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:
Reporting
and
Recordkeeping
Requirements
under
EPA's
Lead
Safety
Partnership
(
LSP)
Pilot
Program
EPA
ICR
No.
2172.01;
OMB
Control
No.
2070­

1(
b)
Short
Characterization
The
Lead
Safety
Partnership
(
LSP)
is
an
Environmental
Protection
Agency
(
EPA)
voluntary
program
that
seeks
to
increase
the
use
of
lead­
safe
work
practices
(
LSWP)
among
contractors
and
homeowners.
Within
EPA,
the
Program
was
developed
and
is
managed
by
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT),
National
Program
Chemicals
Division.
EPA
will
pilot
this
program
to
test
its
design
and
determine
how
to
best
proceed
with
a
national
LSP
program.

Participants
in
the
LSP
fall
into
two
categories:
Members
and
Partners.
Members
are
renovation,
remodeling,
painting
and
other
contractors
in
the
building
trades
who
work
in
properties
built
before
1978.
To
be
a
Member,
a
contractor
must
sign
a
Lead
Safety
Partnership
Member
Agreement
indicating
that
the
contractor
will:

°
Train
all
workers
in
LSWP
°
Inform
all
potential
clients
in
pre­
78
housing
of
LSWP
(
using
the
406(
b)
pamphlet);
°
Use
LSWP
in
homes
built
before
1978;
and
°
Report
annually
to
the
LSP
about
numbers
of
jobs
done
with
LSWP.

LSP
Members
will
also
be
asked
to
submit
a
Lead
Safety
Partnership
Annual
Member
Report
on
Progress
in
Meetings
Goals
of
Agreement
(
also
known
as
the
Annual
Member
Report)
that
will
include
items
such
as
number
of
renovation
and
remodeling
jobs
completed
in
pre­
1978
and
other
housing,
number
of
employees
trained,
and
information
on
the
Members'
satisfaction
with
the
program.
Members
of
the
LSP
can
expect
to
benefit
from
the
following:

°
Use
of
the
LSP
logo
on
their
marketing
materials;
°
Access
to
marketing
materials
from
the
LSP;
and
°
Indirect
promotion
through
the
LSP
public
education
campaign.

Partners
are
entities
that
participate
in
the
LSP
but
are
not
contractors.
These
may
include
associations,
community­
based
organizations,
retailers,
lenders,
Realtors,
state
and
local
agencies,
­
2­
etc.
Each
Partner
will
be
asked
to
provide
basic
information
about
their
organization
and
sign
a
Lead
Safety
Partnership
Partner
Agreement
that
outlines
their
role
and
level
of
commitment.
Partners
will
also
provide
an
Annual
Partner
Report
on
Progress
in
Meeting
Goals
of
Agreement
(
also
known
as
the
Annual
Partner
Report)
over
the
telephone.
This
report
will
include
information
on
services
provided
in
the
past
year
and
Partner
satisfaction
with
the
program,
among
other
items.
Partners
are
expected
to
benefit
from
the
recognition
they
receive
from
the
Partnership.
Partner
roles
and
responsibilities
will
depend
on
what
the
individual
organizations
can
offer.
Examples
include:

°
Associations
providing
worker
training;
°
Retailers,
such
as
Home
Depot,
requiring
that
all
their
contractors
be
LSP
Members;
°
Lenders
and
Realtors
helping
with
public
education;
°
Local
housing
and
health
agencies
helping
to
ensure
that
LSP
Member
contractors
get
work
through
local
programs;
and
°
Community­
based
organizations
that
work
in
neighborhoods
with
high
levels
of
lead
poisoning
or
older
housing
stock
helping
with
community
awareness
and
the
matching
of
LSP
contractors
to
appropriate
jobs.

EPA
will
use
the
information
collected
under
the
LSP
Pilot
to
determine
the
effectiveness
of
the
program
in
increasing
the
use
of
LSWP.
The
Agency
will
also
use
feedback
from
Members
and
Partners
to
adjust
the
pilot
program
design
before
instituting
a
national
Lead
Safety
Partnership
so
that
the
program
is
effective
and
useful
for
all
parties
involved.
The
general
public
is
also
expected
to
use
some
of
the
information
gathered
as
homeowners
and
others
undertaking
renovation
and
remodeling
projects
consult
the
LSP
Member
directory.

EPA
will
distribute
the
one­
page
Lead
Safety
Partnership
Member
Agreement
and
the
Lead
Safety
Partnership
Partner
Agreement
to
Members
and
Partners,
respectively.
Partners
and
Members
have
the
option
to
mail
or
fax
the
forms
to
EPA.
The
Agency
will
enter
the
data
from
these
forms
into
a
spreadsheet.
The
Annual
Member
Report
will
be
a
two­
page
form
with
multiple
choices
and
check
boxes
that
Members
will
be
asked
to
complete
and
mail
or
fax
to
EPA.
Data
comprising
the
Annual
Partner
Report
will
be
provided
to
EPA
orally
in
a
telephone
conversation.

EPA
expects
200
Members
and
40
Partners
to
join
the
Lead
Safety
Partnership
Pilot
during
the
three­
year
period
of
the
information
collection.
The
information
collection
activities
are
expected
to
cost
each
Member
an
average
of
$
69
and
1.33
burden
hours
per
year.
Partners
are
expected
to
incur
an
average
of
$
142
and
2.75
burden
hours
of
labor
per
year
when
participating
in
the
Lead
Safety
Partnership.
­
3­
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
EPA
seeks
to
reduce
the
risk
of
lead
poisoning
in
housing.
The
Agency
believes
that
this
risk
can
be
effectively
reduced
by
increasing
the
percentage
of
homeowners,
contractors,
and
property
managers
that
use
LSWP
when
disturbing
painted
surfaces.

The
Residential
Lead­
based
Paint
Hazard
Reduction
Act
of
1992
(
Title
X)
directs
EPA
to
develop
regulations
under
the
Toxic
Substances
Control
Act
(
TSCA)
Section
402(
a)
)(
15
U.
S.
C.
2682;
see
Attachment
A)
to
establish
standards
for
conducting
lead­
based
paint
activities
that
include
abatement.
EPA
has
already
promulgated
final
regulations
for
lead­
based
paint
activities
in
target
housing
and
child­
occupied
facilities
(
40
CFR
Part
745;
see
Attachment
B).
These
regulations
require
that
individuals
conducting
lead­
based
paint
inspections,
risk
assessments,
and
abatement
be
properly
trained
and
certified
and
that
the
work
be
performed
in
accordance
with
the
standards
set
forth
in
the
rule.

TSCA
Section
402(
c)
directs
EPA
to
address
renovation
and
remodeling
activities
by
determining
whether
renovation
and
remodeling
activities
should
be
subject
to
regulations
under
Section
402(
a).
If
so,
EPA
must
then
revise
the
Section
402(
a)
regulations
for
abatement
activities
and
apply
them,
if
appropriate,
to
renovation
or
remodeling
activities.

As
an
alternative
to
renovation
and
remodeling
regulations,
EPA
is
piloting
the
LSP
to
determine
if
that
approach
will
be
more
effective
in
increasing
the
use
of
LSP.
EPA
developed
the
idea
for
this
program
after
determining
from
stakeholders
that
using
LSWP
is
not
the
norm
in
the
renovation
and
remodeling
industry.
The
information
collection
activities
described
in
this
supporting
statement
are
necessary
to
obtain
information
about
firms
that
are
using
LSWP
and
to
gauge
the
number
of
activities
in
which
LSWP
are
incorporated
under
the
voluntary
program.

2(
b)
Practical
Utility/
Users
Of
The
Data
EPA
will
use
the
information
gathered
in
the
LSP
to
gauge
the
effectiveness
of
the
pilot
program.
EPA
will
analyze
the
number
of
employees
trained
in
LSWP
and
the
number
of
renovation
or
remodeling
jobs
performed
in
pre­
1978
housing
to
determine
how
frequently
LSWP
are
being
used
under
the
Partnership.
Along
with
this
quantitative
data,
EPA
will
use
feedback
on
satisfaction
with
the
program
from
program
participants
to
adjust
the
program
design
so
that
it
meets
Agency
and
stakeholder
needs,
while
still
meeting
the
goals
of
increasing
the
use
of
LSWP
during
renovation
and
remodeling
activities.
These
evaluations
will
enable
EPA
to
make
the
program
more
effective
as
it
moves
from
the
pilot
stage
into
a
national
program.

Members
and
Partners
will
use
the
data
to
identify
each
other
and
further
the
goal
of
increased
use
of
LSWP.
The
public
will
use
some
data
collected
in
the
Partnership.
EPA
will
­
4­
maintain
a
directory
of
Members
and
Partners
that
homeowners
can
use
to
easily
find
Members
and
use
their
services.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
As
discussed
above,
EPA
has
promulgated
final
regulations
for
lead­
based
paint
activities
in
target
housing
and
child­
occupied
facilities
(
40
CFR
Part
745).
The
US
Department
of
Housing
and
Urban
Development
(
HUD)
had
addressed
LSWP
in
HUD­
assisted
housing.
However,
EPA's
LSP
Pilot
would
bring
the
benefit
of
LSWP
to
the
general
public.
Another
EPA
voluntary
program,
Energy
Star,
has
a
home
improvement
program
that
encourages
contractors
to
develop
a
range
of
energy
efficient
practices,
but
none
of
the
practices
address
lead.

The
LSP
Pilot
Program
is
designed
to
increase
the
use
of
LSWP
without
further
regulation.
None
of
the
regulations
or
programs
listed
above
collect
the
same
information
as
the
LSP
Pilot
program
­­
namely,
data
on
LSWP
and
the
number
and
characteristics
of
organizations
that
utilize
LSWP.

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
In
the
process
of
developing
the
Lead
Safety
Partnership,
EPA
began
consultations
with
the
National
Association
of
Homebuilders
(
NAHB)
and
will
engage
other
parties
during
the
ICR
review
process.
Once
the
ICR
becomes
final,
the
Agency
will
revise
this
section
to
include
a
description
of
all
consultations
and
any
public
comments
that
are
received.

3(
d)
Effects
of
Less
Frequent
Collection
The
Lead
Safety
Partnership
Member
Agreement
and
the
Partnership
MOU
are
onetime
information
submissions
for
organizations
that
wish
to
participate
in
the
LSP
and,
therefore,
could
not
be
conducted
less
frequently.
The
Annual
Member
Report
and
Annual
Partner
Report
are
submitted
once
per
year
and
less
frequent
collection
would
likely
result
in
a
higher
burden,
as
Members
and
Partners
would
require
more
time
to
locate
records
older
than
one
year.
­
5­
Annual
reporting
takes
advantage
of
recent
memories
regarding
satisfaction
with
the
program,
while
not
overly
burdening
organizations
with
filling
out
forms
more
than
once
per
year.

3(
e)
General
Guidelines
All
of
the
collection
activities
described
within
this
ICR
adhere
to
OMB's
General
Guidelines.

3(
f)
Confidentiality
No
information
collected
by
EPA
under
the
LSP
comprises
confidential
business
information.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
any
of
the
reporting
forms.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS
Codes
The
LSP
targets
establishments
primarily
engaged
in
renovation,
remodeling,
and
repair,
including
general
contractors
such
as
painters,
plumbers,
electricians,
and
other
trades.
The
following
is
a
list
of
North
American
Industry
Classification
System
(
NAICS)
codes
and
associated
industries
that
are
most
likely
to
be
affected
by
information
collection
requirements
for
Members
covered
under
this
ICR:

NAICS
Codes
Affected
Industry
236118
Residential
Remodelers
238320
Painting
and
Wall
Covering
Contractors
238210
Electrical
Contractors
238220
Plumbing
Contractors
541310
Architectural
Services
624229
Other
Community
Housing
Services
­
6­
Partners
in
the
following
industries
are
expected
to
participate
in
the
LSP:

NAICS
Codes
Affected
Industry
813910
Contractors'
and
Construction
Associations
621999
Health
Screening
Services
624229
Housing
Assistance
Agencies
531110
Housing
Authorities
Operating
Residential
Buildings
444130
Hardware
Retailers
444120
Paint
and
Wallpaper
Stores
541350
Building
Inspection
Services
926150
Government
Building
Inspection
Agencies
444190
Building
Materials
Supply
Dealers
423390
Building
Materials
Wholesalers
531110
Building,
Apartment,
Rental,
Leasing
325510
Paint
and
Coating
Manufacturing
813910
Chambers
of
Commerce
611210
Community
Colleges
925110
Government
Housing
Authorities
423720
Plumbing
Supply
Wholesalers
444190
Plumbing
Supply
Stores
925120
Government
Community
Development
Agencies
4(
b)
Information
Requested
Once
a
prospective
organization
reviews
the
LSP
materials
and
decides
to
join
the
Program,
it
submits
a
Lead
Safety
Partnership
Member
Agreement
(
Attachment
C).
Members
will
report
annually
to
EPA
using
the
Annual
Member
Report
on
Progress
in
Meeting
Goals
of
Agreement
,
or
Annual
Member
Report
(
Attachment
D).
­
7­
Lead
Safety
Partnership
Member
Agreement
LSP
Members
complete
and
submit
to
EPA
a
standard,
one­
page
Lead
Safety
Partnership
Member
Agreement
that
provides
basic
organization
information.

(
i)
Data
items:

The
reporting
items
include:

°
Name
of
firm;
°
Name
and
title
of
owner/
representative.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Lead
Safety
Partnership
Member
Agreement:

°
Review
the
Lead
Safety
Partnership
information;
°
Decide
whether
to
join
the
Partnership;
°
Select
a
primary
contact
person
for
the
Partnership;
°
Complete
the
Lead
Safety
Partnership
Member
Agreement;
and
°
Fax
or
mail
the
form
to
EPA.

Annual
Member
Report
on
Progress
in
Meeting
Goals
of
Agreement
LSP
Members
complete
and
submit
to
EPA
a
standard,
2­
page
Annual
Member
Report
that
includes
a
series
of
questions
designed
to
ascertain
the
Member's
progress
in
meeting
the
goals
of
the
LSP
and
their
satisfaction
with
the
program.
For
Members
who
enroll
before
September
30
and
continuing
Members,
this
annual
reporting
form
is
due
by
January
31
of
the
following
year.
Those
Members
who
enroll
after
September
30
are
asked
to
complete
and
submit
the
form
by
January
31
of
the
second
year.

(
i)
Data
items:

The
reporting
items
include:

°
Name
of
firm;
°
Address
of
firm;
°
Name
and
title
of
owner/
representative;
°
Contact
information
(
phone,
fax,
email);
°
URL
to
firm's
website;
°
Number
of
employees;
°
Number
of
jobs
completed
in
past
year;
­
8­
°
Number
of
jobs
in
pre­
78
housing;
°
Number
of
jobs
using
LSWP;
°
Number
of
employees
trained
in
LSWP
(
on
the
job
or
through
a
course);
°
Number
of
referrals
from
LSP
web
site
or
program
literature;
°
Use
of
program
incentives
(
e.
g.,
use
of
discounted
products,
etc.);
°
Use
of
program
marketing
materials
and
other
LSP
products;
°
Satisfaction
with
procedures;
°
Satisfaction
with
the
program.

EPA
assumes
that
participating
organizations
keep
track
of
the
number
of
jobs
done
as
a
Common
Business
Practice.

Items
that
may
require
minimal
recordkeeping
include:

°
Number
of
jobs
in
pre­
78
housing;
°
Number
of
jobs
using
LSWP;
°
Number
of
employees
trained
in
LSWP
(
on
the
job
or
through
a
course);
and
°
Number
of
referrals
from
LSP
web
site
or
program
literature.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Annual
Member
Report:

°
Establish
a
method
to
keep
track
of
number
of
jobs
in
pre­
78
housing,
number
of
jobs
using
LSWP,
and
number
of
referrals
from
LSP
website
or
program
literature
(
such
as
additional
notation
on
current
contract
records);
°
Establish
a
method
to
document
employee
training
in
LSWP;
°
Consult
contract
records
from
the
previous
year
to
determine
number
of
jobs
done
by
location
and
type
of
structure;
°
Consult
training
records
to
determine
number
of
employees
trained
in
LSWP
(
on
the
job
or
through
a
course);
°
Complete
the
Annual
Member
Report
on
Progress
in
Meeting
Goals
of
Agreement;
and
°
Fax
or
mail
the
form
to
EPA.

Lead
Safety
Partnership
Partner
Agreement
Organizations
who
wish
to
become
Partners
will
be
asked
to
meet
with
EPA
to
determine
their
role
based
upon
the
services
offered
by
the
potential
Partner.
Then
the
organization
and
EPA
will
sign
a
Partner
Agreement
outlining
the
organization's
role
and
level
of
commitment
(
Attachment
E).
Partners
will
submit
an
Annual
Partner
Report
on
Progress
in
Meeting
Goals
of
Agreement
via
a
telephone
call
with
EPA
(
Attachment
F).
­
9­
(
i)
Data
items:

The
Partner
Agreement
will
include
the
following
data
items:

°
Name
of
organization;
°
Address;
°
Name
of
representative;
°
Contact
information
 
phone,
fax,
email;
°
Role
and
level
of
commitment
agreed
to
by
the
Partner.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Partner
Agreement
materials:

°
Review
the
Lead
Safety
Partnership
information;
°
Discuss
with
EPA
the
level
of
participation
and
activities
that
will
be
involved;
°
Decide
whether
to
join
the
Partnership;
°
Select
a
primary
contact
person
for
the
Partnership;
and
°
Fax
or
mail
the
Partner
Agreement
to
EPA.

Annual
Partner
Report
on
Progress
in
Meeting
Goals
of
Agreement
LSP
Partners
will
agree
to
speak
with
an
EPA
representative
on
the
phone
for
approximately
one­
half
hour
to
report
their
progress
on
meeting
the
goals
outlined
in
their
Partner
Agreement.
The
date
for
the
call
will
be
set
and
recorded
in
the
Partner
Agreement.

Partners
conduct
the
following
activities
in
order
to
complete
and
submit
the
Annual
Partner
Report:

(
i)
Data
items:

The
reporting
items
include:

°
Activities
performed
over
past
year
to
support
the
Partnership;
°
Number
of
materials
distributed;
°
Description
of
materials
developed,
outreach
programs;
°
Number
of
community
meetings;
°
Number
of
trainings;
°
Number
of
people
trained;
°
Number
of
advertisements/
public
service
announcements
publicizing
Partnership;
°
Benefits
received
from
the
Partnership;
°
Satisfaction
with
the
program;
and
­
10­
°
Activities
proposed
for
next
year
as
Partner.

Items
that
may
require
minimal
recordkeeping
include:

°
Activities
performed
over
past
year
to
support
the
Partnership;
°
Number
of
materials
distributed;
°
Description
of
materials
developed,
outreach
programs;
°
Number
of
community
meetings;
°
Number
of
trainings;
°
Number
of
people
trained;
and
°
Number
of
advertisements/
public
service
announcements
publicizing
Partnership.

(
ii)
Respondent
activities:

Participants
conduct
the
following
activities
in
order
to
complete
and
submit
the
Annual
Partner
Report:

°
Establish
a
method
to
keep
track
of
recordkeeping
items
listed
above;
°
Review
data
items
to
be
collected
by
EPA;
and
°
Meet
with
EPA
representative
on
the
phone
for
about
one­
half
hour
to
answer
questions
based
on
data
items.

5.
THE
INFORMATION
COLLECTED
 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Under
the
LSP
Pilot
Program,
EPA
engages
in
the
following
activities
related
to
the
Member
Agreement,
Partner
Agreement,
and
two
annual
reports:

Lead
Safety
Partnership
Member
Agreement
°
Distribute
the
Lead
Safety
Partnership
Member
Agreement
to
potential
Members;
°
Answer
questions
posed
by
potential
participants
regarding
membership
in
the
Partnership;
and
°
Receive
completed
forms,
enter
information
into
a
spreadsheet,
conduct
quality
assurance/
quality
control
(
QA/
QC)
on
data
entry.
­
11­
Lead
Safety
Partnership
Partner
Agreement
°
Distribute
the
Lead
Safety
Partnership
materials
to
potential
Partners;
°
Answer
questions
posed
by
potential
Partners
regarding
partnership
in
the
LSP
Program;
°
Negotiate
roles
and
activities
with
each
Partner;
and
°
Receive
Partner
data
in
telephone
conversation,
enter
information
into
a
spreadsheet,
conduct
quality
assurance/
quality
control
(
QA/
QC)
on
data
entry.

Annual
Member
Report
on
Progress
in
Meeting
Goals
of
Agreement
°
Receive
completed
forms,
enter
information
into
a
spreadsheet,
conduct
quality
assurance/
quality
control
(
QA/
QC)
on
data
entry;
and
°
Evaluate
effectiveness
of
the
program
based
on
annual
report
information
received.

Annual
Partner
Report
on
Progress
in
Meeting
Goals
of
Agreement
°
Conduct
annual
report
telephone
calls,
enter
information
into
a
spreadsheet,
conduct
quality
assurance/
quality
control
(
QA/
QC)
on
data
entry;
and
°
Evaluate
effectiveness
of
the
program
based
on
annual
report
information
received.

5(
b)
Collection
Methodology
and
Management
Respondents
will
be
able
to
obtain
the
reporting
forms
in
hard
copy
from
EPA.
The
completed
forms
can
be
faxed
or
mailed
to
EPA.

In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
a
telephone
system,
personal
computers,
and
applicable
spreadsheet
software.
EPA
ensures
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
enters
the
information
obtained
from
the
forms
into
a
spreadsheet
and
conducts
QA/
QC
on
data
entry.
Data
that
are
collected
are
used
to
evaluate
effectiveness
of
the
pilot
program
and
identify
next
steps/
changes
for
the
national
program.

5(
c)
Small
Entity
Flexibility
EPA
expects
that
some
of
the
participants
in
the
LSP
Program
will
be
small
entities.
EPA
has
designed
its
reporting
forms
to
minimize
respondent
burdens
while
obtaining
sufficient
and
accurate
information.
In
addition,
the
burden
associated
with
the
LSP
Program
is
inherently
reduced
since
the
initial
agreement
to
participate
is
voluntary.

5(
d)
Collection
Schedule
­
12­
Organizations
may
submit
a
Lead
Safety
Partnership
Member
Agreement
to
join
the
LSP
Pilot
Program
at
any
time.
If
a
Member
joins
by
September
30,
they
are
asked
to
submit
the
Annual
Member
Report
by
January
31
of
the
following
year.
Members
that
join
after
September
30
are
asked
to
submit
the
annual
report
by
January
31
of
the
second
year
after
enrollment.
Partners
may
join
the
Lead
Safety
Partnership
and
submit
the
Partner
Agreement
at
any
time.
Partners
will
submit
information
for
the
Annual
Partner
Report
on
a
date
agreed
upon
by
the
Partner
and
EPA
and
established
in
the
Partner
Agreement
signed
by
both
parties.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Exhibit
6.1
presents
the
burden
hours
and
costs
for
all
respondents
during
each
of
the
three
years
covered
under
this
ICR.
This
three­
year
period
represents
two­
year
programs
in
two
cities.
The
program
begins
in
the
first
city
in
year
one
and
in
the
second
city
in
year
two.

The
Lead
Safety
Partnership
Member
Agreement
contains
basic
questions
and
only
applies
for
the
first
year
of
the
Member's
participation;
thus,
the
burden
is
expected
to
be
minimal.
The
overall
burden
for
the
agreement
is
estimated
to
be
1.0
hours
per
participant.
The
Annual
Member
Report
is
expected
to
involve
minimal
recordkeeping
time
and
approximately
2.0
hours
per
participant.

Submission
of
the
Partner
Agreement
will
vary
based
upon
how
long
it
takes
each
Partner
to
discuss
and
decide
with
EPA
their
role
and
level
of
commitment.
This
set
of
activities
is
expected
to
range
from
about
1.0
hours
to
up
to
10
hours
per
Partner,
with
an
average
of
6
hours
per
Partner.
The
Annual
Partner
Report
is
expected
to
involve
minimal
recordkeeping
time
and
take
approximately
1.5
hours
per
participant.

For
the
burden
estimates
in
this
ICR,
it
is
assumed
that
Members
and
Partners
who
join
in
the
first
year
will
file
two
annual
reports
while
those
who
join
in
the
second
year
will
file
one.

These
burden
levels
are
estimates
based
on
EPA's
experience
with
other
voluntary
programs
and
based
on
the
advice
of
LSP
partnering
organizations.

6(
b)
Estimating
Respondent
Costs
To
estimate
respondent
costs,
EPA
assumes
average
hourly
labor
rates
(
hourly
rate
plus
overhead)
of
$
41
for
managerial
staff
and
$
23
for
clerical
staff.
These
rates
were
calculated
using
the
August
2004
National
Compensation
Survey:
Occupation
Wages
in
the
United
States,
July
2003,
Supplementary
Tables
published
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
(
BLS).
The
managerial
rate
was
calculated
to
be
$
24.72
by
averaging
the
managerial
rates
for
supervisors
in
the
painting,
plumbing,
electrical,
and
construction
occupations.
This
rate
­
13­
was
adjusted
for
inflation
by
5.5
percent,
the
difference
in
the
consumer
price
index
between
July
2003
(
when
it
was
183.9)
and
July
2004
(
189.4).
The
wage
rate
was
also
multiplied
by
1.57,
which
accounts
for
benefit
costs
(
27
percent)
as
listed
in
the
June
2004
Employer
Costs
for
Employee
Compensation
published
by
the
BLS,
plus
overhead
costs
(
30
percent).
The
clerical
hourly
wage
rate
was
calculated
using
the
BLS
July
2003
wage
rate
for
administrative
support
($
13.91)
and
adjusting
it
for
inflation
as
described
above,
plus
an
adjustment
for
benefit
costs
(
30
percent)
as
listed
in
the
June
2004
Employer
Costs
for
Employee
Compensation
published
by
the
BLS
and
overhead
costs
(
30
percent).

EPA
assumes
that
management
staff
will
complete
80
percent
of
the
tasks
listed
in
Exhibit
6.1
and
clerical
staff
will
complete
20
percent.
The
estimates
in
Exhibit
6.1
assume
that
October
1,
2004
through
September
30,
2005
will
comprise
Year
1
of
the
ICR,
October
1,
2005
through
September
30,
2006
is
Year
2,
and
October
1,
2006
through
September
30,
2007
is
Year
3.
As
discussed
above,
annual
Member
reporting
will
occur
by
January
31
of
each
year
and,
for
the
purposes
of
this
burden
analysis,
EPA
has
assumed
that
annual
Partner
reporting
will
occur
by
the
same
date.
The
time
needed
to
establishing
roles
and
commitment
levels
will
vary
for
each
Partner.
This
analysis
assumes
an
average
of
5
hours
to
complete
these
deliberations.

No
capital
or
operations
and
management
costs
are
incurred
by
respondents
under
this
ICR.
­
14­
Exhibit
6.1.
Estimated
Annual
Burden
and
Costs
to
Respondents
Collection
Activity
Estimated
#
of
Responses
Estimated
response
time
in
hours
TOTAL
BURDEN
TOTAL
COST
M
(
80%)
$
41/
hour
C
(
20%)
$
23/
hour
Total
Hours
LSP
Member
Agreement
200
Review
Program
information
and
decide
whether
to
participate
0.5
80
20
100
$
3,740
Select
contact
person
0.25
40
10
50
$
1,870
Complete
and
submit
form
0.25
40
10
50
$
1,870
Subtotal
200
1.0
160
40
200
$
7,480
Annual
Member
Report
300
Establish
recordkeeping
method
for
some
data
items
0.5
120
203
150
$
5,610
Consult
contract
records
from
previous
year
0.5
120
30
150
$
5,610
Consult
training
records
0.25
60
15
75
$
2,805
Complete
report
0.5
120
30
150
$
5,610
Fax
or
mail
form
to
EPA
0.25
60
15
75
$
2,805
Subtotal
300
2.0
480
120
600
$
22,440
LSP
Partner
Agreement
40
Review
Program
information
and
decide
whether
to
participate
0.5
16
4
20
$
748
Meet
with
EPA
to
discuss
role
and
level
of
commitment
5.0
160
40
200
$
7,480
Select
contact
person
0.25
8
2
10
$
374
Review,
complete,
and
submit
MOU
0.25
8
2
10
$
374
Subtotal
40
6.0
192
48
240
$
8,976
Annual
Partner
Report
60
Establish
recordkeeping
method
for
some
data
items
0.5
24
4
30
$
1,122
Review
data
items
to
be
collected
by
EPA
0.5
24
4
30
$
1,122
Meet
with
EPA
representative
via
telephone
to
report
annual
data
0.5
24
4
30
$
1,122
Subtotal
60
1.5
72
12
90
$
3,366
Total
600
904
226
1130
$
42,262
Collection
Activity
Estimated
#
of
Responses
Estimated
response
time
in
hours
TOTAL
BURDEN
TOTAL
COST
M
(
80%)
$
41/
hour
C
(
20%)
$
23/
hour
Total
Hours
­
15­
YEAR
1
LSP
Member
Agreement
50
1.0
40
10
50
$
1,870
Annual
Member
Report
50
2.0
80
20
100
$
3,740
LSP
Partner
Agreement
10
6.0
48
12
60
$
2,244
Annual
Partner
Report
10
1.5
12
3
15
$
561
TOTAL
120
180
45
225
$
8,415
YEAR
2
LSP
Member
Agreement
100
1.0
80
20
100
$
3,740
Annual
Member
Report
150
2.0
240
60
300
$
11,220
LSP
Partner
Agreement
20
6.0
96
24
120
$
4,488
Annual
Partner
Report
30
1.5
36
9
45
$
1,683
TOTAL
300
452
113
565
$
21,131
YEAR
3
LSP
Membership
Agreement
50
1.0
40
10
50
$
1,870
Annual
Member
Report
100
2.0
160
40
200
$
7,480
Partner
MOU
10
6.0
48
12
60
$
2,244
Annual
Partner
Report
20
1.5
24
6
30
$
1,122
TOTAL
180
272
68
340
$
12,716
3­
YEAR
TOTAL
600
904
226
1130
$
42,262
6(
c)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Burden
EPA
estimates
that
over
the
three­
year
life
of
the
pilot,
200
Members
will
join
the
Lead
Safety
Partnership
and
complete
the
Lead
Safety
Partnership
Member
Agreement.
Of
these,
100
will
complete
the
Annual
Member
Report
once
and
100
will
complete
the
report
twice.
In
addition,
40
Partners
will
join
the
program
and
submit
the
Lead
Safety
Partnership
Partner
Agreement.
Of
these,
20
will
complete
the
Annual
Partner
Report
once
and
20
will
complete
the
report
twice.
The
total
respondent
burden
associated
with
this
information
collection
is
1,130
hours
and
$
42,262.

6(
d)
Estimating
Agency
Burden
and
Costs
Exhibit
6.2
presents
the
estimated
Agency
burden
hours
and
costs
associated
with
the
information
collection
activities
under
this
ICR.
Other
direct
costs
(
copying,
printing,
telephone,
and
mailing
expenses)
are
also
included.
EPA
based
its
burden
estimates
on
its
experience
managing
other
voluntary
programs.
­
16­
Based
on
the
general
schedule
(
GS)
pay
schedule,
EPA
assumes
average
hourly
labor
rates
of
$
55
for
managerial
staff
and
$
39
for
technical
staff.
This
rate
was
multiplied
by
the
standard
government
overhead
factor
of
1.6.

Exhibit
6.2.
Annual
Agency
Burden/
Cost
Activities
Estimated
Hours
per
Response
Total
Hours
Other
Direct
Costs
TOTAL
COST
M
$
55/
hour
T
$
39/
hour
LSP
Membership
Agreement
(
200
Members)

Distribute
Program
Information
and
Forms
0.25
50
Postage
=
$
74
Reproduction
=
$
88
$
2,112
Answer
Questions
0.1
0.2
60
$
2,260
Record/
Enter
Forms
0.1
0.15
50
$
2,270
Subtotal
0.2
0.6
160
$
163
$
7,042
Annual
Member
Report
(
300
Reports)

Distribute
Form
0.25
70
Postage
=
$
111
Reproduction
=
$
132
$
3,168
Answer
Questions
0.1
0.2
90
$
3,990
Review
Submitted
Data
0.20
0.3
150
$
6,810
Enter/
QA
Data
in
Spreadsheet
0.25
0.25
150
$
7,050
Subtotal
0.55
1.0
465
$
243
$
21,018
LSP
Partner
Agreement
(
40
Partners)

Distribute
Program
Information
0.25
10
Postage
=
$
15
Reproduction
=
$
18
$
422
Answer
Questions
and
Meet
with
Potential
Partner
to
Determine
Role
2.5
2.5
200
$
9,400
General
Counsel
Review
of
Agreement
2.0
80
$
4,400
Record/
Enter
Forms
0.1
0.15
10
$
454
Subtotal
4.6
2.9
300
$
32
$
14,676
Annual
Partner
Report
(
60
Reports)
Distribute
Annual
Report
Questions
0.25
15
$
585
Perform
Telephone
Interview
0.25
0.75
60
$
2,580
Review
Submitted
Data
0.25
0.25
30
$
1410
Enter/
QA
Data
in
Spreadsheet
0.25
0.25
30
$
1410
Subtotal
0.75
1.5
135
$
0
$
5,985
Total
1060
$
437
$
48,721
Activities
Estimated
Hours
per
Response
Total
Hours
Other
Direct
Costs
TOTAL
COST
M
$
55/
hour
T
$
39/
hour
­
17­
YEAR
1
LSP
Membership
Agreement
(
50)
0.2
0.6
40
$
41
$
1,761
Annual
Member
Report
(
50)
0.55
1.0
78
$
41
$
3,502
LSP
Partner
Agreement
(
10)
4.6
2.9
75
$
8
$
3,669
Annual
Partner
Report
(
10)
0.75
1.5
23
$
0
$
998
TOTAL
6.1
6.0
115
$
49
$
9,930
YEAR
2
LSP
Membership
Agreement
(
100)
0.2
0.6
80
$
81
$
3,521
Annual
Member
Report
(
150)
0.55
1.0
233
$
123
$
10,510
LSP
Partner
Agreement
(
20)
4.6
2.9
150
$
16
$
7,338
Annual
Partner
Report
(
30)
0.75
1.5
68
$
0
$
2,993
TOTAL
6.1
6.0
330
$
138
$
24,362
YEAR
3
LSP
Membership
Agreement
(
50)
0.2
0.6
40
$
41
$
1,761
Annual
Member
Report
(
100)
0.55
1.0
155
$
82
$
7,007
LSP
Partner
Agreement
(
10)
4.6
2.9
75
$
8
$
3,669
Annual
Partner
Report
(
20)
0.75
1.5
45
$
0
$
1,995
TOTAL
6.1
6.0
315
$
172
$
14,432
3­
YEAR
TOTAL
1062
$
441
$
48,724
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
a.
Respondent
Tally
Exhibit
6.3.
Average
Annual
Estimated
Respondent
Burden
and
Cost
Summary
Number
of
Respondents
Average
Annual
Burden
Hours
per
Respondent
Average
Annual
Cost
per
Respondent
Members:
200
1.33
$
69
Partners:
40
2.75
$
142
­
18­
b.
Agency
Tally
Exhibit
6.4.
Average
Annual
Estimated
Agency
Burden
and
Cost
Summary
Annual
Burden
Hours
Average
Annual
Cost
353
$
16,240
6(
f)
Reasons
for
Change
in
Burden
Because
this
is
a
new
ICR,
change
in
respondent
burden
is
not
applicable.

6(
g)
Burden
Statement
The
annual
public
burden
for
this
collection
of
information
is
estimated
to
range
between
1.33
and
2.75
hours
per
response,
depending
upon
the
category
of
the
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
number
for
this
information
collection
appears
above.
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
0127,
which
is
available
for
public
viewing
at
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Pollution
Prevention
and
Toxics
Docket
is
(
202)
566­
0280.
An
electronic
version
of
the
public
docket
is
available
through
EDOCKET
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OPPT­
2004­
0127
in
any
correspondence.

ATTACHMENTS:

Attachment
A
­
TSCA
Section
402
Attachment
B
­
40
CFR
Part
745,
Subpart
L
 
Lead­
Based
Paint
Activities
Attachment
C
­
Lead
Safety
Partnership
Member
Agreement
Attachment
D
­
Annual
Member
Report
on
Progress
in
Meeting
Goals
of
Agreement
Attachment
E
­
Lead
Safety
Partnership
Partner
Agreement
Attachment
F
­
Annual
Partner
Report
on
Progress
in
Meeting
Goals
of
Agreement
