Supporting Statement for a Request for OMB Review

Under the Paperwork Reduction Act

1.	Identification of the Information Collection

	1(a)	Title of the Information Collection

	TITLE:	Second Proposed Rule Related Addendum to Existing EPA ICR

Entitled: TSCA Sections 402/404 Training and Certification,
Accreditation, and Standards for Lead-Based Paint Activities

	ICR No.	EPA ICR No. 1715.08; OMB 2070-0155

	1(b)	Short Characterization/Abstract

  SEQ CHAPTER \h \r 1 	The following information collection request
(ICR) addendum covers reporting and recordkeeping requirements for
individuals and firms conducting renovations in child-occupied
facilities, which are pre-1978 residential, public, or commercial
buildings where children under 6 are regularly present.  These rules are
promulgated under the authority of Sections 402, 404, and 407 of the
Toxic Substances Control Act (TSCA).  This ICR revises ICR numbers
1715.06 and 1715.07 to incorporate reporting and recordkeeping
requirements in a supplemental notice of proposed rulemaking expected to
publish in the Federal Register on [insert anticipated publication
date]. 

	Section 402(a) of TSCA requires EPA to develop and administer a
training and certification program as well as work practice standards
for persons who perform lead-based paint activities.  The current
regulations in 40 CFR part 745, subpart L, cover inspections, lead
hazard screens, risk assessments, and abatement activities in target
housing, which is most pre-1978 housing, and child-occupied facilities. 
Section 402(c)(3) of TSCA directs EPA to revise its regulations under
TSCA Section 402(a) to apply to renovation and remodeling activities,
basing its decisions on a study of hazards created by renovation and
remodeling activities and on consultation with interested stakeholders. 

On January 11, 2006, EPA proposed regulations covering renovations in
target housing.  EPA is now proposing to extend the requirements in that
proposal to renovations in child-occupied facilities.  The supplemental
proposal would define a child-occupied facility as a building, or
portion of a building, constructed prior to 1978, visited regularly by
the same child, under 6 years of age, on at least two different days
within any week (Sunday through Saturday period), provided that each
day’s visit lasts at least 3 hours and the combined weekly visits last
at least 6 hours, and the combined annual visits last at least 60 hours.
 Child-occupied facilities may include, but are not limited to, day-care
centers, preschools and kindergarten classrooms.  Child-occupied
facilities may be located in target housing or in public or commercial
buildings.  In public or commercial buildings that contain
child-occupied facilities, the child-occupied facility encompasses only
those common areas that are routinely used by children under 6, such as
restrooms and cafeterias.  Common areas that children under 6 only pass
through, such as hallways, stairways, and garages are not included.  In
addition, for public or commercial buildings that contain child-occupied
facilities, the child-occupied facility encompasses only the exterior
sides of the building that are immediately adjacent to the
child-occupied facility or the common areas routinely used by children
under 6.  		

	Like the regulations under Section 402(a) of TSCA, the regulations
pertaining to renovation projects under Section 402(c)(3) of TSCA would
require reporting and/or recordkeeping from three entities:  firms
engaged in renovations in target housing and child-occupied facilities;
training providers; and States/Territories/Tribes/Alaskan Native
Villages (hereafter, the term “States” includes Territories, Tribes
and Villages).  The following sections provide a general overview of the
reporting and recordkeeping requirements for each entity, discussed in
more detail in section 4(b).

  SEQ CHAPTER \h \r 1 Firms.  Firms that wish to engage in renovations
in target housing or child-occupied facilities would be required to
obtain certification from EPA/States.  This includes firms consisting
only of one self-employed individual.  To receive certification, a firm
would have to submit a letter to EPA/States certifying that it will
employ certified renovators and conduct renovations in target housing in
accordance with the work practice standards.  Firms would have to
re-certify every three years.  The rule would also require that firms
develop and retain records of the renovation activities they undertake
to demonstrate compliance with standards and provide a written record
for future reference.  In addition, for renovations in child-occupied
facilities located in public or commercial buildings, the rule would
require firms to provide   SEQ CHAPTER \h \r 1 the building owner and
adult representative of the child-occupied facility with a lead hazard
information pamphlet, and make the information available to interested
parents and guardians of children frequenting the facility.  After
providing the pamphlet to the owner and occupant and obtaining written
acknowledgment, the firm must keep acknowledgment records on file for
three years after completion of work.  (Existing regulations require the
distribution of a lead hazard information pamphlet, and the associated
recordkeeping, before renovations in all target housing.  This burden is
reflected in ICR 1669.04, OMB 2070-0158.)  The reporting and
recordkeeping requirements are necessary to provide EPA compliance
monitoring and enforcement personnel with information necessary to track
compliance activity and to prioritize inspections.    SEQ CHAPTER \h \r
1 The Agency believes that the distribution of the pamphlet will help to
further reduce exposures that can cause serious lead poisonings in
children under age six, who are particularly susceptible to the hazards
of lead.

Training providers.  Training programs seeking to offer training for
renovators or dust sampling technicians would be required to obtain
EPA/State accreditation.  In order for EPA/States to have the
information necessary to evaluate and accredit the training programs,
training providers would be required to prepare and submit application
packages.  Training programs also would have to retain certain records
related to their students and training personnel qualifications. 
Training programs would be required to notify the Agency 1) prior to
providing training courses, and 2) following completion of training
courses.  Training programs would have to apply for re-accreditation
every four years.  These notification requirements are necessary to
provide EPA compliance monitoring and enforcement personnel with
information necessary to track compliance activity and to prioritize
inspections.

 

States.  EPA has proposed to allow States to administer programs
addressing training, certification, accreditation, and standards for
renovations in target housing and child-occupied facilities.  EPA has
also proposed to continue to allow States to administer programs
addressing the distribution of lead hazard information before renovation
activities commence.  Under TSCA Section 404, EPA would have to review
and assess State submissions to determine whether authorization is
warranted.  A State seeking authorization will need to provide
information to EPA so the Agency may determine whether its program is at
least as protective of human health and the environment as the Federal
program and whether it provides adequate enforcement.  Authorized States
would be required to provide a report to EPA on their activities.

  SEQ CHAPTER \h \r 1 	This proposed ICR revises ICR numbers 1715.06 and
1715.07 to incorporate the burden of the proposed extension of the
recordkeeping and reporting requirements to firms that engage in
renovations in child-occupied facilities.

  	In addition to these new requirements for renovations in
child-occupied facilities, EPA is proposing to amend the Pre-Renovation
Education Rule to require that persons performing renovations in target
housing or child-occupied facilities provide a new, renovation-specific
pamphlet to the owners and occupants of the buildings being renovated. 
A State seeking authorization for a renovation program would have to use
either the EPA-developed renovation pamphlet or a comparable pamphlet
developed by the State.  States with existing authorization to
administer the Pre-Renovation Education Rule program in their
jurisdictions would be given time to amend their programs to incorporate
an approved renovation-specific pamphlet as well as the new requirements
for information distribution associated with renovations in
child-occupied facilities located in public or commercial buildings. 

2.	Need for and Use of the Collection

	2(a)	Need/Authority for the Collection

  SEQ CHAPTER \h \r 1 	Under Section 402(a)(1) of TSCA, the Agency must
“...promulgate final regulations governing lead-based paint activities
to ensure that individuals engaged in such activities are properly
trained; that training programs are accredited; and that contractors
engaged in such activities are certified.  Such regulations shall
contain standards for performing lead-based paint activities, taking
into account reliability, effectiveness and safety.” 

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

	-	Minimum requirements for the accreditation of training providers;

	-	Minimum training curricula requirements;

	-	Minimum training hour requirements;

	-	Minimum hands-on training requirements;

	-	Minimum training competency and proficiency requirements;

	-	Minimum requirements for training program quality.”

	Section 402(c)(3) directs EPA to revise its regulations under TSCA
Section 402(a) to apply to renovation and remodeling activities that
create lead-based paint hazards.  

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

	Section 407 of TSCA states that regulations shall include such
recordkeeping and reporting requirements as may be necessary to ensure
effective implementation.   

	The Agency’s proposed amendments to the regulations issued under
Sections 402(a), 402(c)(3), 404, and 407 fulfill these statutory
mandates.

	2(b)	Practical Utility/Users of the Data

	Public or Commercial Building Owners, Child-occupied Facility
Operators, and Parents/Guardians

	The owner of a public or commercial building containing a
child-occupied facility must be provided with a lead hazard information
pamphlet before any renovation in the child-occupied facility commences.
 In addition, if the child-occupied facility is not operated by the
owner of the building, an adult representative of the child-occupied
facility must also be provided with a lead hazard information pamphlet. 
The firm performing the renovation must make lead hazard information
available to the parents and guardians of children frequenting the
child-occupied facility.  Information contained in this pamphlet may be
used by building owners, child-occupied facility operators, and
parents/guardians to take appropriate precautions to avoid the exposure
of children under age six to lead-contaminated dust and lead-based paint
debris that are sometimes generated during renovations.

	EPA

  SEQ CHAPTER \h \r 1 	This information collection will provide EPA with
the materials necessary to authorize State renovation programs and to
serve as the accrediting and certifying body in States without
authorized programs, discussed further below.

	EPA/States

  SEQ CHAPTER \h \r 1 	This collection will enable EPA/States to
determine compliance with and enforce the requirements for
renovation-specific training, certification, accreditation, and work
practice standards.  Without this collection, there would be no
meaningful way of ensuring the implementation of the statutory
objective: to ensure that trained individuals conduct renovations in
such a way as to minimize potential harm to occupants.  The proposal
provides flexibility for individuals conducting renovations, by relying
on guidance and training to help renovators determine the best
approaches to controlling leaded dust that may be created during
renovation activities.  The Agency believes this is the best method for
accommodating a variety of renovation projects and site-specific
conditions. 

	It is the nature of certification and accreditation that an entity
seeking such must provide materials to the certifying or accrediting
body.  The materials the Agency/State requires for these activities are
central to the activity.  In addition, EPA will be relying on training
provider notifications to keep track of which individuals have received
accredited renovator training.  This information will be a critical part
of EPA’s compliance monitoring and enforcement activities.  

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

	The records renovation firms would have to compile and retain are
necessary as a reference for building owners/occupants, EPA or
authorized entities.  The records would demonstrate that individuals
conducting the activities do so in a safe and effective manner,
according to the minimum work practice standards established by the
rule.  These recordkeeping requirements are also necessary to permit the
Agency to target its enforcement activities and to ensure compliance
within the contracting and training community.

3.	Nonduplication, Consultations, and Other Collection Criteria

	3(a)	Nonduplication

  SEQ CHAPTER \h \r 1 	The Agency’s collection pursuant to the TSCA
402/404/407 regulations does not

duplicate any other collection. There is no other model program for
lead-based paint activities and renovations, or associated State program
approval process, and there are currently no other Federal requirements
for the training and certification of individuals engaged in these
activities, for the accreditation of training programs, required
standards for the conduct of these activities, or lead hazard
information distribution requirements for renovations in child-occupied
facilities.

	3(b)	Public Notice Required Prior to ICR Submission to OMB

  SEQ CHAPTER \h \r 1 	The supplemental notice of proposed rulemaking
serves as the public notice for this ICR addendum.  Interested parties
should submit comments to the address listed at the end of this
document.  Responses will be taken into account in developing the final
rulemaking.

	3(c)	Consultations

  SEQ CHAPTER \h \r 1 	During the development of the proposed renovation
regulations, the Agency has consulted with a broad range of interested
parties, including States, training providers, renovation contractors,
and advocacy groups.  More information on EPA’s consultations with
stakeholders can be found in the preamble to the 2006 proposal and the
preamble to the supplemental notice.  Summaries and transcripts of
meetings with stakeholders can be found in the docket for the proposed
rule.

	3(d)	Effects of Less Frequent Collection

  SEQ CHAPTER \h \r 1 	Due to the nature of this regulation and its
collection, less frequent collection is not feasible.  In particular,
each firm must obtain certification and re-certification, each training
program must obtain accreditation and re-accreditation as well as
provide specific notification and documentation prior to commencement
and upon completion of each course, and each renovation activity is a
separate and unique event requiring the distribution of lead hazard
information and specific documentation.  Program approval for States is
a one-time activity, although there is ongoing reporting.

	3(e)	General Guidelines

  SEQ CHAPTER \h \r 1 	This ICR is consistent with OMB’s general
guidelines.  The Agency is requiring that firms maintain records for
three years.  Authorized States report once a year for the first three
years, and biannually thereafter.

	EPA has proposed to apply the current recordkeeping requirements for
lead-based paint activities training providers to training providers
that wish to offer renovator or dust sampling technician courses.  This
recordkeeping requirement is three and one-half years.  This is due to
the interim certification period of six months following an individual
completing lead-based paint activities training, which allows the
individual time to apply to EPA/States to receive official
certification.  At such time, the individual remains certified for three
years before he or she must obtain refresher training and
re-certification.  EPA wishes training providers to maintain records on
a particular student for as long as the individual is certified
following training, so three and one-half years is an appropriate period
for the retention of such records.  It is likely that most training
providers that seek accreditation to offer renovator or dust sampling
technician courses will already be accredited to offer lead-based paint
activities courses.  The Agency believes that a single recordkeeping
period for these providers will be simpler and easier to administer. 

	3(f)	Confidentiality

  SEQ CHAPTER \h \r 1 	Neither the existing regulations nor the proposal
address questions of a confidential nature.

	3(g)	Sensitive Questions

	  SEQ CHAPTER \h \r 1 Neither the existing regulations nor the proposal
address questions of a sensitive nature.

4.	The Respondents and the Information Requested

	4(a)	Respondents/NAICS Codes/SIC Codes

  SEQ CHAPTER \h \r 1 	Respondents to the existing rule include: 1)
firms and individuals engaged in lead-based paint activities, 2)
training programs providing training services in lead-based paint
activities, and 3) State programs.  Respondents for the reporting and
recordkeeping requirements of the 2006 proposed amendments to the rule
and the supplemental notice of proposed rulemaking for child-occupied
facilities include: 1) firms and individuals engaged in residential
renovations, 2) firms and individuals engaged in renovations in
child-occupied facilities, 3)training programs providing training
services in lead-based paint activities and renovations, and 4) State
programs.  The North American Industrial Classification System (NAICS)
codes associated with industries most likely affected by the paperwork
requirements covered in ICR 1715.07 and this ICR addendum are described
below:

	236118	Residential Remodelers

	238210	Electrical Contractors

	238220	Plumbing, Heating, and Air-Conditioning Contractors

	238320	Painting and Wall Covering Contractors

	238350	Finish Carpentry Contractors

	238310	Drywall and Insulation Contractors

	238170	Siding Contractors

	238340 	Tile and Terrazzo Contractors

	238150	Glass and Glazing Contractors

	238390 	Other Building Finishing Contractors

	238290	Other Building Equipment Contractors

	531110	Lessors of Residential Buildings and Dwellings

	531311	Residential Property Managers

	541330	Engineering Services

	541350	Building Inspection Services

	611110	Elementary and Secondary Schools

	611519	Other Technical and Trade Schools

	624410	Child Day Care Services

	4(b)	Information Requested

  SEQ CHAPTER \h \r 1 	The existing rule specifies reporting and record
keeping for training providers and individuals/firms undertaking
lead-based paint abatement activities.  The 2006 proposal and the
supplemental notice of proposed rulemaking would add reporting and
record keeping for individuals/firms undertaking renovations in target
housing and child-occupied facilities. 

	(i)	Data Items

	States

  SEQ CHAPTER \h \r 1 	In order to obtain authorization from EPA to
administer and enforce a program under section 404, States must prepare:

	-	A notice of intent to seek authorization; and

An application for authorization identifying the agencies responsible
for implementation, administration, and enforcement of the program, and
a description of the authority and responsibilities vested in such
agencies.

	

  SEQ CHAPTER \h \r 1 	States that receive authorization for lead-based
paint activities programs under the existing rule and/or renovation
programs under the proposed rule must submit to EPA a report summarizing
implementation and enforcement activities, including a list of
enforcement actions taken and any changes in content, administration, or
enforcement of the State program.

	Training Providers

  SEQ CHAPTER \h \r 1 	To receive accreditation to provide lead-based
paint activities courses under the existing rule or renovator or dust
sampling technician courses under the proposals, training providers must
submit the following documents to EPA/State, using either the EPA Form
747-B-98-003 entitled “Application and Instructions for Training
Providers” or a similar form containing the required information:

An accreditation statement that clearly indicates how the training
program meets the minimum requirements for accreditation; and

A quality control plan, which outlines procedures for periodic revision
of training materials and exams, annual review of instructors, and
adequacy of the training facilities.  

  SEQ CHAPTER \h \r 1 	Before giving a lead-based paint activity
training course under the existing rule or a renovator or dust sampling
technician course under the proposal, training providers must provide
notification to the Agency, using either the sample form entitled
“Lead-Based Paint Training Course Schedule” or a similar form
containing the required information.  Training providers may provide
electronic submissions using the Agency’s Central Data Exchange (CDX)
(secure internet based electronic submission of data).  The initial
notice must include the following:

Notification type (Original, Updated, Cancellation);

Training program name, EPA accreditation number, address, and phone
number;

Course discipline, type (initial/refresher), and the language in which
instruction will be given;

Date(s) and time(s) of training;

Training location(s) phone number, and street address;

Principal instructor’s name; and 

Training manager’s name and signature.

  SEQ CHAPTER \h \r 1 	Training providers must update the Agency
regarding any changes to training dates, course locations, course
cancellations, or other changes made to the original notice.

	Following completion of lead-based paint activities, renovator, or dust
sampling technician courses, training providers must provide notice
using either the sample form, entitled “Lead-Based Paint Training
Course Follow-Up” or a similar form containing the required
information.  Training providers may provide electronic submissions
using the Agency’s CDX.  The notice must include the following:

Training program name, EPA accreditation number, address, and phone
number;

Course discipline and type (initial/refresher);

Date(s) of training;

The following information for each student who took the course:

Name

Address

Date of birth

Course completion certificate number

Student test score

Training manager’s name and signature

	Training course providers must maintain the following records:

Records demonstrating the qualifications of the training manager and the
principal instructor(s);

Current curriculum and course materials;

Course test blueprints;

Information on how hands-on assessments are conducted;

Quality control plan;

Results of students’ hands-on assessments and course test;

Record of each student’s course completion certificate.  

		Firms

 	  SEQ CHAPTER \h \r 1 To obtain certification to conduct either
lead-based paint activities under the existing rule or renovations under
the 2006 proposal and the supplemental notice, firms must submit
specific materials to EPA/State, using either the sample EPA Form
747-B-99-001 entitled “Application and Instructions for Firms” or a
similar form containing the required information:

List of current permits, licenses, certifications, or registrations in
the lead-based paint field held by the firm;

Explanation of any violations related to lead-based paint;

Certification statement that the firm will employ only properly
certified or trained individuals and that its employees will follow the
specified work practice standards.

  SEQ CHAPTER \h \r 1 	On occasion, firms may later amend their
application to add or modify information.  Certified firms must apply
for re-certification every three years.

	Firms performing renovations in child-occupied facilities in public or
commercial buildings must provide lead hazard information pamphlets to
the building owners and child-occupied facility representatives and make
them available to parents/guardians of children frequenting the
facility.  Firms must prepare and maintain documentation providing proof
that pamphlets were provided to building owners and child-occupied
facility representatives,   SEQ CHAPTER \h \r 1 or that an attempt was
made to provide the pamphlets.  Examples of such documentation include
signed acknowledgment forms, self-certifications for failed deliveries,
and postal receipts for mailings.  

  

		In addition, firms conducting renovations would be required to
maintain records demonstrating compliance with the proposed requirements
for using certified renovators and properly trained workers, posting
signs, containing the renovation work area, cleaning the renovation work
area, and performing a post-renovation cleaning verification or dust
clearance testing after the renovation activity has been completed. 

		(ii)	Respondent Activities

  SEQ CHAPTER \h \r 1 	The proposed rule specifies reporting and
recordkeeping for authorized States, training providers, and individuals
and firms undertaking renovations.  The rule does not require specific
forms or applications for submissions.

		States seeking authorization for a renovation program will perform the
following activities:

Read the regulations;

Compare any existing State program requirements to the minimum
requirements of the Federal regulation;

Develop and adopt new legislation as necessary;

Develop and promulgate new regulations as necessary;

Publish a notice of intent to seek authorization and provide an
opportunity for public hearing;

Prepare and submit to EPA an application for program approval;

Maintain program application availability for public inspection for up
to one year after submission; and

Submit an annual report to EPA.

	Training providers seeking accreditation for renovator or dust sampling
technician courses will perform the following activities:

Read the regulations;

Prepare and submit an accreditation application to the accrediting
entity;

Submit an initial and, if needed, amended notification of courses to be
given;

Provide notice of completion of all courses offered;

Retain records; and

Provide accrediting entity access to records as requested.

	Firms perform the following activities:

Read the regulations;

Submit applications for certification; 

Provide lead hazard information pamphlets to building owners and
child-occupied facility operators and make them available to
parents/guardians; and

Prepare and retain records.  

	5.	Agency Activities, Collection Methodology, and Information
Management

		5(a)	Agency Activities

	EPA will perform the following activities in response to the submittals
required by this proposal:

Receive, review, and act on applications for authorization from States;

Receive, review, and file reports from authorized States;

Receive, review, and act on applications for accreditation from training
providers;

Receive, review, and file initial, update, and course completion notices
from training providers; and

Receive, review, and act on applications for certification from
renovation firms.

		5(b)	Collection Methodology and Management

	  SEQ CHAPTER \h \r 1 For purposes of this proposal, the Agency will
make use of existing technology to simplify the application and
notification process where possible.  In addition to the more
traditional methods (mail, commercial delivery service, or hand
delivery), the Agency would accept fax and e-mail course notifications
from training providers as well as notifications through the Central
Data Exchange (CDX).  E-mail notification would have to be followed by a
written notification for the record, but the original e-mail notice
would satisfy the applicable notification time requirements.  In
addition, firms may use CDX to apply for certification and
re-certification.

	5(c)	Small Entity Flexibility

  SEQ CHAPTER \h \r 1 	The Agency has attempted to ensure that its
proposed regulatory requirements do not unduly burden small businesses. 
As part of the development process for the rule, the Agency convened a
Small Business Advocacy Review Panel under the Regulatory Flexibility
Act.  More information on this Panel, as well as the Agency’s
assessment of the impacts of the proposal on small businesses, can be
found in the preamble to the 2006 proposal and the preamble to the
supplemental notice.  

	5(d)	Collection Schedule

  SEQ CHAPTER \h \r 1 	For authorization, certification, and
accreditation, collection activities will occur according to the
following schedule:

States/Tribes may submit an application for program authorization at any
time;

Training programs may apply to become accredited at any time;

Training programs must seek re-accreditation at four-year intervals
following initial accreditation;

Firms may apply for certification at any time;

Firms must seek re-certification at three-year intervals following
initial certification.

Firms must provide building owners and COF representatives with the
renovation-specific pamphlet no more than 60 days prior to beginning a
renovation project.

  SEQ CHAPTER \h \r 1 	The Agency believes that receipt of notification
7 business days prior to conducting training courses is necessary to
facilitate the inspection of training locations.  The regulation also
includes provisions for updating the original notification.  The Agency
determined that the time periods for initial notification will also
apply to a change in course location, or if the course is to be
presented earlier than described in the original notification.  Other
changes, including cancellation of courses, need only be received by the
Agency at least 2 business days before a training course is scheduled to
begin.  Such notification periods are appropriate to allow proper
allocation of EPA compliance monitoring and enforcement resources, and
to prevent the arrival of Agency personnel at the wrong location or
time.

6 	ESTIMATING THE BURDEN AND COST

This section estimates the incremental burden of reporting and
recordkeeping for the proposed renovation requirements under TSCA
section 402(c)(3) that pertain to renovations in child-occupied
facilities (COFs).  This burden is incremental to the burden already
accounted for in the Supporting Statement for OMB Review under the
Paperwork Reduction Act: TSCA Sections 402/404 Training, Certification,
Accreditation and Standards for Lead-Based Paint Activities (EPA ICR No.
1715.06, OMB Control No:2070-0155) and the Supporting Statement for OMB
Review under the Paperwork Reduction Act: Proposed Rule Related Addendum
to Existing EPA ICR entitled: TSCA Sections 402/404 Training and
Certification, Accreditation, and Standards for Lead-Based Paint
Activities (EPA ICR No. 1715.07, OMB Control No. 2070-0155).  The
estimates of the number of entities subject to the proposed requirements
were taken from the Economic Analysis for the Supplemental Proposed Rule
on Child-Occupied Facilities Under the TSCA Lead Renovation, Repair and
Painting Program, also referred to as the Supplemental Economic Analysis
(EPA 2007).  

The supplemental proposal would phase in the rule’s requirements.  In
Phase 1, the recordkeeping and reporting requirements would initially
apply to all renovations for compensation in child-occupied facilities
that are used by a child with an increased blood lead level and
child-occupied facilities constructed before 1960.  This phase would
last one year, so this time period is referred to as Year 1.  In Phase
2, beginning in Year 2, coverage would be expanded to child-occupied
facilities built in the years 1960 through 1977.  This supporting
statement provides burden and cost estimates for Years 1 through 3.  All
costs are presented in year 2005 dollars.  

Sections 6(a) and 6(b) estimate the respondents’ paperwork burdens and
costs, respectively.  Section 6(c) estimates EPA costs, section 6(d)
summarizes the bottom line burden and costs, section 6(e) describes the
reasons for changes in burden from the previous ICR, and section 6(f)
presents the burden statement.

6(a)	Estimating Respondent Burden

Two types of respondents will be affected by this information collection
request:  training providers and entities performing renovation, repair,
and painting activities.,  The paperwork burden associated with
reporting and recordkeeping for these two types of respondents is
estimated separately.  The reporting estimates include the time
associated with reviewing instructions, collecting the information
needed to complete the notification form, and completing and sending the
notification forms to the appropriate authority.  The recordkeeping
burden estimates include the time required for the respondent to file a
record of the information.

Training Providers

To comply with the Renovation, Repair, and Painting rule, training
providers must gain accreditation and keep records on both the courses
they provide and the students they train.  They must notify EPA both
before offering each course (to facilitate EPA’s enforcement
activities) and after each course (so EPA has a record of the
individuals who have completed the course).  

  SEQ CHAPTER \h \r 1 The training providers that will become accredited
as a result of the 2006 proposed rule will have sufficient capacity to
provide training for persons who wish to conduct renovations in
child-occupied facilities.  Therefore, no additional training providers
are expected to seek accreditation under the COF LRRP Rule, and there
will be no incremental accreditation burden.  It is assumed that there
will be 100 accredited training providers in Year 1 of the regulation
and 168 training providers in Years 2 and 3.  This yields an average of
145 accredited training providers each year over the three years covered
by this ICR.

Under the 2006 proposed rule, training providers will spend time
familiarizing themselves with the rule, determining the rule’s
applicability to their services, completing the accreditation statement,
and keeping records associated with accreditation.    REF _Ref159298080
\h  Exhibit 6.1  presents the types of accreditation activities
generating burden for training providers.  However, since there are no
additional training providers expected to become accredited as a result
of the supplemental proposal, there is no additional burden or cost
estimated in this ICR supporting statement for training provider
accreditation.   

Under the proposed rule, pre-course notification would be required at
least 7 business days prior to the start of a renovator or dust sampling
technician course.  Re-notification would be required if the course date
changes.  Within 10 days of course completion, training providers would
be required to submit a post-course notification. The following sections
discuss how the reporting and recordkeeping burden estimates in this
analysis were developed.    REF _Ref159313028 \h  \* MERGEFORMAT 
Exhibit 6.2  presents the estimation of training provider burden for
course notifications resulting from the supplemental proposal for COFs.

This analysis assumes that training providers will complete a separate
notification form for each renovator or dust sampling technician course
conducted.  The number of pre-course and post-course notification events
was estimated by dividing the total number of students in a given year
by an estimated average class size and the estimated number of training
providers.  (See the Supplemental Economic Analysis (EPA 2007) for
details.)  The number of notification events were rounded upwards to
reflect the possibility that some courses will be under subscribed. 
There is one pre- and one post-notification for each training course,
with an average burden of 0.15 and 1.54 hours each.  (Post-notifications
are more time consuming because the training provider must send records
pertaining to each student who attended the course.)  In addition, some
courses may require re-notification. Re-notification events are
calculated based on notification events in EPA’s Federal Lead-Based
Paint Program (FLPP) database.  Re-notifications are estimated to occur
for approximately 12 percent of original pre-course notifications, and
are also estimated to require 0.15 hours of time.  Estimates of the
amount of time required to complete the pre-course and post-course
notification forms were determined in EPA ICR No. 1715.06.  

The training provider burden estimates described above also include the
recordkeeping burden associated with filing a one page record of the
notification form sent to the administering agency.  An estimate of the
amount of time needed to file a record was adopted from EPA ICR No.
1715.06 and is estimated to be 0.01 hours per training event.

As presented below in   REF _Ref159298132 \h  \* MERGEFORMAT  Exhibit
6.3 , this addendum estimates the burden attributable to renovations in
child-occupied facilities for training providers in Year 1 of the
regulation to be 1,798 hours.  In Year 2 the burden for these training
providers rises to 2,115 hours (as additional renovators are trained in
response to Phase Two of the rule).  In Year 3, the burden drops to
1,098 hours to reflect the decrease in the number of renovators needing
training each year, since initial training is generally only needed for
new entrants to the market and retraining is only required every three
years.  The average annual aggregate burden for these training providers
over the three years covered by this ICR addendum is 1,670 hours,
resulting in an average burden of 11.5 hours per year for each training
provider.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  1   Training Providers:
Accreditation Burden Estimates









Number of Training Providers	



	Year 1	Year 2	Year 3

Receiving Initial Accreditation	0	0	0

Receiving  Re-Accreditation	0	0

	0



Already Accredited	

100	

168	

168



Total	

100	

168	

168



	

	

	

	





Accreditation/Re-Accreditation Burden- Hours per Training Provider

	Accreditation Year	Re-Accreditation Year	Other Years

Rule Familiarization	8	0	0

Accreditation Statement	4	4	0



Clerical Time- Statement	

2	

2	

0

Clerical Time- Recordkeeping	1	1	1

Total	15	7	1







Total Accreditation Burden- Hours

	Year 1	Year 2	Year 3

Rule Familiarization	0	0	0

Accreditation Statement	0	0	0



Clerical Time- Statement	0	0	0

Clerical Time- Recordkeeping	0	0	0

Total	0	0	0







Note(s): All necessary training providers are expected to seek
accreditation due to the 2006 proposed rule.  So there is no incremental
burden for accreditation due to the supplemental proposal for COFs.  

Sources: Supplemental Economic Analysis (EPA 2007) and EPA ICR No.
1715.07.  





Exhibit 6.  SEQ Exhibit_6. \* ARABIC  2   Training Providers:
Notification Burden











Category	

Events per Training Provider	

Reporting

Hours/Event	

Recordkeeping

Hours/Event	

Total 

Hours/Event

	Year 1	Year 2	Year 3



	

Pre-notification	10	7	4	0.15	0.01	0.16



Re-notification	1.2	0.9	0.5	0.15	0.01	0.16



Post-notification	10	7	4	1.54	0.01	1.55



Annual Total	22.0	15.4	8.0













	Notification Burden Hours per Training Provider

	

	

	

Year 1	

Year 2	

Year 3	

	





18	13	7











	Training Providers per Year	





	

	

Year 1	

Year 2	

Year 3	

	





100	168	168











	Total Notification Burden Hours per Year	





Year 1	Year 2	Year 3





1,798	2,115	1,098





Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.

Sources: Supplemental Economic Analysis (EPA 2007) and EPA ICR No.
1715.07.  



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  3   Total Training Provider Burden







	Year 1	Year 2	Year 3

Accreditation Burden	0	0	0

Notification Burden	1,798	2,115	1,098

Total Burden	1,798	2,115	1,098

Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.  All training providers are expected
to seek accreditation due to the 2006 proposed rule.  So there is no
incremental burden for accreditation due to the supplemental proposal
for COFs.  

Sources: Supplemental Economic Analysis (EPA 2007) and EPA ICR No.
1715.07.  



Renovation, Repair, and Painting Firms: Certification-Related Burden

Under the supplemental proposal, renovation, repair, and painting (RRP)
firms wishing to conduct renovations in child-occupied facilities would
be required to apply for certification.  They would also be required to
keep records reflecting RRP events conducted by trained employees.

It is estimated that firms that become certified under the rule will
spend a total of three hours familiarizing themselves with the rule’s
requirements when they are initially certified.  They will spend another
half an hour filling out and mailing the Application for Firm
Certification each time they are certified or re-certified. 
(Re-certification is required every three years.)  As shown in   REF
_Ref159299188 \h  \* MERGEFORMAT  Exhibit 6.4 , 24,381 entities will
become certified in the first year as a result of the supplemental
proposal.  In the second year, 28,482 entities will be certified (24,759
initial certifications and 3,723 re-certifications).  In the third year,
14,829 entities will be certified (8,008 initial certifications and
6,821 re-certifications).  The number of firms certified each year are
calculated in the Supplemental Economic Analysis (EPA 2007).  

Additionally, all RRP firms, regardless of whether they are applying for
certification in a given year, will spend time keeping records of RRP
work conducted in child-occupied facilities.  An estimate of the amount
of time needed to file a record was adopted from EPA ICR No. 1715.07. 
On average, RRP firms will spend 5.2 hours on recordkeeping per year. 
The number of events per firm is estimated in the Supplemental Economic
Analysis (EPA 2007).  

	In the first year, it is assumed that the number of firms that seek
certification is equal to the number that is necessary to meet the
demand for lead-safe RRP services in that first year.  Thus, the stock
of firms required to meet the demand for lead-safe RRP services in all
pre-1960 COFs seek certification.  

	In the second year, this analysis makes the simplifying assumption that
one third of the number certified in the first year seek initial- or
re-certification.  (The number of certifications is assumed to decline
by 0.41 percent annually to reflect the decline in the pre-1978 housing
stock.)  In addition, the stock of firms required to meet the additional
demand in the newly regulated structures obtain initial certification
(for the COFs built between 1960 and 1978 that are covered by the rule
in Phase 2).  In later years, it is assumed that one third of the
necessary stock of firms will obtain certification each year (since
re-certification is required every three years).

	As indicated above, this analysis assumes a steady annual number of
firm certifications after the second year of regulation.  If all the
firms needed to meet the demand for lead-safe RRP were certified in the
first and second years, one might expect a drop in the level of
certification in the third year, followed by a spike in the next year. 
That is, one might expect a cyclical pattern of training and
certification to emerge.  However, it is difficult to predict how
cyclical training and certification demand might be, or how this
cyclicality might diminish over time.  Therefore, this analysis assumes
that a typical amount of certification occurs each year after the first
two years because modeling a cyclical component would add little to the
analysis without being able to estimate the extent of any cyclicality
more precisely.

	This analysis accounts for turnover in the regulated RRP industry by
assuming a certain percentage of certifications each year are initial
certifications.  Specifically, after the first year, 54 percent of firms
seeking certification are assumed to be seeking their initial
certification based on the relative frequency of initial certifications
observed for abatement firms in the Federal Lead-Based Paint Program
(FLPP) database.  

As presented below in   REF _Ref159299188 \h  \* MERGEFORMAT  Exhibit
6.4 , this amendment estimates the burden for all firms conducting
renovations in child-occupied facilities in Year 1 to be 212,117 hours
for all entities. The burden is estimated to be 320,803 hours for all
entities in Year 2 (as additional firms are certified in response to
Phase Two of the rule), before dropping to 262,769 hours in Year 3
(reflecting the decrease in the number of firms needing certification,
since re-certification is only required every three years).  There are
an annual average of 265,230 hours during the three year period covered
by this ICR addendum.  This yields an average burden of 7 hours per year
for RRP firms. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  4  Firms: Certification Burden
Estimates





Number of Firms	



	Year 1	Year 2	Year 3

Contractors Working in Target Housing COFs (See Notes)

Receiving Initial Certification	1,402	1,441	464

Receiving  Re-Certification	0	214	395



Subtotal: Firms Receiving Certification or Re-Certification	1,402	1,655
858



Already Certified - Not Receiving Certification or Re-Certification	0
931	1,717



Total	1,402	2,586	2,575

Entities Working in Commercial or Public Building COFs (See Notes)

Receiving Initial Certification	22,979	23,318	7,544

Receiving  Re-Certification	0	3,509	6,426



Subtotal: Firms Receiving Certification or Re-Certification	22,979
26,827	13,970



Already Certified - Not Receiving Certification or Re-Certification	0
15,257	27,941



Total	22,979	42,084	41,911

Total Number of Firms Working in COFs

Receiving Initial Certification	24,381	24,759	8,008

Receiving  Re-Certification	0	3,723	6,821



Subtotal: Firms Receiving Certification or Re-Certification	24,381
28,482	14,829



Already Certified - Not Receiving Certification or Re-Certification	0
16,188	29,658



Total	24,381	44,670	44,487



Certification/Re-Certification/Recordkeeping Burden- Hours Per Firm

	Certification Year	Re-Certification Year	Other Years

Rule Familiarization	3	0	0

Certification Form	0.5	0.5	0

Recordkeeping	5.2	5.2	5.2

Total	8.7	5.7	5.2



Total Certification/Recordkeeping  Burden- Hours

Contractors Working in Target Housing COFs - Total
Certification/Recordkeeping Burden - Hours

 	Year 1	Year 2	Year 3

Rule Familiarization	4,206	4,323	1,391

Certification Form	701	828	429

Recordkeeping	7,290	13,447	13,392

Total	12,197	18,598	15,212

Entities Working in Commercial or Public Building COFs

Total Certification/Recordkeeping Burden - Hours

 	Year 1	Year 2	Year 3

Rule Familiarization	68,938	69,955	22,632

Certification Form	11,490	13,414	6,985

Recordkeeping	119,492	218,837	217,940

Total	199,919	302,205	247,557

Total Certification/Recordkeeping  Burden- Hours

	Year 1	Year 2	Year 3

Rule Familiarization	73,144	74,278	24,023

Certification Form	12,191	14,241	7,414

Recordkeeping	126,783	232,284	231,332

Total	212,117	320,803	262,769

Note(s): Numbers may not calculate due to rounding.  Re-certification
required every three years.    Burden is incremental to EPA ICR No.
1715.07.  Contractors working in target housing COFs include only
contractors working in owner-occupied units without a child under the
age of 6.  Entities working in commercial or public building COFs
include contractors and landlords, as well as schools and daycare
centers that conduct work in-house.  

Sources: Supplemental Economic Analysis (EPA 2007) and EPA ICR No.
1715.07.  



Renovation, Repair, and Painting Firms – Burden Related to
Pre-Renovation Education

Under TSCA section 406(b), persons renovating target housing for
compensation must provide the owner and the occupant of the housing with
a lead hazard information pamphlet before renovations commence.  The
supplemental proposal extends the pre-renovation information
dissemination requirements to renovation projects performed by
contractors or landlords in public or commercial building COFs.  This
analysis assumes that these contractors will work both in COFs that rent
space, and in those that own space.  Landlords will only work in the
buildings that they own.  

The Pre-Renovation Education Rule requirements do not apply to events
where a test kit indicates that lead-based paint is not present;
therefore, it is assumed costs are incurred for events where LSWPs are
used.  The number of LSWP events performed by landlords and contractors
in owner-occupied and rented COFs was calculated using the approach for
estimating the total number of events performed by these entities, as
described in detail in Appendix 4A to Chapter 4 of the Supplemental
Economic Analysis (EPA 2007).  Appendix 4A estimated the percentage of
events, by event and facility type, performed by landlords, contractors,
and by the COFs themselves. These percentages are presented in Table
4A-8 of the Appendix. This analysis applies the percentages presented in
Table 4A-8 to the numbers of LSWP events performed in each type of
daycare facility (see Section 4.2 of Chapter 4) to estimate the number
of events where contractors and landlords will need to distribute
pamphlet(s) and obtain proof of pamphlet receipt prior to beginning
renovation work. 

Number of Landlord Firms and Events Performed by Landlords

As discussed in detail in Appendix 4A to Chapter 4 of the Supplemental
Economic Analysis (EPA 2007), 6,868 non-residential property manager or
lessor firms are expected to rent space to COFs in pre-1960 buildings in
Year 1.  A total of 13,224 firms are expected to rent space to COFs in
pre-1978 buildings in Year 2.  The number of events with LSWP decreases
in Year 2, even as the rule coves all pre-1978 buildings in Phase 2,
because more reliable test kits are expected to become available
starting in Year 2.    REF _Ref159223958 \h  \* MERGEFORMAT  Exhibit 6.5
 presents the number of lessor/manager firms renting space to COFs and
the numbers of LSWP events performed by these firms each year during the
first three years of the rule 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  5 : Number of Non-Residential
Property Manager Firms and LSWP Events They Perform



	Year 1	Year 2	Year 3

Number of Lessor/Manager Firms	6,868	13,224	13,170

Number of LSWP Events Performed	4,912	2,707	2,696

Source(s): Supplemental Economic Analysis (EPA 2007).



Number of Contractor Firms and Events Performed by Contractors

Appendix 4A to Chapter 4 of the Supplemental Economic Analysis (EPA
2007) presents the estimated percentages of RRP events, by event and
facility type, performed by landlords, contractors, and by the COFs
themselves.  To estimate the number of LSWP events performed by
contractors in commercial or public building COFs, percentages of all
RRP events performed by contractors in schools and daycare centers were
applied to the total number of LSWP events performed in these buildings
in a given year.  It is estimated that contractors will perform 142,011
renovation events that require lead-safe work practices in commercial or
public building COFs in the first year.  In the second year, when the
rule covers all pre-1978 buildings and a more reliable test kit becomes
available, the number of LSWP events performed by these contractors is
estimated to decrease to 55,907.

  REF _Ref159223974 \h  \* MERGEFORMAT  Exhibit 6.6  presents the number
of events performed by contractors in the first, second, and third years
of the rule in schools, in daycare centers that own their space and in
daycare centers that rent their space.  These calculations are based on
estimates presented in Table 4A-8 of Appendix 4A of the Supplemental
Economic Analysis (EPA 2007).  

 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  6 : Number of Contractor LSWP
Events by COF Type

Type of COF	Number of Events Performed by Contractors

	Year 1

Option B 

(Pre-1960 

Buildings Only)	Year 2

Option B 

(All Pre-1978 Buildings)	Year 3

Option B

(All Pre-1978 Buildings)

Public and Private Schoolsa	82,258	32,124	31,992

Daycare Centers that Rent their Spaceb	41,008	16,582	16,514

Daycare Centers that Own their Spacec	18,744	7,202	7,172

Total in Owner-Occupied COFs	123,267	48,705	48,506

Total in COFs that Rent Space	18,744	7,202	7,172

Total Events	142,011	55,907	55,678

All schools are assumed to own their buildings.

About 34.2 percent of daycare centers rent their space.  As such, the
number of events performed by contractors in daycare centers that rent
their space is equal to 34.2 percent of the 57,590 LSWP electrical,
plumbing/HVAC, and unscheduled maintenance projects performed by
contractors in all daycare centers (see Footnote 6 of this ICR and Table
4A-8 in Appendix 4A of the Supplemental Economic Analysis (EPA 2007)).  
 

The number of events in daycare centers that own their space is
calculated as the difference between the number of contractor events in
all daycare centers and the number of events in daycare centers that
rent their space (See Table 4A-8 in Appendix 4A of the Supplemental
Economic Analysis (EPA 2007).  



Sources:  Supplemental Economic Analysis (EPA 2007). 



 Estimated Burden per Event

Landlords, as well as contractors working in COFs that own their own
space, will need to prepare one set of acknowledgement and certification
forms, distribute the pamphlet to the COF owner only, and obtain proof
that the pamphlet was provided to the COF owner.  Contractors working in
COFs that are renting space will need to prepare two sets of
acknowledgement and certification forms (one for the building owner, and
the other for the COF owner), distribute the pamphlet to both
individuals, and obtain proof that both individuals have received the
pamphlet.  

This analysis estimates the per-event burden of preparing
acknowledgement and certification forms, distributing pamphlets, and
obtaining proof of pamphlet receipt based on the supporting statement
for the Information Collection Request for the Lead-Based Paint
Pre-Renovation Information Dissemination Rule - TSCA Section 406(b) (EPA
ICR No. 1669.04).  ICR No. 1669.04 estimated that contractors or
landlords will need two minutes each to prepare a set of acknowledgement
and certification forms; photocopy the pamphlet; and deliver the
pamphlet and obtain proof of pamphlet receipt from each individual
involved, and three minutes to file all of the signed acknowledgement
forms or mailing certificates.    REF _Ref159223994 \h  \* MERGEFORMAT 
Exhibit 6.7  presents total per-event burden estimates.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  7 : Per-Event Burden Estimates by
Task (In Hours)



Activity	Burden Hours

	Landlord Event or Contractor Event in COF that Owns Space	Contractor
Event in COF that Rents Space

Preparing Written Acknowledgement	0.033	0.066

Photocopying of Pamphlet	0.033	0.066

Distribution of Pamphlet	0.033	0.066

Filing and Retaining Acknowledgement	0.050	0.050

Total	0.150	0.250

Sources:  Supporting Statement for Lead-Based Paint Pre-Renovation
Information Dissemination - TSCA Sec. 406(b.  EPA ICR No. 1669.04 (2003)





Estimated Total Burden

  REF _Ref159225811 \h  \* MERGEFORMAT  Exhibit 6.8  presents the total
burden and cost to respondents resulting from the extension of
pre-renovation information dissemination requirements to commercial or
public building COF events. Total respondent burden was estimated by
multiplying the numbers of events in Exhibits   REF _Ref159223958 \h  \*
MERGEFORMAT  Exhibit 6.5  and   REF _Ref159223974 \h  \* MERGEFORMAT 
Exhibit 6.6  by the corresponding per-event burden estimates in   REF
_Ref159223994 \h  \* MERGEFORMAT  Exhibit 6.7 .  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  8 : Total Burden and Cost
Estimates



 	Year 1	Year 2	Year 3

Total Burden Hours

Landlords	737	406	404

Contractors Performing Work in COFs Renting Space	4,686	1,800	1,793

Contractors Performing Work in COFs that Own Space	18,490	7,306	7,276

Sources: Supplemental Economic Analysis (EPA 2007). 



6(b)	Estimating Respondent Costs

Introduction

The cost estimates addressed in this section are based on the burden
estimates discussed in section 6(a).  Wage rates for each category of
personnel are based on wage rate information from the Bureau of Labor
Statistics (BLS).  Following are the wage rates used in this analysis,
which are fully loaded (i.e., include fringe benefits and overhead), and
are in 2005 US dollars :

Training Provider Clerical Time	

$23.54/hr



Training Provider Professional Time	

$38.76/hr



RRP Firm Wage Rate	

$31.64/hr



Training Providers

The loaded wage rate for training provider clerical staff is $23.54 per
hour. The loaded wage rate for professional training staff is $38.76 per
hour.  It is assumed that professional staff will familiarize themselves
with the rule and will prepare the accreditation statement.  Clerical
staff will prepare and mail notifications and will perform recordkeeping
activities. Training provider costs also include $0.39 per postage stamp
and $0.02 per envelope for mailing notifications and $0.08 per one page
copy of each notification for the firm’s records. 

  REF _Ref159299491 \h  \* MERGEFORMAT  Exhibit 6.9  estimates the
annual accreditation costs for training providers, and   REF
_Ref159299521 \h  \* MERGEFORMAT  

Exhibit 6.10  estimates the annual cost for training provider
notifications.  As shown in   REF _Ref159299558 \h  \* MERGEFORMAT 
Exhibit 6.11 , this addendum estimates the training provider costs
attributable to renovations in child-occupied facilities in the first
year of the rule to be about $43,364.  In the second year of the rule
the total cost for all such training providers rises to approximately
$51,003 and then drops in Year 3 to $26,489.  The average annual cost
over the three years covered by the ICR addendum is $40,285.  This
yields an average cost of $277 per training provider.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  9   Training Providers:
Accreditation Cost Estimates





Number of Training Providers	



	Year 1	Year 2	Year 3

Receiving Initial Accreditation	0	0	0

Receiving  Re-Accreditation	0	0

	0



Already Accredited	

100	

168	

168



Total	

100	

168	

168



Accreditation/Re-Accreditation Cost per Training Provider – 2005
Dollars

	Accreditation Year	Re-Accreditation Year	Other Years

Rule Familiarization	$310.08	$0.00	$0.00

Accreditation Statement	$155.04	$155.04	$0.00



Clerical Time- Statement	

$47.08	

$47.08	

$0.00

Clerical Time- Recordkeeping	$23.54	$23.54	$23.54

Material Costs	$0.55	$0.55	$0.00

Total Cost	$536.29	$226.21	$23.54



Total Accreditation Cost - 2005 Dollars

	Year 1	Year 2	Year 3

Rule Familiarization	$0	$0	$0

Accreditation Statement	$0	$0	$0



Clerical Time- Statement	$0	$0	$0

Clerical Time- Recordkeeping	$0	$0	$0

Material Costs	$0	$0	$0

Total	$0	$0	$0

Note(s): All training providers are expected to seek accreditation due
to the 2006 proposed rule.  So there is no incremental cost for
accreditation due to the supplemental proposal for COFs.

Sources:  Supplemental Economic Analysis (EPA 2007); EPA ICR No.
1715.07; and U.S. Bureau of Labor Statistics Occupational Employment
Statistics Series (2005).  



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  10   Training Providers:
Notification Cost Estimates









	

Category	

Events per Training Provider	

Reporting

Cost/Event	

Recordkeeping

Cost/Event	

Materials 

Cost/Event	

Total 

Cost/Event

	Year 1	Year 2	Year 3







Pre-notification	10	7	4	$3.53	$0.24	$0.47	$4.24



Re-notification	1.2	0.9	0.5	$3.53	$0.24	$0.47	$4.24



Post-notification	10	7	4	$36.25	$0.24	$0.47	$36.96











	Cost per Training Provider	

	

	

	

Year 1	

Year 2	

Year 3	

	

	





$434 	$304 	$158 













	Training Providers per Year	





	

	

Year 1	

Year 2	

Year 3	

	

	





100	168	168













	Total Cost per Year	





	

	

Year 1	

Year 2	

Year 3	

	

	





$43,364	$51,003	$26,489



	

Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.

Sources: Supplemental Economic Analysis (EPA 2007); EPA ICR No. 1715.07;
and U.S. Bureau of Labor Statistics Occupational Employment Statistics
Series (2005).  







Exhibit 6.  SEQ Exhibit_6. \* ARABIC  11   Total Training Provider
Burden- 2005 Dollars







	Year 1	Year 2	Year 3

Accreditation Cost	$0	$0	$0

Notification Cost	$43,364 	$51,003 	$26,489 

Total Cost	$43,364	$51,003	$26,489

Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.

Sources: Supplemental Economic Analysis (EPA 2007); EPA ICR No. 1715.07;
and U.S. Bureau of Labor Statistics Occupational Employment Statistics
Series (2005).  



RRP Firms – Costs Related to Certification

The loaded wage rate for clerical staff at RRP firms is $31.64.  In
addition to labor costs, firm certification costs also include $0.37 per
postage stamp and $0.02 per envelope for mailing notifications and $0.08
per one page copy of each notification for the firm’s records. 

As presented below in   REF _Ref159299612 \h  \* MERGEFORMAT  Exhibit
6.12 , based on the burden estimates provided in section 6(a) and the
wage rates discussed above, this amendment estimates the costs
associated with certification applications for all firms conducting
renovations in child-occupied facilities in Year 1 to be $6.7 million. 
The notification cost is estimated to rise to $10 million in Year 2 and
then fall to $8.3 million in Year 3.  The average annual cost for these
entities is $8.4 million over the three years covered by this ICR
addendum, resulting in an average cost per firm of $222. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  12   Firms: Certification Cost
Estimates





Number of Firms	



	Year 1	Year 2	Year 3

Contractors Working in Target Housing COFs (See Notes)

Receiving Initial Certification	1,402	1,441	464

Receiving Re-Certification	0	214	395

Subtotal: Firms Receiving Certification or Re-Certification	1,402	1,655
858

Already Certified - Not Receiving Certification or Re-Certification	0
931	1,717

Total	1,402	2,586	2,575

Entities Working in Commercial or Public Building COFs (See Notes)

Receiving Initial Certification	22,979	23,318	7,544

Receiving Re-Certification	0	3,509	6,426

Subtotal: Firms Receiving Certification or Re-Certification	22,979
26,827	13,970

Already Certified - Not Receiving Certification or Re-Certification	0
15,257	27,941

Total	22,979	42,084	41,911

Total Number of Firms Working in COFs

Receiving Initial Certification	24,381	24,759	8,008

Receiving  Re-Certification	0	3,723	6,821



Subtotal: Firms Receiving Certification or Re-Certification	24,381
28,482	14,829



Already Certified - Not Receiving Certification or Re-Certification	0
16,188	29,658



Total	24,381	44,670	44,487



Certification/Re-Certification/Recordkeeping Cost per Firm - 2005
Dollars

	Accreditation Year	Re-Accreditation Year	Other Years

All Entities

Rule Familiarization	$94.92	$0.00	$0.00

Certification Form	$15.82	$15.82	$0.00



Recordkeeping	$164.53	$164.53	$164.53

Material Costs	$0.55	$0.55	$0.00

Total	$275.82	$180.90	$164.53



Total Certification/Recordkeeping Costs - 2005 Dollars

	Year 1	Year 2	Year 3

Contractors Working in Target Housing COFs (See Notes)

Rule Familiarization	$133,078	$136,787	$44,002

Certification Form	$22,180	$26,185	$13,581

Recordkeeping	$230,668	$425,469	$423,725

Material Costs	$771	$910	$472

Total	$386,697	$589,351	$481,780

Entities Working in Commercial or Public Building COFs (See Notes)

Rule Familiarization	$2,181,190	$2,213,370	$716,082

Certification Form	$363,532	$424,408	$221,013

Recordkeeping	$3,780,730	$6,923,996	$6,895,607

Material Costs	$12,639	$14,755	$7,684

Total	$6,338,091	$9,576,528	$7,840,386

Total Certification/Recordkeeping Cost

Rule Familiarization	$2,314,268	$2,350,157	$760,084

Certification Form	$385,711	$450,593	$234,594

Recordkeeping	$4,011,398	$7,349,465	$7,319,332

Material Costs	$13,410	$15,665	$8,156

Total	$6,724,788	$10,165,879	$8,404,278

Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.  Contractors working in target
housing COFs include only contractors working in owner-occupied units
without a child under the age of 6.  Entities working in commercial or
public building COFs include contractors and landlords, as well as
schools and daycare centers that conduct work in-house.  

Sources:  Supplemental Economic Analysis (EPA 2007); EPA ICR No.
1715.07; and U.S. Bureau of Labor Statistics Occupational Employment
Statistics Series (2005).  



RRP Firms – Costs Related to Pre-Renovation Education

In addition to the time needed to prepare acknowledgement forms and
distribute the pamphlet, contractors and landlords will also incur the
costs of either photocopying or purchasing the renovation-specific lead
safety pamphlets.  Based on per-page photocopy costs reported by
Kinko’s, EPA estimates that a single pamphlet costs $0.56 to photocopy
or purchase.    REF _Ref159299649 \h  \* MERGEFORMAT  Exhibit 6.13 
presents resulting per-event pamphlet costs. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  13   Number of Pamphlets and
Pamphlet Cost per Event



 	Event Type

	Landlord Event or Contractor Event in COF that Owns Space	Contractor
Event in COF that Rents Space

Number of Pamphlets	1	2

Cost per Pamphlet	$0.56	$0.56

Total Pamphlet Cost/Event	$0.56	$1.12

Sources: Kinko’s, Personal Communication. February 21, 2007. EPA ICR
No. 1669.04 (2003) Lead-Based Paint Pre-Renovation Information
Dissemination - TSCA Sec. 406(b).



  REF _Ref159299670 \h  \* MERGEFORMAT  Exhibit 6.14  presents the
estimated total costs of pre-renovation education to property
lessors/managers and contractors performing work in commercial or public
building COFs.  To estimate total labor costs associated with
pre-renovation education, the total burden estimates in   REF
_Ref159225811 \h  \* MERGEFORMAT  Exhibit 6.8  were multiplied by the
loaded wage rate for clerical staff ($31.64 per hour).  Total pamphlet
costs were estimated by multiplying the numbers of events in   REF
_Ref159223958 \h  \* MERGEFORMAT  Exhibit 6.5  and   REF _Ref159223974
\h  \* MERGEFORMAT  Exhibit 6.6  by the corresponding pamphlet cost
estimates in   REF _Ref159299649 \h  \* MERGEFORMAT  Exhibit 6.13 .

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  14   Total Costs Associated with
Pre-Renovation Education



Total Labor Cost

	Year 1	Year 2	Year 3

Landlords	$23,312	$12,849	$12,796

Contractors Performing Work in COFs Renting Space	$148,264	$56,965
$56,732

Contractors Performing Work in COFs that Own Space	$585,024	$231,155
$230,208

Total Pamphlet Cost

Landlords	$2,751	$1,516	$1,510

Contractors Performing Work in COFs Renting Space	$20,993	$8,066	$8,033

Contractors Performing Work in COFs that Own Space	$69,029	$27,275
$27,163

Total Cost

Landlords	$26,062	$14,365	$14,306

Contractors Performing Work in COFs Renting Space	$169,257	$65,031
$64,764

Contractors Performing Work in COFs that Own Space	$654,053	$258,430
$257,371

Total, All Events	$849,372	$337,827	$336,442

Sources:   Supplemental Economic Analysis (EPA 2007); EPA ICR No.
1669.04 (2003) Lead-Based Paint Pre-Renovation Information Dissemination
- TSCA Sec. 406(b); U.S. Bureau of Labor Statistics Occupational
Employment Statistics Series (2005); Kinko’s, Personal Communication.
February 21, 2007.



6(c)	Estimating Agency Cost

There are also government costs to administer the program.  States,
Tribes, and Territories are allowed, but are under no obligation, to
apply for and receive authorization to administer these proposed
requirements.  EPA will directly administer programs for States, Tribes,
and Territories that do not become authorized.  Because the number of
States, Tribes, and Territories that will become authorized is not
known, administrative costs are estimated assuming that EPA will
administer the program everywhere.  To the extent that other government
entities become authorized, EPA’s administrative costs will be lower. 
States, Tribes, and Territories that choose to implement the rule
themselves are expected to incur similar costs on a per-unit basis.

Under the preferred regulatory option, EPA will perform three tasks as
part of administering the RRP program: accredit training providers,
certify firms and process training provider notifications.  To reduce
the burden on the regulated community, EPA’s preferred option does not
include formal certification for renovators or dust sampling
technicians.  

Accreditation and certification cost estimates are based on responses
from nine states to a phone survey conducted in support of the TSCA
section 402(a)(3) “Fees Rule.” Data were collected from California,
Illinois, Maine, Massachusetts, New Hampshire, Ohio, Rhode Island,
Vermont, and Virginia.  States were asked to provide the number of hours
per applicant required to perform a variety of administrative tasks
under the broader TSCA section 402(a) lead abatement training and
certification regulation.  While TSCA section 402(a) defines training
and certification requirements for five different categories of lead
abatement professionals, the type of administrative activities
associated with the TSCA section 402(a) rule are similar to those
expected for the Renovation, Repair and Painting Rule. 

The nine states provided information on the hours required to perform
the following administrative activities:

Application Processing and Recordkeeping

Fee Transactions and Waivers;

Issuance of Accreditation/Certification Papers;

Public Assistance/Outreach;

Reporting;

Management; and

Auditing Training Courses for Training Provider Accreditation Only.

These data were used to estimate the costs of accrediting training
providers and certifying firms.  In each case, the amount of time
necessary to implement the rule was calculated as the simple average of
the hours reported by the nine states surveyed for the section 402(a)
rule.  Hours are reported for three categories of workers:  clerical,
technical, and managerial.  These hourly burden estimates were
multiplied by wage rates for each job category to determine the
per-entity cost of administering the rule.  

Wage rates for administrative staff vary from region to region.  EPA
used the Office of Personnel Management’s General Salary Table 2005-GS
to estimate government employee wage rates.  The labor rates used were: 
$49.44 per hour for managerial staff (GS-13, Step 1), $34.69 per hour
for technical staff (GS 11, Step 1), and $21.09 per hour for clerical
staff (GS-6, Step 1).  These wage rates were multiplied by the hourly
time estimates to derive total unit costs for accreditation and
certification.

Agency Cost of Accrediting Training Providers and Processing Training
Notifications

The task of accrediting training providers includes approving curricula
and quality assurance/quality control (QA/QC) programs for instructors,
and maintaining a database of accredited training providers.  The
Renovation, Repair and Painting Rule requires that renovators receive
formal training on lead-safe work practices from an accredited training
provider.  In addition, renovators are required to take a refresher
course once every three years.  EPA, in turn, must accredit training
courses by reviewing the curriculum and ensuring that training providers
have acceptable quality assurance/quality control (QA/QC) procedures in
place to ensure quality instruction by every instructor.  EPA will
review and document all applications for accreditation, audit training
courses, process fees and fee waivers, issue accreditation papers,
perform public outreach and assistance, report to overseeing agencies or
legislatures, and perform other general program management activities
(i.e., budgeting).  In addition, EPA will process notifications
submitted by training providers prior to and following each course
session.

Data on the time required to perform training accreditation activities
were available from eight of nine states.  The time required to
administer the TSCA section 402(a) program varies widely by state.  In
particular, the amount of time spent auditing training courses differs
substantially among respondents.  EPA used the simple average of time
estimates for all eight responding states to determine the time required
to process a single application in a typical state.  EPA then adjusted
the number of hours spent on auditing training courses to account for
the fact that the Renovator course is shorter than the majority of
initial abatement training courses.  EPA estimates 12 FTE hours will be
spent on auditing each training course.  

The average time spent performing each of the seven administrative
activities associated with accrediting training courses is shown in  
REF _Ref159301933 \h  \* MERGEFORMAT  Exhibit 6.15 .  Notification
processing time is assumed to be included in the Reporting hours
estimate.  It is assumed that the Agency will spend two minutes per
training provider notification on processing.  It is also assumed that
the Agency will spend some portion of management time processing
notifications.  The total unit cost of processing notifications is $24
based on these estimates and the above labor rates.  

Agency reporting and management costs will apply to all training
providers in each year, regardless of whether or not it is an
accreditation year.  As shown in   REF _Ref159298080 \h  Exhibit 6.1 ,
there will be no training providers accredited in any year as a result
of the supplemental proposal to include additional child-occupied
facilities (because all of the necessary training providers became
accredited as a result of the 2006 proposal).  As shown in   REF
_Ref159302141 \h  \* MERGEFORMAT  Exhibit 6.16 , it will cost EPA $2,353
to process training provider notifications in the first year of the
proposed rule as a result of the supplemental proposal including
child-occupied facilities.  Agency notification processing costs will be
$3,953 in Years 2 and 3.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  15  Agency Cost Per Unit for
Accrediting Training Providers





	

 Clerical Hrs.

(GS-6, Step 1)	

Technical Hrs.     (GS-11, Step 1)	

Managerial Hrs.  (GS-13, Step 1)	

Unit Cost

Application Processing and Recordkeeping	1.94	17.3	0	$641

Auditing Training Courses	0	12	0	$416

Fee Transactions and Waivers	0.24	0	0	$5

Issuance of Accreditation Documents	0.79	0	0	$17

Public Assistance/Outreach	0	5.79	0	$201

Reporting	0	2.16	0	$75

Other Management	0	0	8.93	$441

Total 	2.97	37.25	8.93	$1,796

Portion of Cost Associated with Processing Training Provider
Notifications

Reporting	0	0.51	0	$18

Other Management	0	0	0.12	$6

Total	0	0.51	0.12	$24

Note(s): numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.

Sources:  Supplemental Economic Analysis (EPA 2007); EPA ICR No.
1715.07; and U.S. OPM 2005.







Exhibit 6.  SEQ Exhibit_6. \* ARABIC  16   Total EPA Cost of Accrediting
Training Providers- 2005 Dollars





	

Year 1	

Year 2	

Year 3

Application Processing and Recordkeeping*	$0	$0	$0

Auditing Training Courses*	$0	$0	$0

Fee Transactions and Waivers*	$0	$0	$0

Issuance of Accreditation Documents*	$0	$0	$0

Public Assistance/Outreach*	$0	$0	$0

Reporting	$1,754	$2,946	$2,946

Other Management	$599	$1,007	$1,007

Total 	$2,353	$3,953	$3,953

* There are no incremental EPA costs estimated for these activities as a
result of the supplemental proposal.  Costs for these activities
resulting from the RRP program were already accounted for in EPA ICR No.
1715.07.

Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.

Sources: Supplemental Economic Analysis (EPA 2007); EPA ICR No. 1715.07;
and U.S. OPM 2005.



Agency Costs of Certifying Renovation Firms

The Renovation, Repair and Painting Rule will require renovation
establishments to submit a completed application and fee.  For the
purpose of estimating costs, it is assumed that EPA will review the
certification statement for completeness, review the firm’s
environmental compliance history, record the establishment’s
information in a database, and mail a certification form to the
establishment. 

Data on the time required to perform establishment certification
activities were available from six of nine states.  The states of
California, New Hampshire, and Ohio did not provide any information on
the cost of certifying establishments under TSCA §402(a).  The time
required to administer the section 402(a) program is reasonably
consistent among states.  The simple average of the six states’ data
was used to determine the time required to certify an establishment in a
typical state.

  REF _Ref159302281 \h  \* MERGEFORMAT  Exhibit 6.17  provides the
average time spent performing six administrative activities associated
with certifying establishments.  The total unit cost of certifying
establishments is $318 based on these estimates and the above labor
rates. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  17   Per Unit Costs of Certifying
Renovation Establishments





	

Clerical       (GS-6, Step 1)	

Technical     (GS-11, Step 1)	

Managerial  (GS-13, Step 1)	

Unit Cost*

Application Processing and Recordkeeping	0.21	1.49	0	$56

Fee Transactions and Waivers	0.16	0	0	$3

Issuance of Accreditation Documents	0.12	0	0	$3

Public Assistance/Outreach	0	1.66	0	$58

Reporting	0	1.58	0	$55

Other Management	0	0	2.9	$143

Total 	0.49	4.73	2.9	$318

Note(s): numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.

Sources:  Supplemental Economic Analysis (EPA 2007); EPA ICR No.
1715.07; and U.S. OPM 2005.



As described earlier in   REF _Ref159299188 \h  \* MERGEFORMAT  Exhibit
6.4 , it is estimated that, as a result of the supplemental proposal,
24,381 additional firms would become certified in Year 1.  In Year 2,
28,482 firms are expected to seek certification or re-certification, and
in Year 3 14,828 firms are expected to be certified or re-certified.  As
shown in   REF _Ref159302374 \h  \* MERGEFORMAT  Exhibit 6.18 , based on
these estimates, it will cost EPA $7.8 million to certify these firms in
Year 1.  EPA’s costs for firm certifications attributable to
renovations in child-occupied facilities are estimated to be $9.1
million in Year 2 and $4.7 million in Year 3.    

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  18   Total Costs of Certifying
Renovation Establishments 



	

Year 1	

Year 2	

Year 3

Contractors Working in Target Housing COFs (See Notes)

Application Processing and Recordkeeping	$78,512	$92,689	$48,074

Fee Transactions and Waivers	$4,206	$4,965	$2,575

Issuance of Accreditation Documents	$4,206	$4,965	$2,575

Public Assistance/Outreach	$81,316	$96,000	$49,791

Reporting	$77,110	$91,034	$47,216

Other Management	$200,486	$236,689	$122,761

Total 	$445,836	$526,343	$272,992

Entities Working in Commercial or Public Building COFs (See Notes)

Application Processing and Recordkeeping	$1,286,838 	$1,502,329 
$782,347 

Fee Transactions and Waivers	$68,938 	$80,482 	$41,911 

Issuance of Accreditation Documents	$68,938 	$80,482 	$41,911 

Public Assistance/Outreach	$1,332,797 	$1,555,984 	$810,288 

Reporting	$1,263,859 	$1,475,502 	$768,377 

Other Management	$3,286,033 	$3,836,305 	$1,997,779 

Total 	$7,307,402 	$8,531,083 	$4,442,614 



Total Cost of Certifying Renovation Establishments

Application Processing and Recordkeeping	$1,365,350 	$1,595,018 
$830,421 

Fee Transactions and Waivers	$73,144 	$85,447 	$44,486 

Issuance of Accreditation Documents	$73,144 	$85,447 	$44,486 

Public Assistance/Outreach	$1,414,113 	$1,651,984 	$860,079 

Reporting	$1,340,969 	$1,566,536 	$815,593 

Other Management	$3,486,519 	$4,072,994 	$2,120,540 

Total 	$7,753,238 	$9,057,426 	$4,715,606 

Note(s): Numbers may not calculate due to rounding.    Burden is
incremental to EPA ICR No. 1715.07.  Contractors working in target
housing COFs include only contractors working in owner-occupied units
without a child under the age of 6.  Entities working in commercial or
public building COFs include contractors and landlords, as well as
schools and daycare centers that conduct work in-house.  

Sources:  Supplemental Economic Analysis (EPA 2007); EPA ICR No.
1715.07; U.S. OPM 2005.



6(d)	Bottom Line Burden Hours and Cost

The number of respondents attributable to renovations in child-occupied
facilities is shown in   REF _Ref159303131 \h  Exhibit 6.19 , and the
number of responses in   REF _Ref159303145 \h  \* MERGEFORMAT  Exhibit
6.20 .  The respondent burden for the collection of notification
information is shown in   REF _Ref159303172 \h  \* MERGEFORMAT  Exhibit
6.21 .  The average annual respondent burden over the first three years
is estimated to be 281,200 hours.  The average annual respondent cost
for the collection of notification information is shown in   REF
_Ref159303269 \h  Exhibit 6.22 , and is estimated to be $8.9 million. 
The Agency cost is estimated to average $7.2 million per year, as shown
in   REF _Ref159303280 \h  \* MERGEFORMAT  Exhibit 6.23 .  These are all
incremental to the burdens and costs in EPA ICR No. 1715.07.	

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  19   Number of Respondents









	

Year 1	

Year 2	

Year 3	

Average

Training Providers	100	168	168	145

Firms – Target Housing COF Contractorsa	1,402	2,586	2,575	2,188

Firms - Entities Working in Commercial or Public Building COFsb 	22,979
42,084	41,911	35,658

COF Rule Total	24,481	44,838	44,655	37,991

Contractors working in target housing COFs include only contractors
working in owner-occupied units without a child under the age of 6.  

Entities working in commercial or public building COFs include
contractors and landlords, as well as schools and daycare centers that
perform work in-house.



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  20   Number of Responses









	

Year 1	

Year 2	

Year 3	

Average

Training Provider Initial Accreditation	0	0	0	0

Training Provider Initial Re-Accreditation	0	0	0	0

Training Provider Notification	2,205	2,593	1,347	2,048

Firm Initial Certification – Target Housing COF Contractorsa	1,402
1,441	464	1,102

Firm Initial Certification – Entities Working in Commercial or Public
Building COFs b	22,979	23,318	7,544	17,947

Firm Re-Certification – Target Housing COF Contractorsaa	0	214	395	203

Firm Re-Certification – Entities Working in Commercial or Public
Building COFs b	0	3,509	6,426	3,312

COF Rule Total	26,586	31,075	16,176	24,612

 Contractors working in target housing COFs include only contractors
working in owner-occupied units without a child under the age of 6.  

Entities working in commercial or public building COFs include
contractors and landlords, as well as schools and daycare centers that
perform work in-house.





Exhibit 6.  SEQ Exhibit_6. \* ARABIC  21   Respondent Burden Hours









	

Year 1	

Year 2	

Year 3	

Average

Training Providers	1,798	2,115	1,098	1,670

Firms – Target Housing COF Contractorsa	12,197	18,598	15,212	15,336

Firms - Entities Working in Commercial or Public Building COFsb	223,832
311,718	257,030	264,193

COF Rule Total	237,828	332,430	273,341	281,200

Contractors working in target housing COFs include only contractors
working in owner-occupied units without a child under the age of 6.  

Entities working in commercial or public building COFs include
contractors and landlords, as well as schools and daycare centers that
perform work in-house.





Exhibit 6.  SEQ Exhibit_6. \* ARABIC  22   Respondent Cost









	

Year 1	

Year 2	

Year 3	

Average

Training Providers	$43,364	$51,003	$26,489	$40,285

Firms – Target Housing COF Contractorsa	$386,697	$589,351	$481,780
$485,943

Firms - Entities Working in Commercial or Public Building COFs b
$7,187,463	$9,914,355	$8,176,828	$8,426,215

COF Rule Total	$7,617,524	$10,554,709	$8,685,097	$8,952,443

 Contractors working in target housing COFs include only contractors
working in owner-occupied units without a child under the age of 6.  

Entities working in commercial or public building COFs include
contractors and landlords, as well as schools and daycare centers that
perform work in-house.





Exhibit 6.  SEQ Exhibit_6. \* ARABIC  23   Agency Cost









	

Year 1	

Year 2	

Year 3	

Average



EPA	$7,755,590	$9,061,378	$4,719,558	$7,178,842



The total burden in OMB’s inventory for the previous version of this
ICR (EPA ICR No. 1715.06) is 440,813 hours.  With the addition of the
1,259,418 hours in the first ICR addendum (EPA ICR No. 1715.07) and the
281,200 hours in this second ICR addendum (EPA ICR No. 1715.08), the
total burden requested for this ICR will be 1,540,618 hours.

6(e)  Reasons For Changes in Burden

This amendment would increase the average annual burden by 281,200
hours.  This change is due to a supplemental notice of proposed
rulemaking to add child-occupied facilities to the Lead Renovation,
Repair, and Painting rule, which represents a program change. 

6(f) Burden Statement

The incremental public burden for this collection of information, which
is approved under OMB Control No. 2070-0155, is estimated to average
approximately 12 hours per year for training providers.  For firms
engaged in regulated renovation, repair, and painting activities, the
average incremental burden is estimated to be about 7 hours per year. 
According to the Paperwork Reduction Act, “burden” means the total
time, effort, or financial resources expended by persons to generate,
maintain, retain, or disclose or provide information to or for a federal
agency.  For this collection it includes the time needed to review
instructions; develop, acquire, install and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.  An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. 
The OMB control number for this information collection appears above. 
In addition, the OMB control numbers for EPA’s regulation, after
initial display in the final rule, are listed in 40 CFR part 9.

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.
EPA-HQ-2005-0049, which is available for public viewing at the OPPT
Docket in the EPA Docket Center (EPA/DC), Room 3334, EPA West Building,
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 OPPT Docket is (202)
566-0280.  An electronic version of the public docket is available
through the Federal eRegulations Portal at www.regulations.gov.  Use
www.regulations.gov 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. EPA-HQ-2005-0049 in any
correspondence. 

ATTACHMENTS TO THE SUPPORTING STATEMENT

All attachments are available as documents in the electronic docket for
this ICR at   HYPERLINK "http://www.Regulations.gov" 
www.Regulations.gov  in Docket ID No. EPA-HQ-OPPT-2005-0049.

												

Attachment 1		Toxic Substances Control Act (TSCA), Sections 402 and 404
(15 				USC 2682, 2684)

Attachment 2		Proposed Rule: Lead; Renovation, Repair, and Painting
Program

Attachment 3 		Application and Instructions for Training Providers -
Applying for Accreditation of Lead-Based Paint Activity Training
Programs - EPA Form 8500-25

Attachment 4 		Application and Instructions for Firms- Applying for
Certification to Conduct Lead-Based Paint Activities - EPA Form 8500-27

Attachment 5		Sample Form – Lead-Based Paint Activities Training
Notification- (Pre-Training)

Attachment 6		Sample Form – Lead-Based Paint Activities Post Training
Notification  

	

Attachment 7		Sample Form - Optional Recordkeeping Checklist for Firms

Attachment 8		Sample Form – Pre-Renovation Form 

  SEQ CHAPTER \h \r 1 EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 1

Toxic Substances Control Act Sections 402 and 404

15 U.S.C. 2682, 2684

Sec. 2682. Lead-based paint activities training and certification

     (a) Regulations

(1) In general 

Not later than 18 months after October 28, 1992, the Administrator
shall, in consultation with the Secretary of Labor, the Secretary of
Housing and Urban Development, and the Secretary of Health and Human
Services (acting through the Director of the National Institute for
Occupational Safety and Health), promulgate final regulations governing
lead-based paint activities to ensure that individuals engaged in such
activities are properly trained; that training programs are accredited;
and that contractors engaged in such activities are certified. Such
regulations shall contain standards for performing lead-based paint
activities, taking into account reliability, effectiveness, and safety.
Such regulations shall require that all risk assessment, inspection, and
abatement activities performed in target housing shall be performed by
certified contractors, as such term is defined in section 4851b of title
42. The provisions of this section shall supersede the provisions set
forth under the heading ‘’Lead Abatement Training and
Certification’‘ and under the heading ‘’Training Grants’‘ in
title III of the Act entitled ‘’An Act making appropriations for the
Departments of Veterans Affairs and Housing and Urban Development, and
for sundry independent agencies, commissions, corporations, and offices
for the fiscal year ending September 30, 1992, and for other
purposes’‘, Public Law 102-139 (105 Stat. 765, 42 U.S.C. 4822 note),
and upon October 28, 1992, the provisions set forth in such public law
under such headings shall cease to have any force and effect. 

	(2) Accreditation of training programs 

Final regulations promulgated under paragraph (1) shall contain specific
requirements for the accreditation of lead-based paint activities
training programs for workers, supervisors, inspectors and planners, and
other individuals involved in lead-based paint activities, including,
but not limited to, each of the following: 

               (A) Minimum requirements for the accreditation of
training providers. 

               (B) Minimum training curriculum requirements. 

               (C) Minimum training hour requirements. 

               (D) Minimum hands-on training requirements. 

               (E) Minimum trainee competency and proficiency
requirements. 

               (F) Minimum requirements for training program quality
control.

	(3) Accreditation and certification fees 

The Administrator (or the State in the case of an authorized State
program) shall impose a fee on - 

               (A) persons operating training programs accredited under
this subchapter; and 

               (B) lead-based paint activities contractors certified in
accordance with paragraph (1). 

The fees shall be established at such level as is necessary to cover the
costs of administering and enforcing the standards and regulations under
this section which are applicable to such programs and contractors. The
fee shall not be imposed on any State, local government, or nonprofit
training program. The Administrator (or the State in the case of an
authorized State program) may waive the fee for lead-based paint
activities contractors under subparagraph (A) for the purpose of
training their own employees.

     (b) Lead-based paint activities 

For purposes of this subchapter, the term ‘’lead-based paint
activities’‘ means - 

(1) in the case of target housing, risk assessment, inspection,  and
abatement; and 

(2) in the case of any public building constructed before 1978,
commercial building, bridge, or other structure or superstructure,
identification of lead-based paint and materials containing lead-based
paint, deleading, removal of lead from bridges, and demolition. For
purposes of paragraph (2), the term ‘’deleading’‘ means
activities conducted by a person who offers to eliminate lead-based
paint or lead-based paint hazards or to plan such activities. 

     (c) Renovation and remodeling 

	(1) Guidelines 

In order to reduce the risk of exposure to lead in connection with
renovation and remodeling of target housing, public buildings
constructed before 1978, and commercial buildings, the Administrator
shall, within 18 months after October 28, 1992, promulgate guidelines
for the conduct of such renovation and remodeling activities which may
create a risk of exposure to dangerous levels of lead. The Administrator
shall disseminate such guidelines to persons engaged in such renovation
and remodeling through hardware and paint stores, employee
organizations, trade groups, State and local agencies, and through other
appropriate means. 

(2) Study of certification 

The Administrator shall conduct a study of the extent to which persons
engaged in various types of renovation and remodeling activities in
target housing, public buildings constructed before 1978, and commercial
buildings are exposed to lead in the conduct of such activities or
disturb lead and create a lead-based paint hazard on a regular or
occasional basis. The Administrator shall complete such study and
publish the results thereof within 30 months after October 28, 1992. 

	(3) Certification determination 

Within 4 years after October 28, 1992, the Administrator shall revise
the regulations under subsection (a) of this section to apply the
regulations to renovation or remodeling activities in target housing,
public buildings constructed before 1978, and commercial buildings that
create lead-based paint hazards. In determining which contractors are
engaged in such activities, the Administrator shall utilize the results
of the study under paragraph (2) and consult with the representatives of
labor organizations, lead-based paint activities contractors, persons
engaged in remodeling and renovation, experts in lead health effects,
and others. If the Administrator determines that any category of
contractors engaged in renovation or remodeling does not require
certification, the Administrator shall publish an explanation of the
basis for that determination. 

Sec. 2684. Authorized State programs 

	(a) Approval 

Any State which seeks to administer and enforce the standards,
regulations, or other requirements established under section 2682 or
2686 of this title, or both, may, after notice and opportunity for
public hearing, develop and submit to the Administrator an application,
in such form as the Administrator shall require, for authorization of
such a State program. Any such State may also certify to the
Administrator at the time of submitting such program that the State
program meets the requirements of paragraphs (1) and (2) of subsection
(b) of this section. Upon submission of such certification, the State
program shall be deemed to be authorized under this section, and shall
apply in such State in lieu of the corresponding Federal program under
section 2682 or 2686 of this title, or both, as the case may be, until
such time as the Administrator disapproves the program or withdraws the
authorization. 

	(b) Approval or disapproval 

Within 180 days following submission of an application under subsection
(a) of this section, the Administrator shall approve or disapprove the
application. The Administrator may approve the application only if,
after notice and after opportunity for public hearing, the Administrator
finds that - 

(1) the State program is at least as protective of human health and the
environment as the Federal program under section 2682 or 2686 of this
title, or both, as the case may be, and 

(2) such State program provides adequate enforcement. Upon authorization
of a State program under this section, it shall be unlawful for any
person to violate or fail or refuse to comply with any requirement of
such program. 

	(c) Withdrawal of authorization 

If a State is not administering and enforcing a program authorized under
this section in compliance with standards, regulations, and other
requirements of this subchapter, the Administrator shall so notify the
State and, if corrective action is not completed within a reasonable
time, not to exceed 180 days, the Administrator shall withdraw
authorization of such program and establish a Federal program pursuant
to this subchapter. 

	(d) Model State program 

Within 18 months after October 28, 1992, the Administrator shall
promulgate a model State program which may be adopted by any State which
seeks to administer and enforce a State program under this subchapter.
Such model program shall, to the extent practicable, encourage States to
utilize existing State and local certification and accreditation
programs and procedures. Such program shall encourage reciprocity among
the States with respect to the certification under section 2682 of this
title. 

	(e) Other State requirements 

Nothing in this subchapter shall be construed to prohibit any State or
political subdivision thereof from imposing any requirements which are
more stringent than those imposed by this subchapter. 

	(f) State and local certification 

The regulations under this subchapter shall, to the extent appropriate,
encourage States to seek program authorization and to use existing State
and local certification and accreditation procedures, except that a
State or local government shall not require more than 1 certification
under this section for any lead-based paint activities contractor to
carry out lead-based paint activities in the State or political
subdivision thereof. 

	(g) Grants to States 

The Administrator is authorized to make grants to States to develop and
carry out authorized State programs under this section. The grants shall
be subject to such terms and conditions as the Administrator may
establish to further the purposes of this subchapter. 

(h) Enforcement by Administrator 

If a State does not have a State program authorized under this section
and in effect by the date which is 2 years after promulgation of the
regulations under section 2682 or 2686 of this title, the Administrator
shall, by such date, establish a Federal program for section 2682 or
2686 of this title (as the case may be) for such State and administer
and enforce such program in such State.

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 2

Supplemental Proposed Rule: Lead; Renovation, Repair, and Painting
Program

  SEQ CHAPTER \h \r 1  This attachment is available as a document in the
electronic docket for this ICR at   HYPERLINK "www.Regulations.gov" 
www.Regulations.gov  (EPA-HQ-OPPT-2005-0049).

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 3

Application and Instructions for Training Providers- Applying for
Accreditation of Lead-Based Paint Activity Training Programs - EPA Form
8500-25

For an electronic copy of the Training Provider Application Form and
Instructions, go to http://www.epa.gov/lead/pubs/trainapp.pdf.

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 4

  SEQ CHAPTER \h \r 1 Application and Instructions for Firms- Applying
for Certification to Conduct Lead-Based Paint Activities - EPA Form
8500-27

For an electronic copy of the Firm Application Form and Instructions, go
to http://www.epa.gov/lead/pubs/firmapp.pdf.

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 5

  SEQ CHAPTER \h \r 1 Sample Form - Lead-Based Paint Activities Training
Notification- (Pre-Training)

For an electronic copy of the Training Notification Sample Form, go to
http://www.epa.gov/lead/pubs/form2-pre-training.pdf.

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 6

  SEQ CHAPTER \h \r 1 Sample Form - Lead-Based Paint Activities Post
Training Notification

For an electronic copy of the Training Notification Sample Form, go to
http://www.epa.gov/lead/pubs/form3-post-training.pdf.

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 7

  SEQ CHAPTER \h \r 1 Optional Recordkeeping Checklist for Firms

  SEQ CHAPTER \h \r 1 Draft optional Recordkeeping Checklist for Firms:

Name of
Firm:________________________________________________________________

Date and Location of
Renovation:_________________________________________________

Name of Assigned
Renovator:____________________________________________________

Copies of renovator qualifications (training certificates,
certifications) on file.  

Name of Dust Sampling Technician, Inspector, or Risk Assessor, if
used:_________________

________________________________________________________________________

Copies of sampling personnel qualifications (training certificates,
certifications) on file. 

Name(s) of Trained
Workers:____________________________________________________

________________________________________________________________________
____

Description of Tasks Performed by Trained
Workers:_________________________________

________________________________________________________________________
____

Description of Training Provided to Workers by
Renovator:____________________________

________________________________________________________________________

Warning signs posted.  

Description of work area and containment practices
used:______________________________

________________________________________________________________________
____

________________________________________________________________________
____

Description of how waste was
handled:_____________________________________________

________________________________________________________________________
____

Description of how walls, floors, and other surfaces and objects in the
work area were cleaned:

________________________________________________________________________
____

________________________________________________________________________
____

Description of post-renovation cleaning verification
process:____________________________

________________________________________________________________________
____

________________________________________________________________________
____

Description of dust clearance testing, if
performed:___________________________________

________________________________________________________________________
____

________________________________________________________________________
____

________________________________________________________________________
____ 

I certify under penalty of law that the above information is true and
complete.

____________________________________________		______________________

			name							date

____________________________________________

			title

EPA ICR No. 1715.08; OMB Control No. 2070-0155

ATTACHMENT 8

  SEQ CHAPTER \h \r 1 Sample Form – Pre-Renovation Form

For an electronic copy of the Pre-Renovation Sample Form, go to  
HYPERLINK "http://www.epa.gov/lead/pubs/pre-renovationform.pdf_" 
http://www.epa.gov/lead/pubs/pre-renovationform.pdf 

									

 Entities performing renovation, repair, and painting activities may
include contractors, COF operators (schools, daycare centers, etc.), and
landlords in public or commercial buildings that rent space to COFs. 

 The proposed rule allows for the training and use of a sampling
technician to perform dust clearance testing following a renovation
instead of performing cleaning verification.  Because dust clearance
testing is substantially more expensive than the cleaning verification,
EPA expects few buildings to have dust clearance testing performed. 
Since the frequency of dust clearance testing is expected to be low, and
therefore not to have a significant cost impact, this analysis assumes
that cleaning verification is always performed instead of dust clearance
testing.

 Burden and cost tables for training provider accreditation are included
solely for consistency with the supporting statement for EPA ICR No.
1715.07. 

 RRP firms may include contractors, COF operators (schools, daycare
centers, etc.), and landlords in public or commercial buildings that
rent space to COFs. 

As discussed in detail in Appendix 4A of the Supplemental Economic
Analysis (EPA 2007), public schools, private schools with more than 100
students, landlords that rent space to daycare centers in commercial or
public buildings, and daycare centers in religious or other non-profit
establishments are expected to perform all of their own painting and
window/door projects, as well as one unscheduled maintenance event per
building every two years.   Contractors are expected to perform all
electric and plumbing/HVAC, as well as all remaining unscheduled
maintenance projects in these COFs.  Furthermore, contractors are
expected to perform all RRP projects in private schools with less than
100 students, and in daycare centers that own their buildings.

U.S. Bureau of Labor Statistics.  2005.  Occupational Employment
Statistics Series.

Firm Wage Rates were Inflated from 2004 US dollars to 2005 US dollars
the BLS Employment Cost Index for the Construction Industry.

 No additional training providers are expected to seek accreditation due
to the COF rule, so there is no incremental cost for accreditation. 
Burden and cost tables for training provider accreditation are included
here solely for consistency with the supporting statement for EPA ICR
No. 1715.07.

These wage rates are fully loaded, and were calculated using the
standard government multiplier of 1.6 to cover overhead and fringe
benefits.

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