collection
Regulations
at
40
CFR
part
745,
subpart
E
do
not
include
any
reporting
requirements,
only
recordkeeping
requirements.
Therefore,
a
collection
schedule
is
not
applicable.
­
5
­
3(
e)
General
Guidelines
This
collection
does
not
exceed
any
of
the
Paperwork
Reduction
Act
guidelines
at
5
CFR
1320.5.

3(
f)
Confidentiality
In
general,
EPA
does
not
believe
that
respondents
will
assert
a
confidentiality
claim
for
information
collected
under
this
ICR.
However,
to
the
extent
information
submitted
by
respondents
is
business
confidential,
procedures
are
in
place
to
protect
the
information
from
improper
disclosure.

Under
40
CFR
745.84,
EPA
has
established
procedures
for
dealing
with
confidential
business
information.
Section
745.84(
a)
provides
that
those
who
assert
a
confidentiality
claim
for
submitted
information
must
provide
EPA
with
two
copies
of
their
submission.
The
first
copy
must
be
complete
and
contain
all
information
being
claimed
as
confidential.
The
second
copy
must
contain
only
information
not
claimed
as
confidential.
EPA
will
place
the
second
copy
of
the
submission
in
the
public
file.

In
addition,
section
745.84(
b)
establishes
that
EPA
will
disclose
information
subject
to
a
claim
of
confidentiality
only
to
the
extent
permitted
by
section
14
of
TSCA
and
40
CFR
part
2,
subpart
B.
If
a
person
does
not
assert
a
claim
of
confidentiality
for
information
at
the
time
it
is
submitted
to
EPA,
EPA
may
make
the
information
public
without
further
notice
to
that
person.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
the
information
collection
requirements
associated
with
the
distribution
of
the
lead
hazard
information
pamphlet.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS
Codes
The
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
industries
most
likely
affected
by
the
paperwork
requirements
covered
in
this
ICR
are
described
below:

NAICS
Code
Industrial
Sector
23321
Single
Family
Housing
Construction
23322
Multifamily
Housing
Construction
23511
Plumbing,
Heating,
and
Air­
Conditioning
Contractors
NAICS
Code
Industrial
Sector
­
6
­
23521
Painting
and
Wall
Covering
Contractors
23531
Electrical
Contractors
23541
Masonry
and
Stone
Contractors
23542
Drywall,
Plastering,
Acoustical,
and
Insulation
Contractors
23543
Tile,
Marble,
Terrazzo,
and
Mosaic
Contractors
23551
Carpentry
Contractors
23552
Floor
Laying
and
Other
Floor
Contractors
23561
Roofing,
Siding,
and
Sheet
Metal
Contractors
23571
Concrete
Contractors
23581
Water
Well
Drilling
Contractors
23591
Structural
Steel
Erection
Contractors
23592
Glass
and
Glazing
Contractors
23593
Excavation
Contractors
23594
Wrecking
and
Demolition
Contractors
23595
Building
Equipment
and
Other
Machinery
Installation
Contractors
23599
All
Other
Special
Trade
Contractors
53111
Lessors
of
Residential
Buildings
and
Dwellings
53119
Lessors
of
Other
Real
Estate
Property
53121
Offices
of
Real
Estate
Agents
and
Brokers
531311
Residential
Property
Managers
53132
Offices
of
Real
Estate
Appraisers
53139
Other
Activities
Related
to
Real
Estate
4(
b)
Information
Requested
In
the
following
paragraphs,
EPA
describes
the
paperwork
requirements
associated
with
the
distribution
of
the
lead
hazard
information
pamphlet.

Exemption
from
Information
Distribution
Requirements
Under
40
CFR
745.82(
b),
renovators
performing
renovations
of
target
housing
for
compensation
are
not
subject
to
the
regulations
in
40
CFR
part
745,
subpart
E
if
the
renovation
­
7
­
activities
are
limited
to:
(
i)
minor
repair
and
maintenance
activities
(
including
minor
electrical
work
and
plumbing)
that
disrupt
two
square
feet
or
less
of
painted
surface
per
component;
(
ii)
emergency
renovation
operations;
or
(
iii)
renovations
in
target
housing
in
which
a
written
determination
has
been
made
by
an
inspector
(
certified
pursuant
to
either
Federal
regulations
at
40
CFR
745.226
or
a
State
or
Tribal
certification
program
authorized
pursuant
to
40
CFR
745.324)
that
the
components
affected
by
the
renovation
are
free
of
paint
or
other
surface
coatings
that
contain
lead
equal
to
or
in
excess
of
1.0
milligram
per
square
centimeter
or
0.5
percent
by
weight,
where
the
renovator
has
obtained
a
copy
of
the
determination.

(
i)
Data
Item:

Written
determination
by
an
inspector
(
certified
pursuant
to
either
Federal
regulations
at
40
CFR
745.226
or
a
State
or
Tribal
certification
program
authorized
pursuant
to
40
CFR
745.324)
that
the
components
affected
by
the
renovation
are
free
of
paint
or
other
surface
coatings
that
contain
lead
equal
to
or
in
excess
of
1.0
milligram
per
square
centimeter
or
0.5
percent
by
weight.

(
ii)
Respondent
Activity:

A
renovator
performing
renovations
of
target
housing
for
compensation
may
be
exempt
from
the
regulations
in
40
CFR
part
745,
subpart
E
by
obtaining
copy
of
a
determination
made
by
a
certified
inspector
that
the
components
affected
by
the
renovation
are
free
of
paint
or
other
surface
coatings
that
contain
lead
equal
to
or
in
excess
of
1.0
milligram
per
square
centimeter
or
0.5
percent
by
weight.

Information
Distribution
Requirements
for
Renovation
in
Dwelling
Units
Under
40
CFR
745.85(
a),
no
more
than
60
days
before
beginning
renovation
activities
in
any
residential
dwelling
unit
of
target
housing,
a
renovator
must
provide
the
owner
of
the
dwelling
unit
with
a
lead
hazard
information
pamphlet,
and
must
comply
with
the
procedures
specified
at
section
745.85(
a)(
1)(
i)
or
(
ii).
In
addition,
if
the
owner
does
not
occupy
the
dwelling
unit,
the
renovator
must
provide
an
adult
occupant
of
the
unit
with
the
pamphlet,
and
comply
with
the
procedures
specified
at
section
745.85(
a)(
2)(
i)
or
(
ii).

(
i)
Data
Items:


Lead
hazard
information
pamphlet;
and

Documentation
providing
proof
that
the
pamphlet
was
provided
to
the
owner
and
occupant
of
the
target
housing
or
that
an
attempt
was
made
to
provide
the
pamphlet
to
the
owner
and
occupant
of
the
target
housing
(
e.
g.,
collect
signed
acknowledgment
form,
provide
self­
certification
for
failed
deliveries,
document
mailing
the
information).
­
8
­
(
ii)
Respondent
Activities:

A
renovator
planning
to
conduct
renovations
in
any
residential
dwelling
unit
must:


Prepare
acknowledgment
and
certification
forms;


Provide
the
owner
of
dwelling
unit
with
a
lead
hazard
information
pamphlet
and
obtain
proof
that
the
pamphlet
was
provided
to
the
owner
of
the
target
housing
by:

­­
Obtaining,
from
the
owner,
a
written
acknowledgment
that
the
owner
has
received
the
pamphlet
(
section
745.85(
a)(
1)(
i));
or
­­
Obtaining
a
certificate
of
mailing
at
least
seven
days
prior
to
the
renovation
(
section
745.85(
a)(
1)(
ii)).

In
addition,
if
the
owner
does
not
occupy
the
dwelling
unit,
the
renovator
also
must:


Provide
an
adult
occupant
of
the
unit
with
the
pamphlet
and
obtain
proof
that
the
pamphlet
was
provided
to
the
occupant
of
the
target
housing
by:

­­
Obtaining,
from
the
adult
occupant,
a
written
acknowledgment
that
the
occupant
has
received
the
pamphlet
(
section
745.85(
a)(
2)(
i));
or
­­
Certifying
in
writing
that
a
pamphlet
has
been
delivered
to
the
dwelling
and
that
the
renovator
has
been
unsuccessful
in
obtaining
a
written
acknowledgment
from
an
adult
occupant
(
section
745.85(
a)(
2)(
i));
or
­­
Obtaining
a
certificate
of
mailing
at
least
seven
days
prior
to
the
renovation
(
section
745.85(
a)(
2)(
ii)).

Information
Distribution
Requirements
for
Renovations
in
Common
Areas
Under
40
CFR
745.85(
b),
no
more
than
60
days
before
beginning
renovation
activities
in
common
areas
of
multi­
family
housing,
a
renovator
must
provide
the
owner
of
the
multi­
family
housing
with
a
lead
hazard
information
pamphlet,
and
must
comply
with
the
procedures
specified
at
section
745.85(
b)(
1)(
i)
or
(
ii).
In
addition,
the
renovator
must
notify
in
writing,
or
ensure
written
notification
of,
each
affected
unit
of
the
multi­
family
housing
and
make
the
pamphlet
available
upon
request
prior
to
start
of
the
renovation.
Such
notification
must
be
accomplished
by
distributing
written
notice
to
each
affected
unit
(
section
745.85(
b)(
2)).
Finally,
renovators
must
prepare,
sign,
and
date
a
statement
describing
the
steps
performed
to
notify
all
occupants
of
the
intended
renovation
activities
and
to
provide
the
pamphlet
(
section
745.85(
b)(
3)).
­
9
­
(
i)
Data
Items:


Lead
hazard
information
pamphlet;


Notice
describing
the
general
nature
and
locations
of
the
planned
renovation
activities;
the
expected
starting
and
ending
dates;
and
a
statement
of
how
the
occupant
can
obtain
the
pamphlet,
at
no
charge,
from
the
renovator;
and

Statement
describing
the
steps
performed
to
notify
all
occupants
of
the
intended
renovation
activities
and
to
provide
the
pamphlet.

(
ii)
Respondent
Activities:

A
renovator
planning
to
conduct
renovations
in
common
areas
of
multi­
family
housing
must:


Prepare
acknowledgment
and
certification
forms;


Provide
the
owner
of
multi­
family
housing
unit
with
a
lead
hazard
information
pamphlet
and
obtain
proof
that
the
pamphlet
was
provided
to
the
owner
of
the
target
housing
by:

­­
Obtaining,
from
the
owner,
a
written
acknowledgment
that
the
owner
has
received
the
pamphlet
(
section
745.85(
b)(
1)(
i));
or
­­
Obtaining
a
certificate
of
mailing
at
least
seven
days
prior
to
the
renovation
(
section
745.85(
b)(
1)(
ii));


Notify
in
writing,
or
ensure
written
notification
of,
each
unit
of
the
multi­
family
housing
and
make
the
pamphlet
available
upon
request
prior
to
start
of
the
renovation;


Prepare,
sign,
and
date
a
statement
describing
the
steps
performed
to
notify
all
occupants
of
the
intended
renovation
activities
and
to
provide
the
pamphlet
(
section
745.85(
b)(
3));
and

If
the
scope,
locations,
or
expected
starting
and
ending
dates
of
the
planned
renovation
activities
change
after
the
initial
notification,
provide
further
written
notification
to
the
owners
and
occupants
providing
revised
information
on
the
ongoing
or
planned
activities
(
section
745.85(
b)(
4)).
­
10
­
Recordkeeping
Requirements
Under
40
CFR
745.86(
a),
renovators
must
retain
and,
if
requested,
make
available
to
EPA
all
records
necessary
to
demonstrate
compliance
with
the
requirements
of
40
CFR
part
745,
subpart
E
for
a
period
of
three
years
following
completion
of
the
renovation
activities
in
target
housing.

(
i)
Data
Items:

Records
that
must
be
retained
pursuant
to
section
745.86
include,
where
applicable:


Reports
certifying
that
a
determination
has
been
made
by
an
inspector
that
leadbased
paint
is
not
present
in
the
area
affected
by
the
renovation,
as
described
in
section
745.82(
b)(
3)
[
section
745.86(
b)(
1)];


Signed
and
dated
acknowledgments
of
receipt
as
described
in
sections
745.85(
a)(
1)(
i),
(
a)(
2)(
i),
and
(
b)(
1)(
i)
[
section
745.86(
b)(
2)];


Certifications
of
attempted
delivery
as
described
in
section
745.85(
a)(
1)(
i)
[
section
745.86(
b)(
3)];


Certificates
of
mailing
as
described
in
sections
745.85(
a)(
1)(
ii),
(
a)(
2)(
ii),
and
(
b)(
1)(
ii)
[
section
745.86(
b)(
4)];
and

Records
of
notification
activities
performed
regarding
common
area
renovations,
as
described
in
sections
745.85(
b)(
3)
and
(
4)
[
section
745.86(
b)(
5)].

(
ii)
Respondent
Activities:

Renovators
must
maintain
records
to
demonstrate
compliance
with
the
requirements
of
40
CFR
part
745,
subpart
E
for
a
period
of
three
years
following
completion
of
the
renovation
activities
in
target
housing.

5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
There
are
no
Agency
activities
associated
with
the
distribution
of
lead
hazard
information
pamphlets
to
owners
and
occupants
of
target
housing
prior
to
commencing
renovations
for
compensation.
­
11
­
5(
b)
Collection
Methodology
and
Management
There
are
no
Agency
activities
associated
with
the
distribution
of
the
lead
hazard
information
pamphlet
to
owners
and
occupants
of
target
housing
prior
to
commencing
renovations
for
compensation.
However,
under
the
provisions
of
40
CFR
745.87,
EPA
may
conduct
inspections
and
issue
subpoenas
pursuant
to
the
provisions
of
TSCA
section
11
(
15
U.
S.
C.
2610)
to
ensure
compliance
with
40
CFR
part
745,
subpart
E.

5(
c)
Small
Entity
Flexibility
In
promulgating
the
regulations
at
40
CFR
part
745,
subpart
E,
EPA
attempted
to
minimize
the
reporting
and
recordkeeping
burden
for
both
large
and
small
regulated
entities.
While
small
business
constitute
the
majority
of
affected
entities,
hour
and
cost
burden
imposed
by
the
regulations
is
not
considered
to
be
of
sufficient
magnitude
to
have
significant
economic
impacts
on
such
establishments.

5(
d)
Collection
Schedule
Regulations
at
40
CFR
part
745,
subpart
E,
do
not
include
any
reporting
requirements,
only
recordkeeping
requirements.
Therefore,
a
collection
schedule
is
not
applicable.

6.
ESTIMATING
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
and
Costs
The
overall
cost
analysis
for
this
rule
was
presented
in
a
Regulatory
Impact
Analysis
(
RIA),
which
is
available
in
the
docket
for
the
final
rule.
The
current
burden
and
costs
estimates
related
to
the
information
collection
components
of
the
final
rule
are
based
on
the
estimates
presented
in
the
RIA
and
updated
using
the
most
recent
data
available.
For
the
ICR
burden
analysis,
individual
respondent
times
(
burden
hours)
for
a
given
activity
were
estimated
from
the
total
number
of
annual
burden
hours
in
that
activity
(
based
on
total
events
or
total
persons
affected
as
reported
in
the
regulatory
analysis)
divided
by
the
estimated
total
number
of
respondents
that
would
potentially
be
affected
by
the
final
rule.

This
ICR
presents
the
estimated
annual
burden
and
associated
annual
costs
for
the
following
information
collection
components
of
the
final
rule:


Start­
up
­
Renovator
and
Owner/
Managers
of
Rental
Housing
doing
their
own
renovation,
must
read
and
learn
the
new
requirements.
However,
since
renovators
and
rental
property
have
already
encountered
this
burden,
start­
up
costs
in
this
ICR
are
only
calculated
for
new
entrants
to
the
market
to
read
and
learn
the
requirements.
1
U.
S.
Bureau
of
Labor
Statistics,
2003.
Occupational
Employment
Statistics,
National
Cross­
Industry
series
http://
www.
bls.
gov/
oes/
home.
htm.
The
Specialty
Trade
Contractors
included
were
carpenters,
carpet
installers,
drywall
workers
and
lathers,
glaziers,
insulation
workers,
painters
and
paperhangers,
plasterers,
and
plumbers.

2
In
tabulating
the
numbers,
EPA
rounded
the
number
of
employees
in
each
category
to
the
nearest
thousand.

3
U.
S.
Bureau
of
Labor
Statistics,
2003.
Occupational
Employment
Statistics,
National
Cross­
Industry
series
http://
www.
bls.
gov/
oes/
home.
htm.

­
12
­

Prepare
Information
­
Renovators
and
Owner/
Managers
of
Rental
Housing
doing
their
own
renovation,
must
obtain
the
required
pamphlet,
prepare
the
written
acknowledgment,
and
prepare
the
required
notification
to
tenants
of
renovation
activities
in
the
common
areas
of
multi­
unit
target
housing.
Renovators
and
Owners/
Managers
are
also
required
to
prepare,
sign,
and
date
a
statement
describing
the
steps
performed
to
notify
occupants
of
the
intended
common
area
renovation
activities.


Provide
Information
­
Renovators
and
Owner/
Managers
of
Rental
Housing
doing
their
own
renovation,
must
provide
the
owner/
occupant
with
a
copy
of
the
pamphlet,
and
document
receipt
by
having
the
owner/
occupant
sign
the
receipt/
acknowledgment.
In
the
case
of
the
notification,
Renovators
and
Owner/
Managers
of
Rental
Housing
doing
their
own
renovation,
must
provide
notification
to
tenants
of
renovation
activities
in
common
areas
of
multi­
unit
target
housing.


Maintain
Records
­
Renovators
and
Owner/
Managers
of
Rental
Housings
doing
their
own
renovation,
must
retain
the
documentation
of
distribution,
e.
g.,
acknowledgment
by
owner/
occupant.

The
estimated
number
of
renovators,
as
well
as
the
number
of
new
entrants
to
the
occupation
in
future
years,
is
based
on
the
number
of
Construction
Contractors
and
Managers
and
the
total
of
a
selected
list
of
Specialty
Trade
Contractors
listed
in
Bureau
of
Labor
Statistics
(
BLS)
data
for
the
year
20021.
In
2002,
there
were
a
total
of
2,295,000
employees
in
these
categories2.
The
number
of
new
entrants
was
calculated
by
using
the
BLS
data
on
occupational
projections.
BLS
provides
a
projected
percentage
increase
in
employment
from
2000­
2010
for
each
labor
category.
EPA
divided
the
percentage
for
each
labor
category
(
to
approximate
an
annual
percentage)
and
applied
the
annual
percentage
to
the
number
of
employees
in
2002.
This
resulted
in
an
estimated
27,000
new
entrants
for
the
renovation
category.

The
number
of
rental
property
managers
and,
as
well,
the
annual
number
of
new
entrants
are
also
taken
from
BLS
data
for
the
occupational
category,
Property
and
Real
Estate
Managers3.
BLS
estimates
that
in
2002
there
were
156,000
people
employed
in
this
occupation.
The
number
of
new
entrants
was
estimated
in
the
same
way
as
was
done
for
renovators
and
resulted
in
4,000
new
entrants.
4
In
the
previous
ICR,
the
number
of
respondents
was
estimated
to
be
3,046,000.
The
reduction
in
the
number
of
respondents
is
primarily
attributable
to
a
reduced
estimate
for
the
number
of
Property
and
Real
Estate
Managers.
More
recent
BLS
data
have
provided
a
more
accurate
breakdown
of
this
category.

5
U.
S.
Census
Bureau,
Residential
Improvements
and
Repair
Statistics,
2002,
Construction
Report
series,
http://
www.
census.
gov/
const/
www/
c50index.
html
­
13
­
The
total
number
of
respondents,
i.
e.,
renovators
and
rental
property
managers,
including
new
entrants,
estimated
for
this
ICR
is
2,482,0004.
This
is
the
total
of
current
renovators
(
2,295,000),
new
entrants
to
renovation
(
27,000),
current
property
managers
(
156,000),
and
new
entrants
to
property
management
(
4,000).

The
annual
number
of
renovation
events
in
owner­
occupied
target
housing
is
estimated
to
be
11,584,202
units.
This
number
is
estimated
from
the
pre­
1979
owner­
occupied
units
less
the
zero
bedroom
units
not
subject
to
the
rule
(
American
Housing
Survey
data,
HUD,
1997),
and
the
estimated
annual
number
of
paid
renovation
events
per
year
per
unit
of
housing
(
estimated
by
dividing
total
dollar
outlays
for
2002
renovation
events
subject
to
regulation5
by
unit
costs
for
renovation
activities
[
obtained
from
the
National
Association
of
Home
Builders
publication
Profile
of
the
Remodeler
1992
and
inflated
to
2002
dollar
values]).
The
annual
number
of
renovation
events
in
rental
target
housing,
which
is
estimated
to
be
6,055,048
units,
is
based
on
the
total
pre­
1979
rental
units
less
zero­
bedroom
units
not
subject
to
the
rule
(
American
Housing
Survey
data,
HUD,
1997),
and
the
estimated
annual
number
of
paid
renovation
events
per
year
per
unit
of
housing
(
estimated
using
same
sources
cited
above
for
owner­
occupied
housing).
Table
1
provides
details
on
both
of
these
calculations.
­
14
­

Table
1.
Estimated
Number
of
Renovation
Events
Activity
Expenditures
($
millions)
[
a]
Unit
Cost
[
b]
Estimated
Number
of
Events
[
c]

Maintenance
and
Repair
Improvements
TOTAL
Maintenance
and
Repair
Improvements
Maintenance
and
Repair
Improvements
TOTAL
Owner
Occupied
Heating
and
Central
AC
[
d]
$
4,050
$
4,050
[
d]
$
2,552
[
d]
1,586,993
1,586,993
Plumbing
[
d]
$
1,655
$
1,655
[
d]
$
6,260
[
d]
264,298
264,298
Painting
$
5,139
[
d]
$
5,139
$
2,880
[
d]
1,784,503
[
d]
1,784,503
Siding
$
78
$
1,520
$
1,598
$
3,068
$
6,855
25,543
221,748
247,291
Interior
Restructuring
[
d]
$
2,424
$
2,424
[
d]
$
9,632
[
d]
251,671
251,671
Other
$
5,744
$
16,399
$
22,143
$
2,142
$
3,440
2,681,891
4,767,553
7,449,444
Total
$
10,962
$
26,048
$
37,009
­
­
4,491,938
7,092,264
11,584,202
Rental
Properties
Heating
and
Central
AC
[
d]
$
1,923
$
1,923
[
d]
$
2,552
[
d]
753,669
753,669
Plumbing
[
d]
[
d]
[
d]
[
d]
[
d]
[
d]
[
d]
[
d]

Painting
$
5,082
[
d]
$
5,082
$
2,880
[
d]
1,764,559
[
d]
1,764,559
Siding
$
642
$
439
$
1,081
$
3,068
$
6,855
209,205
64,032
273,237
Interior
Restructuring
[
d]
[
d]
[
d]
[
d]
[
d]
[
d]
[
d]
[
d]

Other
$
3,573
$
5,487
$
9,060
$
2,142
$
3,440
1,668,436
1,595,148
3,263,583
Total
$
9,297
$
7,849
$
17,146
­
­
3,642,200
2,412,848
6,055,048
[
a]
Expenditures
are
calculated
from
the
Census
Bureau's
Residential
Improvements
and
Repair
Statistics,
2002.
The
numbers
that
appear
in
this
table
reflect
expenditures
that
estimated
to
occur
in
target
housing.
To
derive
the
level
of
expenditure
that
occurs
in
target
housing,
EPA
multiplied
the
amount
estimated
by
Census
by
68
percent
for
owner­
occupied
and
72
percent
for
rental
properties.
These
percentages,
in
turn,
reflect
the
percentage
of
all
residences
that
were
(
a)
built
before
1979
and
(
b)
that
are
not
zero­
bedroom
residences
with
no
children.
The
percentages
of
pre­
1979
residences
that
are
not
zero­
bedroom
residences
with
no
children
were
assumed
to
be
99.8
percent
for
owner­
occupied
and
96.1
percent
for
rental
properties.

[
b]
Unit
costs
were
provided
by
the
National
Association
of
Home
Builders
(
NAHB)
for
a
previous
version
of
this
ICR.
Unit
costs
were
updated
to
2002
dollars
(
to
be
consistent
with
the
expenditure
data)
using
the
consumer
price
index
for
housing.
The
original
costs
from
NAHB
were
in
1992
dollars.
The
inflation
adjustment
was
a
factor
of
1.2141.
­
15
­

[
c]
The
estimated
number
of
event
was
calculated
by
dividing
the
expenditures
by
unit
costs.

[
d]
These
activities
in
these
categories
(
i.
e.,
maintenance
and
repair,
improvements)
were
determined
to
be
out
of
scope
for
this
ICR.
6
The
previous
ICR
used
an
hourly
wage
for
the
Finance,
Insurance,
and
Real
Estate
sectors
combined.
This
ICR
uses
just
the
rate
for
Real
Estate,
resulting
in
a
lower
hourly
rate.

7
Data
extracted
from
BLS
Current
Employment
Statistics
Data,
http://
www.
bls.
gov/
ces/
home.
htm,
January
12,
2004.

­
16
­
Obviously,
not
all
renovation
contractors
or
owner/
managers
of
rental
housing
will
be
initiating
a
renovation
activity
that
is
covered
by
this
rule
each
year,
nor
will
all
of
the
target
housing
or
rental
properties
that
are
subject
to
the
rule
have
renovation
activities
initiated
each
year.
At
this
time,
however,
it
is
not
possible
to
determine
how
many
renovation
activities
will
occur
each
year,
or
how
many
of
those
will
be
subject
to
this
rule.
EPA
believes
that
it
is
reasonable
to
assume
that
100%
of
the
units
involved
in
renovation
activities
in
target
housing
will
be
required
to
take
an
action
in
accordance
with
the
final
rule,
and
that
the
action
taken
for
each
event
involves
the
personal
delivery
by
renovators
and
owners/
managers
of
a
notification
or
pamphlet
directly
to
the
tenant/
occupant,
the
obtaining
of
a
acknowledgment/
receipt,
and
recordkeeping.
As
such,
it
is
not
necessary
to
include
separate
burden
or
cost
estimates
for
the
alternate
delivery
methods,
which
are
already
captured
by
the
burden
estimate
provided
by
the
assumed
100%
compliance
with
personal
delivery.

The
required
activity
differs
for
renovation
activities
in
rental
housing
between
activities
involving
the
individual
unit
and
activities
involving
the
common
areas.
Renovation
events
occurring
in
individual
rental
units
require
renovators
to
prepare
written
acknowledgments
for,
distribute
pamphlets
to,
and
obtain
acknowledgments
from,
both
the
owner
and
the
tenant
of
the
unit.
On
the
other
hand,
when
renovation
events
take
place
in
common
areas
these
activities
(
prepare
written
acknowledgment,
distribute
pamphlet,
obtain
acknowledgment)
apply
only
to
owners
of
the
unit.
For
occupants
affected
by
common
area
renovations,
renovators
are
required
to
ensure
written
notification
of
the
intended
renovation
activity
and,
if
requested,
make
the
pamphlet
available
to
any
tenants
making
such
a
request.
The
renovator
must
also
document
this
disclosure
activity
by
preparing
a
written
statement
describing
the
steps
performed
to
notify
all
occupants
of
the
intended
renovation
activities.
In
this
ICR
costs
for
providing
pamphlets
to
tenants
affected
by
common
area
renovations
are
not
included
because
property
owners
will
likely
post
copies
of
the
pamphlet
in
common
areas,
thereby
making
them
available
to
any
interested
tenants.
For
individual
units,
the
RIA
indicates
that
the
majority
of
renovation
activities
involving
the
individual
unit
actually
occur
between
tenants
and
while
the
unit
is
vacant.
As
such,
EPA
estimates
that
only
approximately
one
fourth
of
the
rental
property
renovations
will
occur
in
the
individual
unit
while
it
is
occupied
(
1,513,762
units).

Estimates
for
time
requirements
incurred
by
respondents
in
complying
with
the
various
activities
are
based
on
conversations
with
renovation
contractors,
building
trades
groups,
and
rental
property
owners
and
managers.
The
costs
of
time
for
renovation
contractors
(
which
is
$
33.21/
hour)
and
rental
property
managers
(
which
is
$
22.04/
hour)
6
are
based
on
the
average
hourly
earnings
for
October,
2003,
for
the
Construction
category
and
the
Real
Estate
category,
respectively7.
Estimated
hourly
rates
reflect
a
64
percent
mark­
up
on
the
raw
rate
reported
by
­
17
­
BLS
to
reflect
overhead
and
benefits.
The
64
percent
mark­
up
was
used
in
the
previous
ICR
for
this
collection.

The
Agency's
estimated
burden
hours
and
costs
for
the
information
collection
activities
contained
in
this
rule
are
summarized
below
and
presented
in
the
attached
tables.

Start­
Up
Burden
­
The
start­
up
or
first
year
burden
involves
the
time
and
cost
required
to
read
and
learn
the
disclosure
rule's
requirements
and
set
up
procedures
for
meeting
those
requirements.
Since
start­
up
costs
are
greatest
in
the
first
year
following
promulgation,
the
individual
start­
up
burden
was
estimated
for
renovators
and
rental
property
managers
performing
renovation
activities
in
the
1998
ICR.
In
the
1998
ICR,
EPA
had
taken
the
total
burden
associated
with
the
first
year
of
implementing
this
final
rule
and
annualized
it
over
the
next
three
years.
These
burdens
and
costs
have
been
removed
from
the
current
ICR.
EPA
believes
this
revised
ICR
need
not
include
start­
up
costs
since
they
have
already
been
encountered
by
renovators
and
rental
property
managers.
The
only
start­
up
costs
considered
are
those
for
new
entrants
to
these
occupations.
EPA
estimates
that
there
will
be
27,000
new
entrants
for
renovators
and
4,000
new
entrants
for
property
managers
(
See
Table
2,
and
above
for
details).

Preparation
and
the
Provision
of
the
Information
­
The
burden
under
this
activity
section
involves
the
time
and
cost
for
preparing
and
providing
the
information
needed
to
perform
the
disclosure
activities
in
conjunction
with
the
renovation
of
target
housing
as
specified
by
the
rule.
In
essence,
this
includes
the
following
activities:

­
Preparing
written
acknowledgment
for
all
Owner/
Occupants
­
Preparing
written
acknowledgment
for
all
Owners
of
rental
units
(
1­
unit
and
common
area)
­
Preparing
written
acknowledgment
for
1­
unit
occupant
­
Preparing
and
delivering
the
pamphlet
to
individual
Owner/
Occupants,
owners
of
all
rental
units,
and
1­
unit
rental
occupants
­
Obtaining
acknowledgment
of
the
delivered
pamphlet
from
all
Owner/
Occupants,
owners
of
all
rental
units,
and
1­
unit
rental
occupants
­
Preparing
and
posting
the
Notification
for
common
area
activities
­
Preparing
a
statement
describing
the
steps
performed
to
notify
all
occupants
of
common
areas
of
the
intended
renovation
Since
the
owner/
occupant
activities,
i.
e.,
receiving
the
pamphlet
and
signing
the
acknowledgment
of
receipt,
do
not
need
to
be
included
in
the
estimate
(
see
earlier
discussion),
EPA
has
only
estimated
the
burden
for
those
activities
of
the
renovator/
manager
in
this
transaction.
Specifically,
the
renovator/
manager
must
prepare
the
appropriate
document,
make
sufficient
copies,
distribute
the
information,
and
obtain
the
acknowledgments.
Since
per
event
burden
is
likely
to
vary
greatly,
dependent
upon
such
highly
variable
factors
as
the
method
of
delivery
chosen,
the
frequency
of
this
activity
for
the
individual
manager/
renovator,
the
number
of
events,
experience
and
individual
efficiencies,
EPA
has
attempted
to
simplify
the
estimate
by
­
18
­
making
some
general
assumptions.
These
assumptions
are
likely
to
result
in
an
overall
overestimate,
which
the
Agency
believes
will
help
ensure
that
all
the
variations
in
these
activities
are
covered.

For
the
purposes
of
calculating
the
burden
and
costs,
EPA
has
assumed
100%
of
the
renovation
activities
in
owner
occupied
housing
(
11,584,202),
and
25%
of
rental
property
renovation
activities
(
1,513,762
­
assumed
earlier
as
the
estimated
number
of
renovation
events
taking
place
in
the
individual
unit)
will
involve
the
preparation
of
a
written
acknowledgment.
In
addition,
written
acknowledgments
will
also
be
prepared
for
100%
of
owners
of
rental
units
(
6,055,048).
EPA
has
also
assumed
that
100%
of
the
renovation
activities
in
rental
housing
will
involve
the
notification.
In
addition,
EPA
has
provided
average
burden
estimates,
i.
e.,
since
the
burden
calculations
for
the
certificate
and
notification
are
estimated
to
be
about
2
minutes
to
prepare
the
document
for
the
first
event,
and
less
than
1
minute
to
copy
that
document
for
subsequent
distribution,
EPA
has
used
the
estimated
2
minutes
per
event.

The
renovator/
manager
is
also
required
to
distribute
the
pamphlet
and
obtain
acknowledgments
from
all
owner
occupants
(
11,584,202),
all
owners
of
rental
units
(
6,055,048),
and
individual
unit
rental
occupants
(
1,513,762).
As
explained
in
the
final
rule
preamble,
EPA
has
provided
ample
flexibility
to
the
renovator/
manager
for
their
distribution
of
the
pamphlet
or
notification.
Since
the
renovator/
manager
will
already
visit
the
site
on
more
than
one
occasion
to
complete
the
contract
transaction,
evaluate
the
site
for
estimate
purposes,
deliver
material
and
the
like,
EPA
believes
that
personal
delivery,
i.
e.,
distribution
of
the
pamphlet
or
notification,
is
likely
to
be
combined
with
one
of
these
other
activities.
Since
the
manager/
renovator
must
obtain
the
acknowledgment
from
the
recipient
when
the
information
is
provided,
this
activity
will
also
occur
at
this
time.
EPA
estimates
that
this
transaction
may
take
less
than
1
minute,
and
no
more
than
4
minutes.
For
the
ICR,
EPA
has
used
an
average
estimate
of
2
minutes
per
event
for
these
calculations.
By
assuming
that
all
recipients
will
provide
the
acknowledgment,
and
given
the
overestimate
in
the
number
of
events,
EPA
believes
that
this
estimate
also
covers
those
situations
in
which
the
manager/
renovator
may
need
to
provide
a
self­
certification
for
failed
deliveries.
Furthermore,
EPA
did
not
take
any
credits
or
reductions
to
reflect
the
potential
exemptions.

As
noted
above,
renovation
activities
taking
place
in
the
common
area
also
require
the
preparation
of
a
statement
describing
the
steps
performed
to
notify
each
occupant
of
the
intended
renovation.
For
this
requirement,
EPA
is
assuming
a
time
estimate
of
5
minutes
per
event.
(
See
Table
2.)

The
time
estimates
are
based
on
conversations
with
renovation
contractors,
building
trades
groups,
and
rental
property
owners
and
managers.
In
determining
the
corresponding
annual
cost,
EPA
used
the
hourly
rate
for
a
renovation
contractor
($
31.21/
hr).
(
See
Table
2.)
­
19
­
Table
2
­
Total
Annual
Burden
and
Cost
Estimates
for
Renovation
Contractors
and
Owners/
Rental
Property
Managers
Activity
Total
#
People/
Events
Per
Event
Average
Total
Average
Burden
[
a]
Cost
Burden
[
b]
Cost
[
c]

Start­
up
for
Annual
New
Entrant
­
Renovator
27,000
[
d]
1.00
$
31.21
27,000
$
842,670
Start­
up
for
Annual
New
Entrant
­
Rental
Manager
4,000
[
e]
1.00
$
22.04
4,000
$
88,160
Preparing
written
acknowledgment
for
Owner/
Occupants
11,584,202
[
f]
0.033
$
1.03
382,279
$
11,931,728
Preparing
written
acknowledgment
for
1­
unit
rental
occupant
1,513,762
[
g]
0.033
$
1.03
49,954
$
1,559,175
Preparing
written
acknowledgment
for
all
Owners
of
rental
units
6,055,048
[
h]
0.033
$
1.03
199,817
$
6,236,699
Distribution
of
pamphlet
and
obtaining
acknowledgment
from
Owner/
Occupants
11,584,202
[
f]
0.033
$
1.03
382,279
$
11,931,728
Distribution
of
pamphlet
and
obtaining
acknowledgment
from
1­
unit
rental
occupants
1,513,762
[
g]
0.033
$
1.03
49,954
$
1,559,175
Distribution
of
pamphlet
and
obtaining
acknowledgment
from
all
Owners
of
rental
units
6,055,048
[
h]
0.033
$
1.03
199,817
$
6,236,699
Notification
for
common
area
activities
6,055,048
[
h]
0.033
$
1.03
199,817
$
6,236,699
Preparing,
signing,
and
dating
a
statement
describing
the
steps
performed
to
notify
all
common
area
occupants
of
the
intended
renovation
6,055,048
[
h]
0.083
$
2.59
502,569
$
15,682,574
Filing
and
retaining
acknowledgments
17,639,250
[
i]
0.083
$
2.59
1,464,058
$
45,685,658
Totals
3,461,542
$
107,990,966
­
20
­
[
a]
These
numbers
have
been
rounded.
[
b]
Total
average
burdens
were
estimated
by
multiplying
total
people/
events
by
per
event
average
burden.
[
c]
Total
costs
were
estimated
by
multiplying
per
event
average
costs
by
pre­
rounded
total
average
burden.
[
d]
This
is
the
number
of
new
entrants
to
renovation.
[
e]
This
is
the
number
of
new
entrants
to
property
management.
[
f]
This
is
the
number
of
renovation
events
performed
in
owner­
occupied
housing.
[
g]
This
is
the
number
of
renovation
events
in
rental
property
units
that
are
occupied
at
the
time
of
the
renovation.
[
h]
This
is
the
number
of
renovation
events
in
rental
property
units.
[
i]
This
is
the
total
number
of
renovation
events
in
both
owner­
occupied
units
and
in
rental
properties.

Recordkeeping
Burden
­
The
Recordkeeping
Burden
involves
the
time
and
cost
for
meeting
the
disclosure
rule's
recordkeeping
requirements.
The
individual
recordkeeping
burden
for
renovation
contractors
and
property
managers
performing
renovation
work
is
based
on
the
estimated
total
annual
number
of
renovations
performed
17,639,250
(
11,584,202
+
6,055,048),
and
the
total
amount
of
time
spent
in
the
recordkeeping
activity
(
approximately
5
minutes
per
event).
In
determining
the
corresponding
annual
cost,
EPA
used
the
hourly
rate
for
a
renovation
contractor
($
31.21/
hr).
(
See
"
Filing
and
retaining
acknowledgments"
in
Table
2.)

Costs
for
Materials
­
The
materials
costs
for
this
ICR
consists
of
the
cost
of
purchasing
or
duplicating
the
Lead
Hazard
Pamphlets.
The
Lead
Hazard
Pamphlets
are
16
pages,
printed
front
and
back,
folded
sheet
format
(
i.
e.,
4
sheets
of
standard
sized
paper
per
document).
EPA
believes
that
most
renovators
will
purchase
the
pamphlet
in
bulk,
although
some
may
choose
to
save
money
by
making
their
own
duplicates
of
the
pamphlet.
As
a
conservative
estimate,
EPA
is
assuming
copying
costs
of
$
0.34
for
100%
of
renovators
and
rental
managers.
EPA
assumes
that
all
owner­
occupied
renovation
events
and
rental
renovation
events
taking
place
in
the
individual
unit
will
require
a
copy
of
the
pamphlet.
As
a
result,
the
total
cost
of
pamphlets
incurred
by
renovators
and
property
managers
is
$
3,938,629,
which
was
calculated
using
the
copying
cost
per
pamphlet,
and
the
total
number
of
pamphlets
required
(
11,584,202).

6(
b)
Estimating
Agency
Burden
and
Cost
Not
applicable.
This
is
a
third
party
notification
rule.

6(
c)
Bottom
Line
Burden
Hours
and
Costs/
Master
Table
The
total
annual
burden
for
this
ICR
is
therefore
3,461,542
hours.
The
total
annual
cost
is
estimated
to
be
$
111,929,595
including
$
107,990,966
for
implementation
activities
and
$
3,938,629
for
estimated
capital
expenditures.
See
Table
3.
8
See
footnote
number
4
above.

­
21
­
Table
3
­
Total
Estimated
Burden
and
Costs
Burden
Hours
Cost
Total
Implementation
Activities
3,461,542
$
107,990,966
Material
Costs
­
$
3,938,629
TOTAL
3,461,542
$
111,929,595
6(
d)
Reasons
for
Changes
in
Burden
It
is
important
to
note
that
the
previously
approved
ICR
included
an
estimated
burden
of
2,938,546
hours.
This
represents
a
difference
of
523,000
hours
between
this
ICR
and
the
previously
approved
ICR.
The
reason
for
the
increase
is
an
increase
in
the
estimated
number
of
annual
renovation
events.
The
difference
are
detailed
in
Table
4.
Thus,
there
are
an
additional
2.85
million
estimated
renovation
events
under
the
current
ICR.
The
increased
number
of
events
reflects
increased
spending
on
renovations
(
i.
e.,
from
Census
data).
The
increased
spending
on
renovations
in
the
United
States
as
a
whole
reflects
a
general
economic
trend.
The
increase
in
renovation
has
been
partly
fueled
by
historically
low
levels
of
interest
rates.

Table
4.
Changes
in
the
Number
of
Estimated
Renovation
Events
Renovation
Event
Previously
Approved
ICR
Current
ICR
Difference
Owner­
Occupied
10,678,100
11,548,202
870,102
One­
Unit
Dwellings
1,117,681
1,513,762
396,081
Common
Areas
4,470,723
6,055,048
1,584,325
TOTAL
16,266,504
19,117,012
2,850,508
6(
e)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information,
which
is
approved
under
OMB
Control
No.
2070­
0158,
is
estimated
to
be
1.39
hours
per
respondent.
There
are
an
estimated
2,482,000
respondents
and
an
estimated
3,461,542
burden
hours.
This
represents
an
increase
from
the
previous
ICR's
burden
of
0.96
hours.
The
increase,
however,
is
due
to
a
change
in
the
data
used
to
estimate
respondents8.
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
such
­
22
­
activities
as
annual
familiarization
with
requirements
for
new
entrants,
the
preparation
of
acknowledgment
or
notification
documents,
the
provision
of
the
notification
document,
and
record
retention
of
any
acknowledgments.
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
0082,
which
is
available
for
public
viewing
at
the
Pollution
Prevention
and
Toxics
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
xxxx­
xxxx
and
OMB
control
number
2070­
0158
in
any
correspondence.
EPA
ICR
No.
1669.04;
OMB
Control
No.
2070­
0158
Appendix
1
Toxic
Substances
Control
Act
(
TSCA)
Section
406
15
U.
S.
C.
2686
Sec.
2686.
Lead
hazard
information
pamphlet
(
a)
Lead
hazard
information
pamphlet
Not
later
than
2
years
after
October
28,
1992,
after
notice
and
opportunity
for
comment,
the
Administrator
of
the
Environmental
Protection
Agency,
in
consultation
with
the
Secretary
of
Housing
and
Urban
Development
and
with
the
Secretary
of
Health
and
Human
Services,
shall
publish,
and
from
time
to
time
revise,
a
lead
hazard
information
pamphlet
to
be
used
in
connection
with
this
subchapter
and
section
4852d
of
title
42.
The
pamphlet
shall
­
(
1)
contain
information
regarding
the
health
risks
associated
with
exposure
to
lead;
(
2)
provide
information
on
the
presence
of
lead­
based
paint
hazards
in
federally
assisted,
federally
owned,
and
target
housing;
(
3)
describe
the
risks
of
lead
exposure
for
children
under
6
years
of
age,
pregnant
women,
women
of
childbearing
age,
persons
involved
in
home
renovation,
and
others
residing
in
a
dwelling
with
lead­
based
paint
hazards;
(
4)
describe
the
risks
of
renovation
in
a
dwelling
with
lead­
based
paint
hazards;
(
5)
provide
information
on
approved
methods
for
evaluating
and
reducing
lead­
based
paint
hazards
and
their
effectiveness
in
identifying,
reducing,
eliminating,
or
preventing
exposure
to
lead­
based
paint
hazards;
(
6)
advise
persons
how
to
obtain
a
list
of
contractors
certified
pursuant
to
this
subchapter
in
lead­
based
paint
hazard
evaluation
and
reduction
in
the
area
in
which
the
pamphlet
is
to
be
used;
(
7)
state
that
a
risk
assessment
or
inspection
for
lead­
based
paint
is
recommended
prior
to
the
purchase,
lease,
or
renovation
of
target
housing;
(
8)
state
that
certain
State
and
local
laws
impose
additional
requirements
related
to
lead­
based
paint
in
housing
and
provide
a
listing
of
Federal,
State,
and
local
agencies
in
each
State,
including
address
and
telephone
number,
that
can
provide
information
about
applicable
laws
and
available
governmental
and
private
assistance
and
financing;
and
(
9)
provide
such
other
information
about
environmental
hazards
associated
with
residential
real
property
as
the
Administrator
deems
appropriate.
(
b)
Renovation
of
target
housing
Within
2
years
after
October
28,
1992,
the
Administrator
shall
promulgate
regulations
under
this
subsection
to
require
each
person
who
performs
for
compensation
a
renovation
of
target
housing
to
provide
a
lead
hazard
information
pamphlet
to
the
owner
and
occupant
of
such
housing
prior
to
commencing
the
renovation.
EPA
ICR
No.
1669.04;
OMB
Control
No.
2070­
0158
Attachment
2
40
CFR
Part
745,
Subpart
E
TITLE
40­­
PROTECTION
OF
ENVIRONMENT
CHAPTER
I­­
ENVIRONMENTAL
PROTECTION
AGENCY
PART
745­­
LEAD­
BASED
PAINT
POISONING
PREVENTION
IN
CERTAIN
RESIDENTIAL
STRUCTURES­­
Table
of
Contents
Subpart
E­­
Residential
Property
Renovation
Source:
63
FR
29919,
June
1,
1998,
unless
otherwise
noted.

Sec.
745.80
Purpose.

This
subpart
contains
regulations
developed
under
Title
IV
(
15
U.
S.
C.
2681­
2692)
of
the
Toxic
Substances
Control
Act
and
applies
to
all
renovations
of
target
housing
performed
for
compensation.
The
purpose
of
this
subpart
is
to
require
each
person
who
performs
a
renovation
of
target
housing
for
compensation
to
provide
a
lead
hazard
information
pamphlet
to
the
owner
and
occupant
of
such
housing
prior
to
commencing
the
renovation.

Sec.
745.81
Effective
date.

The
requirements
in
this
subpart
shall
take
effect
on
June
1,
1999.

Sec.
745.82
Applicability.

(
a)
Except
as
provided
in
paragraph
(
b)
of
this
section,
this
subpart
applies
to
all
renovations
of
target
housing
performed
for
compensation.
(
b)
This
subpart
does
not
apply
to
renovation
activities
that
are
limited
to
the
following:
(
1)
Minor
repair
and
maintenance
activities
(
including
minor
electrical
work
and
plumbing)
that
disrupt
2
square
feet
or
less
of
painted
surface
per
component.
(
2)
Emergency
renovation
operations.
(
3)
Renovations
in
target
housing
in
which
a
written
determination
has
been
made
by
an
inspector
(
certified
pursuant
to
either
Federal
regulations
at
Sec.
745.226
or
a
State
or
Tribal
certification
program
authorized
pursuant
to
Sec.
745.324)
that
the
components
affected
by
the
renovation
are
free
of
paint
or
other
surface
coatings
that
contain
lead
equal
to
or
in
excess
of
1.0
milligram
per
square
centimeter
or
0.5
percent
by
weight,
where
the
renovator
has
obtained
a
copy
of
the
determination.

Sec.
745.83
Definitions.

For
purposes
of
this
part,
the
definitions
in
Sec.
745.103
as
well
as
the
following
definitions
apply:
Administrator
means
the
Administrator
of
the
Environmental
Protection
Agency.
Emergency
renovation
operations
means
renovation
activities,
such
as
operations
necessitated
by
non­
routine
failures
of
equipment,
that
were
not
planned
but
result
from
a
sudden,
unexpected
event
that,
if
not
immediately
attended
to,
presents
a
safety
or
public
health
hazard,
or
threatens
equipment
and/
or
property
with
significant
damage.
Multi­
family
housing
means
a
housing
property
consisting
of
more
than
four
dwelling
units.
Pamphlet
means
the
EPA
pamphlet
developed
under
section
406(
a)
of
TSCA
for
use
in
complying
with
this
and
other
rulemakings
under
Title
IV
of
TSCA
and
the
Residential
Lead­
Based
Paint
Hazard
Reduction
Act,
or
any
State
or
Tribal
pamphlet
approved
by
EPA
pursuant
to
40
CFR
745.326
that
is
developed
for
the
same
purpose.
This
includes
reproductions
of
the
pamphlet
when
copied
in
full
and
without
revision
or
deletion
of
material
from
the
pamphlet
(
except
for
the
addition
or
revision
of
State
or
local
sources
of
information).
Person
means
any
natural
or
judicial
person
including
any
individual,
corporation,
partnership,
or
association;
any
Indian
Tribe,
State,
or
political
subdivision
thereof;
any
interstate
body;
and
any
department,
agency,
or
instrumentality
of
the
Federal
Government.
Renovation
means
the
modification
of
any
existing
structure,
or
portion
thereof,
that
results
in
the
disturbance
of
painted
surfaces,
unless
that
activity
is
performed
as
part
of
an
abatement
as
defined
by
this
part
(
40
CFR
745.223).
The
term
renovation
includes
(
but
is
not
limited
to):
the
removal
or
modification
of
painted
surfaces
or
painted
components
(
e.
g.,
modification
of
painted
doors,
surface
preparation
activity
(
such
as
sanding,
scraping,
or
other
such
activities
that
may
generate
paint
dust));
the
removal
of
large
structures
(
e.
g.,
walls,
ceiling,
large
surface
replastering,
major
re­
plumbing);
and
window
replacement.
Renovator
means
any
person
who
performs
for
compensation
a
renovation.

Sec.
745.84
Confidential
business
information.

(
a)
Those
who
assert
a
confidentiality
claim
for
submitted
information
must
provide
EPA
with
two
copies
of
their
submission.
The
first
copy
must
be
complete
and
contain
all
information
being
claimed
as
confidential.
The
second
copy
must
contain
only
information
not
claimed
as
confidential.
EPA
will
place
the
second
copy
of
the
submission
in
the
public
file.
(
b)
EPA
will
disclose
information
subject
to
a
claim
of
confidentiality
only
to
the
extent
permitted
by
section
14
of
TSCA
and
40
CFR
part
2,
subpart
B.
If
a
person
does
not
assert
a
claim
of
confidentiality
for
information
at
the
time
it
is
submitted
to
EPA,
EPA
may
make
the
information
public
without
further
notice
to
that
person.

Sec.
745.85
Information
distribution
requirements.

(
a)
Renovations
in
dwelling
units.
No
more
than
60
days
before
beginning
renovation
activities
in
any
residential
dwelling
unit
of
target
housing,
the
renovator
shall:
(
1)
Provide
the
owner
of
the
unit
with
the
pamphlet,
and
comply
with
one
of
the
following:
(
i)
Obtain,
from
the
owner,
a
written
acknowledgment
that
the
owner
has
received
the
pamphlet.
(
ii)
Obtain
a
certificate
of
mailing
at
least
7
days
prior
to
the
renovation.
(
2)
In
addition
to
the
requirements
in
paragraph
(
a)(
1)
of
this
section,
if
the
owner
does
not
occupy
the
dwelling
unit,
provide
an
adult
occupant
of
the
unit
with
the
pamphlet,
and
comply
with
one
of
the
following:
(
i)
Obtain,
from
the
adult
occupant,
a
written
acknowledgment
that
the
occupant
has
received
the
pamphlet;
or
certify
in
writing
that
a
pamphlet
has
been
delivered
to
the
dwelling
and
that
the
renovator
has
been
unsuccessful
in
obtaining
a
written
acknowledgment
from
an
adult
occupant.
Such
certification
must
include
the
address
of
the
unit
undergoing
renovation,
the
date
and
method
of
delivery
of
the
pamphlet,
names
of
the
persons
delivering
the
pamphlet,
reason
for
lack
of
acknowledgment
(
e.
g.,
occupant
refuses
to
sign,
no
adult
occupant
available),
the
signature
of
the
renovator,
and
the
date
of
signature.
(
ii)
Obtain
a
certificate
of
mailing
at
least
7
days
prior
to
the
renovation.
(
b)
Renovations
in
common
areas.
No
more
than
60
days
before
beginning
renovation
activities
in
common
areas
of
multi­
family
housing,
the
renovator
shall:
(
1)
Provide
the
owner
with
the
pamphlet,
and
comply
with
one
of
the
following:
(
i)
Obtain,
from
the
owner,
a
written
acknowledgment
that
the
owner
has
received
the
pamphlet.
(
ii)
Obtain
a
certificate
of
mailing
at
least
7
days
prior
to
the
renovation.
(
2)
Notify
in
writing,
or
ensure
written
notification
of,
each
unit
of
the
multi­
family
housing
and
make
the
pamphlet
available
upon
request
prior
to
the
start
of
renovation.
Such
notification
shall
be
accomplished
by
distributing
written
notice
to
each
affected
unit.
The
notice
shall
describe
the
general
nature
and
locations
of
the
planned
renovation
activities;
the
expected
starting
and
ending
dates;
and
a
statement
of
how
the
occupant
can
obtain
the
pamphlet,
at
no
charge,
from
the
renovator.
(
3)
Prepare,
sign,
and
date
a
statement
describing
the
steps
performed
to
notify
all
occupants
of
the
intended
renovation
activities
and
to
provide
the
pamphlet.
(
4)
If
the
scope,
locations,
or
expected
starting
and
ending
dates
of
the
planned
renovation
activities
change
after
the
initial
notification,
the
renovator
shall
provide
further
written
notification
to
the
owners
and
occupants
providing
revised
information
on
the
ongoing
or
planned
activities.
This
subsequent
notification
must
be
provided
before
the
renovator
initiates
work
beyond
that
which
was
described
in
the
original
notice.
(
c)
Written
acknowledgment.
Sample
language
for
such
acknowledgments
is
provided
in
Sec.
745.88.
The
written
acknowledgments
required
in
paragraphs
(
a)(
1)(
i),
(
a)(
2)(
i),
and
(
b)(
1)(
i)
of
this
section
shall:
(
1)
Include
a
statement
recording
the
owner
or
occupant's
name
and
acknowledging
receipt
of
the
pamphlet
prior
to
the
start
of
renovation,
the
address
of
the
unit
undergoing
renovation,
the
signature
of
the
owner
or
occupant
as
applicable,
and
the
date
of
signature.
(
2)
Be
either
a
separate
sheet
or
part
of
any
written
contract
or
service
agreement
for
the
renovation.
(
3)
Be
written
in
the
same
language
as
the
text
of
the
contract
or
agreement
for
the
renovation
or,
in
the
case
of
non­
owner
occupied
target
housing,
in
the
same
language
as
the
lease
or
rental
agreement
or
the
pamphlet.

Sec.
745.86
Recordkeeping
requirements.

(
a)
Renovators
shall
retain
and,
if
requested,
make
available
to
EPA
all
records
necessary
to
demonstrate
compliance
with
this
subpart
for
a
period
of
3
years
following
completion
of
the
renovation
activities
in
target
housing.
This
3­
year
retention
requirement
does
not
supersede
longer
obligations
required
by
other
provisions
for
retaining
the
same
documentation,
including
any
applicable
State
or
Tribal
laws
or
regulations.
(
b)
Records
that
must
be
retained
pursuant
to
paragraph
(
a)
of
this
section
shall
include
(
where
applicable):
(
1)
Reports
certifying
that
a
determination
had
been
made
by
an
inspector
(
certified
pursuant
to
either
Federal
regulations
at
Sec.
745.226
or
an
EPA­
authorized
State
or
Tribal
certification
program)
that
lead­
based
paint
is
not
present
in
the
area
affected
by
the
renovation,
as
described
in
Sec.
745.82(
b)(
vi).
(
2)
Signed
and
dated
acknowledgments
of
receipt
as
described
in
Sec.
745.85(
a)(
1)(
i),
(
a)(
2)(
i),
and
(
b)(
1)(
i).
(
3)
Certifications
of
attempted
delivery
as
described
in
Sec.
745.85(
a)(
2)(
i).
(
4)
Certificates
of
mailing
as
described
in
Sec.
745.85(
a)(
1)(
ii),
(
a)(
2)(
ii),
and
(
b)(
1)(
ii).
(
5)
Records
of
notification
activities
performed
regarding
common
area
renovations,
as
described
in
Sec.
745.85(
b)
(
3)
and
(
4).

Sec.
745.87
Enforcement
and
inspections.

(
a)
Failure
or
refusal
to
comply
with
any
provision
of
this
subpart
is
a
violation
of
TSCA
section
409
(
15
U.
S.
C.
2689).
(
b)
Failure
or
refusal
to
establish
and
maintain
records
or
to
make
available
or
permit
access
to
or
copying
of
records,
as
required
by
this
subpart,
is
a
violation
of
TSCA
sections
15
and
409
(
15
U.
S.
C.
2614
and
2689).
(
c)
Failure
or
refusal
to
permit
entry
or
inspection
as
required
by
40
CFR
745.87
and
TSCA
section
11
(
15
U.
S.
C.
2610)
is
a
violation
of
sections
15
and
409
(
15
U.
S.
C.
2614
and
2689).
(
d)
Violators
may
be
subject
to
civil
and
criminal
sanctions
pursuant
to
TSCA
section
16
(
15
U.
S.
C.
2615)
for
each
violation.
(
e)
EPA
may
conduct
inspections
and
issue
subpoenas
pursuant
to
the
provisions
of
TSCA
section
11
(
15
U.
S.
C.
2610)
to
ensure
compliance
with
this
subpart.

Sec.
745.88
Acknowledgment
and
certification
statements.

(
a)(
1)
Acknowledgment
statement.
As
required
under
Sec.
745.85(
c)(
1),
acknowledgments
shall
include
a
statement
of
receipt
of
the
pamphlet
prior
to
the
start
of
renovation,
the
address
of
the
unit
undergoing
renovation,
the
signature
of
the
owner
or
occupant
as
applicable,
and
the
date
of
signature.
(
2)
Sample
acknowledgment
language.
The
following
is
a
sample
of
language
that
could
be
used
for
such
acknowledgments:

I
have
received
a
copy
of
the
pamphlet,
Protect
Your
Family
From
Lead
In
Your
Home,
informing
me
of
the
potential
risk
of
lead
hazard
exposure
from
renovation
activity
to
be
performed
in
my
dwelling
unit.
I
received
this
pamphlet
before
the
work
began.
__________________________________________
__________________________________________

Printed
Name
and
Signature
__________________________________________
Date
__________________________________________
__________________________________________
Unit
Address
(
b)(
1)
Certification
of
attempted
delivery.
When
an
occupant
is
unavailable
for
signature
or
refuses
to
sign
the
acknowledgment
of
receipt
of
the
pamphlet,
the
renovator
is
permitted
(
per
Sec.
745.85(
a)(
2)(
i))
to
certify
delivery
for
each
instance.
The
certification
shall
include
the
address
of
the
unit
undergoing
renovation,
the
date
and
method
of
delivery
of
the
pamphlet,
names
of
the
persons
delivering
the
pamphlet,
reason
for
lack
of
acknowledgment
(
e.
g.
occupant
refuses
to
sign,
no
adult
occupant
available),
the
signature
of
the
renovator,
and
the
date
of
signature.
(
2)
Sample
certification
language.
The
following
is
a
sample
of
language
that
could
be
used
under
those
circumstances:
(
i)
Unavailable
for
signature.

I
certify
that
I
have
made
a
good
faith
effort
to
deliver
the
pamphlet,
Protect
Your
Family
From
Lead
In
Your
Home,
to
the
unit
listed
below
at
the
dates
and
times
indicated,
and
that
the
occupant
refused
to
sign
the
acknowledgment.
I
further
certify
that
I
have
left
a
copy
of
the
pamphlet
at
the
unit
with
the
occupant.
__________________________________________
__________________________________________

Printed
Name
and
Signature
__________________________________________
Date
__________________________________________
__

[[
Page
461]]

XXXXXXXXXXXXXXXXXXXX
Unit
Address
Attempted
delivery
dates
and
times:

(
ii)
Refusal
to
sign.

I
certify
that
I
have
made
a
good
faith
effort
to
deliver
the
pamphlet,
Protect
Your
Family
From
Lead
In
Your
Home,
to
the
unit
listed
below,
and
that
the
occupant
was
unavailable
to
sign
the
acknowledgment.
I
further
certify
that
I
have
left
a
copy
of
the
pamphlet
at
the
unit
by
sliding
it
under
the
door.
__________________________________________
__________________________________________

Printed
Name
and
Signature
__________________________________________
Date
__________________________________________
__________________________________________
Unit
Address
Attempted
delivery
dates
and
times:
EPA
ICR
No.
1669.04;
OMB
Control
No.
2070­
0158
Attachment
3
Lead
Hazard
Information
Pamphlet
(
Note:
An
electronic
copy
of
this
attachment
is
available
on
the
EPA
Website
at:
http://
www.
epa.
gov/
opptintr/
lead/
leadpdfe.
pdf
.)
