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:  ICR Amendment for Rulemaking entitled “Lead; Elimination of
the Opt-out Provision and Other Amendments to the Renovation, Repair,
and Painting Program; Final Rule”

	ICR No.  EPA ICR No. 1715.12; OMB 2070-0155

	1(b)  Short Characterization/Abstract

  SEQ CHAPTER \h \r 1 	The following information collection request
(ICR) addendum covers revisions to the 2008 renovation, repair, and
painting (RRP) rule which established reporting and recordkeeping
requirements for individuals and firms conducting renovations in target
housing, which is most housing constructed before 1978, and
child-occupied facilities, which are pre-1978 residential, public, or
commercial buildings where children under 6 are regularly present.  EPA
is revising the 2008 RRP final rule under the authority of Sections 402
and 407 of the Toxic Substances Control Act (TSCA).  This ICR addendum
revises the existing approved ICR to incorporate reporting and
recordkeeping requirements in a rule expected to be published in the
Federal Register on April 28, 2010. 

	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. 


	Like the regulations under Section 402(a) of TSCA, the regulations
pertaining to renovation projects under Section 402(c)(3) of TSCA
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).  Of these entities, the rule only affects firms and
training providers.  Accordingly, this document does not address the
record keeping or reporting requirements for States. The following
sections provide a general overview of the reporting and recordkeeping
requirements for firms and training providers, 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 must obtain certification
from EPA/States.  This includes firms consisting only of one
self-employed individual.  To receive certification, a firm must 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 must re-certify every five years. 
The rule also requires firms to 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 requires 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.  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.  Renovation firms must also either
(i) provide the lead hazard information pamphlet and general information
on the renovation to parents or guardians of children under age 6 using
the facility, or (ii) erect signs that provide general information on
the renovation accompanied by the pamphlet or information on how to
obtain a copy of it.  (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
EPA ICR No. 1669, Lead-Based Paint Pre-Renovation Information
Dissemination – TSCA Sec. 406(b), and is approved under OMB Control
No. 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.  Under the rule,
firms would be required to provide information regarding compliance with
the 2008 RRP rule to owners and occupants of target housing and
child-occupied facilities.  

Training providers.  Training programs seeking to offer training for
renovators or dust sampling technicians must obtain EPA/State
accreditation.  In order for EPA/States to have the information
necessary to evaluate and accredit the training programs, training
providers must prepare and submit application packages.  Training
programs also must certain records related to their students and
training personnel qualifications.  Training programs are required to
notify the Agency 1) prior to providing training courses, and 2)
following completion of training courses.  Training programs must 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.

  SEQ CHAPTER \h \r 1 

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

	The Agency’s 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

	Owners and Occupants of Target Housing and Child-occupied Facilities

	The rule will require renovation firms to provide training and work
practice information to the owners and occupants of target housing and
child-occupied facilities in a short, easily-read checklist or other
form.  This third-party notification will serve to reinforce the
information provided by the lead hazard information pamphlet that
renovation firms provide to these persons before beginning renovations
covered by this rule.  By addressing the significant training and work
practice provisions of the RRP rule, this information will enable
building owners and occupants to better understand what the renovation
firm did to comply with the rule and how the rule’s provisions
affected their specific renovation.  Educating the owners and occupants
in this way is likely to improve their ability to assist the EPA in
monitoring compliance with the RRP rule.

	EPA

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

	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 rule
provides flexibility for individuals conducting renovations, by relying
on guidance and training to help renovators determine the best
approaches to minimizing exposure to lead-based paint hazards 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 have to compile and retain are necessary
as a reference for building owners/occupants, EPA or authorized
entities.  The records demonstrate that individuals conducting the
activities do so in a safe and effective manner, according to the
minimum work practice standards established by the rule.  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
402/404/406/407  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 notice of final rulemaking served as the
public notice for this ICR addendum.  Interested parties submitted
comments.  Responses were taken into account in developing the final
rulemaking.

	3(c)  Consultations 

  SEQ CHAPTER \h \r 1 	During the development of the 2008 RRP rule, the
Agency 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 RRP proposal and the preamble to the
supplemental notice.  Summaries and transcripts of meetings with
stakeholders can be found in the rulemaking docket
(EPA-HQ-OPPT-2005-0049).

	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 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 specific
documentation.

	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 and training providers to maintain records for three and
one-half years.

	3(f)  Confidentiality

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

	3(g)  Sensitive Questions

	  SEQ CHAPTER \h \r 1 Neither the existing regulations nor the rule
amendments address questions of a sensitive nature.4.	The Respondents
and the Information Requested

	4(a)  Respondents/NAICS Codes

  SEQ CHAPTER \h \r 1 	Respondents for the reporting, third-party
notification and recordkeeping requirements of this rule include: 1)
firms and individuals engaged in residential renovations, 2) firms and
individuals engaged in renovations in child-occupied facilities, and 3)
training programs providing training services in lead-based paint
activities and renovations.  The North American Industrial
Classification System (NAICS) codes associated with industries most
likely affected by the paperwork requirements covered in the existing
ICR and this 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 renovation regulations specify
reporting and record keeping for training providers and
individuals/firms undertaking renovation activities.  The rule is
expected to increase the number of firms and renovators expected to seek
certification and training.

	(i)  Data Items

	Training Providers

  SEQ CHAPTER \h \r 1 	

To comply with the Renovation, Repair, and Painting rule, training
providers 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). 
Training providers must use  SEQ CHAPTER \h \r 1  either the sample form
entitled “Lead-Based Paint Activities and Renovation Training
Notification” or a similar form containing the required information. 
Training providers may provide electronic submissions using the
Agency’s secure, internet-based Central Data Exchange (CDX).  (The
paperwork activities, and related burden and costs, associated with CDX
user registration are described in another ICR that is currently
approved by OMB under OMB Control No. 2025-0003.) 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 Activities
and Renovation Post-Training Notification” 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

Digital photograph

Course completion certificate number

Student test score

Training manager’s name and signature

	In addition, for renovator and dust sampling technician courses, the
training course provider must take a digital photograph of each trainee
and submit it to EPA along with its training course follow-up
information.

	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

	The rule is expected to increase demand for certified firms, and
therefore more firms are expected to seek certification to conduct
renovation, repair and/or painting activities involving lead-based
paint.    SEQ CHAPTER \h \r 1 To obtain certification firms must submit
specific materials to EPA/State, using either the sample EPA Form
8500-27R entitled “Application for Firms to Conduct Renovations” 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 five years.

	Firms performing renovations in target housing and child-occupied
facilities in public or commercial buildings must provide lead hazard
information pamphlets to property owners and tenants or child-occupied
facility representatives.  Firms must also either (i) provide the
pamphlet and general information on the renovation to parents or
guardians of children under age 6 using the facility, or (ii) erect
signs that provide general information on the renovation accompanied by
the pamphlet or information on how to obtain a copy.  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.  Firms must also document their activities with respect to the
notification of parents and guardians of child-occupied facilities.  For
example, the firm could prepare a signed, dated description of the
notification activities performed in connection with a particular
renovation.

	In addition, firms conducting renovations are required to maintain
records demonstrating compliance with the final rule 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.  The rule will
require these firms to give owners and if different, the occupants a
checklist indicating that the firm complied with the rule requirements.

	(ii)  Respondent Activities

	  SEQ CHAPTER \h \r 1 The rule is expected to increase the number of
renovators that require training.  Training providers will perform the
following activities for the additional trainees that will seek
renovation training:

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.

	The rule is expected to increase the number firms seeking
certification.  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. 

The rule will also require all firms to complete the checklist and
provide it to the owner and if different, the occupant of the target
housing or child-occupied facility.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 rule:

Receive, review, and file initial, update, and course completion notices
and digital photographs of trainees 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 rule, 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 	EPA has attempted to ensure that its regulatory
requirements do not unduly burden small businesses.  As part of the
development process for the 2008 RRP rule, the Agency convened a Small
Business Advocacy Review Panel under the Regulatory Flexibility Act. 
More information on the Panel, and the Agency’s assessment of the
impacts on small businesses, can be found in the preamble to the 2008
RRP rule.  

	5(d)  Collection Schedule

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

Training programs submit notification of training to EPA;

Training programs submit post-training notification to EPA;

Firms may apply for certification at any time;

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

  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 revisions to the 2008 lead renovation, repair, and
painting program final rule (73 FR 21692), also known as the RRP or LRRP
rule.  This burden is incremental to the burden already accounted for in
the existing, approved ICR (EPA ICR No. 1715.10).  The estimates of the
number of entities subject to the rule’s requirements and the unit
burden and cost of the requirements were taken from the ICR supporting
statement Final Rule Addendum to an Existing EPA ICR Entitled: TSCA
Sections 402/404 Training and Certification, Accreditation, and
Standards for Lead-Based Paint Activities (EPA ICR No. 1715.10, OMB
2070-0155), the Economic Analysis for the TSCA Lead Renovation, Repair
and Painting Program, Final Rule for Target Housing and Child-Occupied
Facilities, also referred to as the Economic Analysis for the Final
Rule, and from the Economic Analysis for the TSCA Lead Renovation,
Repair and Painting Program Opt-Out and Recordkeeping Final Rule for
Target Housing and Child-Occupied Facilities (EPA 2008, 2010).  This
supporting statement provides burden and cost estimates for the first
three years of the program.  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.

The demand for certified firms and renovators is predicted to increase
as a result of the elimination of the opt-out provision, and therefore
more firms and renovators are predicted to seek certification and
training as a result of the revisions.  Separate impacts are estimated
for these firms and individuals that would not have otherwise sought
certification and training without the elimination of the opt-out
provision.  Hereafter these entities are referred to as “opt-out
entities.”  Likewise, those firms and individuals that would have
sought certification and training without the elimination of the opt-out
provision are referred to as “currently regulated entities.”  The
impacts of the revisions to the rule on the opt-out entities include all
the costs associated with the requirements of the revised LRRP rule.  In
contrast, the only impacts of the revisions on the currently regulated
entities are those associated with the recordkeeping requirement that
renovation firms provide owners and occupants with a copy of the records
demonstrating compliance with the training and work practice
requirements of the RRP rule.  This requirement is hereafter referred to
as the “recordkeeping checklist requirement”.

	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).  

It is assumed that enough training providers will become accredited
under the 2008 LRRP rule to cover the increased demand from RRP firms
seeking certification and training as a result of the elimination of the
opt-out provision.  Therefore, it is estimated that no new training
providers will become accredited as a result of the revisions.  However,
these training providers will have to offer more courses due to the
increased demand which will result in incremental notification costs.

	Under the rule, pre-course notification is required at least 7 business
days prior to the start of a lead-based paint activities course. 
Re-notification is required if the course date changes.  Within 10 days
of course completion, training providers are required to submit a
post-course notification. The following sections discuss how the
reporting and recordkeeping burden estimates in this analysis were
developed.    REF _Ref159313028 \h  \* MERGEFORMAT  Exhibit 6.1 
presents the estimation of Training Provider burden for course
notifications.

	This analysis assumes that training providers will complete a separate
notification form for each lead-based paint activity course conducted.
The number of pre-course and post-course notification events was
estimated by dividing the total number of students in a given year by an
estimated average class size of 25 students and the estimated number of
training providers.  (See the Economic Analysis of the 2008 LRRP rule
(EPA 2008) for details.)  The numbers of notification events were
rounded upwards to reflect the possibility that some courses will be
under subscribed.  There is one pre-notification 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 the FLPP database.  Re-notifications 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 are determined in the existing approved ICR.   

	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 the existing
approved ICR, and is estimated to be 0.01 hours per training event.

	Training providers are also required to take a digital photo of each
certified renovator upon initial and refresher training.  The estimated
time burden associated with taking and processing each photo is 3
minutes per photo (EPA 2008), or 1.25 hours per training course of 25
individuals.

	As presented below in   REF _Ref159298132 \h  \* MERGEFORMAT  Exhibit
6.2 , the burden for all training providers is estimated to be 15,127
hours in Year 1 of the regulation, 3,007 hours in Year 2, and 2,977
hours in Year 3.   (The burden drops 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 five years.)  The average annual aggregate burden
for training providers over the three years covered by this ICR is 7,037
hours.



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











Category	

Events per Training Provider	

Reporting

Hours/Event	

Recordkeeping

Hours/Event	

Total 

Hours/Event

	Year 1	Year 2	Year 3	Avg.



	

Pre-notification	30	6	6	14	0.15	0.01	0.16



Re-notification	4	1	1	2	0.15	0.01	0.16



Post-notification	30	6	6	14	1.54	0.01	1.55

Digital Photo	30	6	6	14	1.25	0.00	1.25



Annual Total	94	19	19	44













	Notification Burden Hours per Training Provider





	

Year 1	

Year 2	

Year 3	

	





90	18	18









	Training Providers per Year	





	

	

Year 1	

Year 2	

Year 3	

	





168	167	166











	Total Notification Burden Hours per Year	





Year 1	Year 2	Year 3





15,127 	3,007 	 2,977 





Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  2   Total Training Provider Burden







	Year 1	Year 2	Year 3	Average

Total Burden	15,127 	3,007 	 2,977 	7,037

Note(s): Numbers may not calculate due to rounding.   

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



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

Under the revisions to the renovation, repair, and painting (RRP) rule,
firms wishing to conduct renovations in opt-out housing would be
required to apply for certification.  They would also be required to
keep records reflecting RRP events conducted by trained employees.  This
ICR presents the costs to firms seeking certification as a result of the
elimination of the opt-out provision.  

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 five years.)  As shown in   REF
_Ref159299188 \h  \* MERGEFORMAT  Exhibit 6.3 , 111,426 firms are
estimated to become certified in the first year as a result of the rule.
 In the second year, 22,193 firms will become certified (19,974 initial
certifications and 2,219 re-certifications).  When combined with the
88,775 firms still operating that are already certified, this yields a
total of 110,968 certified firms.  In the third year, 22,103 firms will
become certified (19,893 initial certifications and 2,210
re-certifications).  When combined with the 88,411 firms still operating
that are already certified, this yields a total of 110,514 certified
firms.  The number of firms certified each year is calculated in the
Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA
2010).

Averaged across three years, there are an estimated 110,969 opt-out
entities operating annually, all of which are private firms.  Small
businesses comprise 110,672 of these firms.

Additionally, all RRP firms, regardless of whether they are applying for
certification in a given year, will spend time keeping records of RRP
work.  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 4.8
hours on recordkeeping per year.  This is based on a burden of 5 minutes
per response and an average of 58 responses per firm.  The number of
events per firm is estimated in the Economic Analysis for the Opt-Out
and Recordkeeping Final Rule (EPA 2010).

	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.  From the second
year on, this analysis makes the simplifying assumption that one fifth
of the number of firms certified in the first year seek initial- or
re-certification year (since re-certification is required every five
years).  The number of certifications is assumed to decline by 0.41
percent annually to reflect the decline in the pre-1978 housing stock

	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, 90 percent of firms
seeking certification are assumed to be seeking their initial
certification based on the relative annual average frequency of initial
certifications observed for abatement firms in FLPP database.

As presented below in   REF _Ref237420352 \h  \* MERGEFORMAT  Exhibit
6.4 , this amendment estimates the burden for all opt-out firms
conducting renovations in Year 1 to be 924,836 hours for all entities.
The burden is estimated to be 603,665 hours for all opt-out firms in
Year 2, and 601,198 hours in Year 3 (reflecting the decrease in the
number of opt-out firms needing certification, since re-certification is
only required every five years).  There is an annual average of 709,899
hours during the three year period covered by this ICR.  This yields an
average burden of 6.4 hours per year for opt-out RRP firms. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  3  Number of Certified Firms





	



	Year 1	Year 2	Year 3	Average

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

Receiving Initial Certification	111,426	19,974	19,893	50,431

Receiving  Re-Certification	0	2,219	2,210	1,476



Subtotal: Firms Receiving Certification or Re-Certification	111,426
22,193	22,103	51,907



Already Certified - Not Receiving Certification or Re-Certification	0
88,775	88,411	59,062



Total	111,426	110,968	110,514	110,969



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  4 : Average Annual Number of
Certifications and Burden per Response



	Number of Small Respondents	Number of Respondents	Burden per Response
(hours)*

Private Firms



	Initial Certification	50,296	50,431	8.3

Recertification	1,472	1,476	5.3

No Certification	58,904	59,062	4.8

Total	110,672	110,969

	Note(s): * Includes annual recordkeeping time of 4.8 hours.

Sources:  Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



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	4.8	4.8	4.8

Total	8.3	5.3	4.8



Total Certification/Recordkeeping  Burden- Hours

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

 	Year 1	Year 2	Year 3	Average

Rule Familiarization	334,278	59,922	59,679	151,293

Certification Form	55,713	11,097	11,052	25,954

Recordkeeping	534,845	532,646	530,467	532,653

Total	924,836	603,665	601,198	709,899

Note(s): Numbers may not calculate due to rounding.  Re-certification
required every five years.  

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



Renovation, Repair, and Painting Firms – Burden Related to
Recordkeeping Checklist

Under the revisions to the 2008 LRRP rule, all renovation firms are
required to provide a copy of the records demonstrating compliance with
the training and work practice requirements of the RRP rule to the owner
and, if different, the occupant of the building being renovated or the
operator of the child-occupied facility.  Firms performing work in
owner-occupied target housing would be required to distribute one copy
of the checklist while firms performing work in renter-occupied target
housing would be required to provide a copy each to the owner and the
occupant.  If the work occurs in the common area of an apartment
building, the checklist, or information on how to obtain the checklist,
must be posted on a sign in the common area or delivered to each of the
affected units.  (This analysis always assumes that a sign will be
posted.)  Child-occupied facilities that perform work themselves must
post the checklist, or information on how to obtain the checklist, on a
sign that is accessible to parents or guardians of the children or mail
this information to these individuals.  Similarly, landlords that
perform work would have to supply one copy of the checklist attached to
a sign in the area where the work is being performed or provide a copy
to each affected unit.  Contractors who perform work in owner-occupied
COFs must provide two copies of the checklist: one copy to the owner of
the COF and one copy to be posted on a sign in the COF (they may also
choose to mail this information to the parents or guardians).  In
addition to the two copies required in owner-occupied events,
contractors working in renter-occupied COFs must also provide the
operator of the COF with a third copy of the checklist.

Number of RRP Firms and Events Performed

All RRP firms are required to comply with the recordkeeping checklist
provision during each RRP event they perform.  As discussed in detail in
Section 4.4 of the Economic Analysis for the Opt-Out and Recordkeeping
Final Rule (EPA 2010), 323,147 entities (111,426 opt-out and 211,721
currently regulated) are expected to perform RRP events in Year 1.   
REF _Ref159223958 \h  \* MERGEFORMAT  Exhibit 6.5  presents the number
of opt-out and currently regulated firms that are expected to incur
costs as a result of the recordkeeping checklist provision and
elimination of the opt-out provision.    REF _Ref159223958 \h  \*
MERGEFORMAT  Exhibit 6.5  also presents the estimated number of events
these firms will perform.  Events are presented in groups based on the
number of checklist copies required for each type of event. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  5 : Number of Opt-Out and
Currently Regulated Firms and RRP Events



	Year 1	Year 2	Year 3

Number of RRP Firms

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision
111,426	110,968	110,514

RRP Entities Regulated under the 2008 LRRP Rule	211,721	210,853	209,989

Total - All Entities	323,147	321,821	320,503

Number of RRP Events

Events as a Result of Eliminating the Opt-Out Provision

Owner Target Housing	7,271,555	7,241,742	7,212,050

Events Currently Regulated under the 2008 LRRP Rule

Owner Target Housing	1,459,940	1,453,954	1,447,993

Renter Target Housing	9,572,191	9,532,945	9,493,860

In-House/Landlord a	100,056	99,646	99,238

Owner COF Contractor b	267,534	266,437	265,344

Renter COF Contractor c	12,900	12,847	12,794

Subtotal – Currently Regulated Events	11,412,621	11,365,829	11,319,229

Total - All Events	18,684,176	18,607,571	18,531,280

Source(s): Economic Analysis for the Opt-Out and Recordkeeping Final
Rule (EPA 2010).

a.  RRP is performed by the owner of a public or commercial building.

b.  RRP is performed by a contractor in an owner-occupied public or
commercial building.

c.  RRP is performed by a contractor in a renter-occupied public or
commercial building.



  REF _Ref191371725 \h  \* MERGEFORMAT  Exhibit 6.6  shows the
three-year average annual number of respondents to the recordkeeping
checklist requirements.  During the three year span of this ICR, it is
estimated that an average of 110,969 private firms, of which 110,672 are
small, will seek certification as a result eliminating the opt-out
provision.  An additional 210,855 currently regulated entities, of which
207,340 are small, are estimated to incur costs of complying with the
checklist provision requirements.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  6 : Average Annual Number of
Recordkeeping Checklist Respondents, Responses per Respondent, and
Burden per Response



	Number of Small Respondents	Number of Respondents	Responses per
Respondent	Burden per Response (hours)

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Private Entity	110,672	110,969	65.26	0.05

State/Local Gov	0	0	0.00	0

Entities Currently Regulated by the 2008 LRRP Rule

Private Entity	200,202	203,105	55.65	0.05

State/Local Gov	7,138	7,750	8.13	0.05

Sources:  Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



 Estimated Burden per Event

All renovation firms are required to provide a copy of the records
demonstrating compliance with the training and work practice
requirements of the RRP rule to the owner and, if different, the
occupant of the building being renovated or the operator of the
child-occupied facility.  

This analysis estimates the per-event burden of preparing photocopies
and distributing the checklist.  It is estimated that it will take
entities performing RRP jobs an average of three minutes to photocopy
and distribute the checklist.

Estimated Total Burden

  REF _Ref194399309 \h  \* MERGEFORMAT  Exhibit 6.7  presents the total
burden and cost to respondents resulting from the recordkeeping
checklist requirements. Total respondent burden was estimated by
multiplying the numbers of RRP events by the corresponding per event
burden estimates.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  7 : Total Recordkeeping Checklist
Provision Burden Due to the Rule 

Total Burden Hours

 	Year 1	Year 2	Year 3

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Owner Target Housing	363,578	362,087	360,603

Entities Currently Regulated by the 2008 LRRP Rule

Owner Target Housing	72,997	72,698	72,400

Renter Target Housing	478,610	476,647	474,693

In-House/Landlord a	5,003	4,982	4,962

Owner COF Contractor b	13,377	13,322	13,267

Renter COF Contractor c	645	642	640

Subtotal – Currently Regulated Events	570,631	568,291	565,961

Total - All Events	934,209	930,379	926,564

Note(s): Numbers may not calculate due to rounding.  

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



	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



RRP Firm Wage Rate	

$31.64/hr



Training Providers

The loaded wage rate for training provider clerical staff is $23.54 per
hour.  Clerical staff will prepare and mail notifications and will
perform recordkeeping activities. Training provider 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.  Training providers are also required to take a digital photo
of each renovator receiving certification.  The use of a one-time
digital camera costs $20.58 per 25 photos and takes approximately three
minutes per photo or 1.25 hours per 25 photos.

  REF _Ref237415374 \h  \* MERGEFORMAT  Exhibit 6.8  estimates the
annual cost for training provider notifications.  As shown in   REF
_Ref159299558 \h  \* MERGEFORMAT  Exhibit 6.9 , total training provider
costs are estimated to be $465,625 in the first year of the rule,
$92,571 in the second year, and $91,639 in the third year.  The average
annual cost over the three years covered by the ICR is $216,612.  This
yields an average cost of $1,297 per training provider.



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  8   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	Avg.







Pre-notification	30	6	6	14	$3.53	$0.24	$0.47	$4.24



Re-notification	4	1	1	2	$3.53	$0.24	$0.47	$4.24



Post-notification	30	6	6	14	$36.25	$0.24	$0.47	$36.96

Digital Photo	30	6	6	14	$29.43	$0.00	$20.58	$50.00











	Cost per Training Provider	

	

	

	

Year 1	

Year 2	

Year 3

	

	





$2,772	$554	$552















Training Providers per Year	





	

	

Year 1	

Year 2	

Year 3



	





168	167	166













	Total Cost per Year	





	

	

Year 1	

Year 2	

Year 3

	

	





$465,625	$92,571	$91,639







Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010); EPA ICR No. 1715.07; and U.S. Bureau of Labor Statistics
Occupational Employment Statistics Series (2005).  







Exhibit 6.  SEQ Exhibit_6. \* ARABIC  9   Total Training Provider Costs
- 2005 Dollars







	Year 1	Year 2	Year 3	Average

Total Notification Cost	$465,625	$92,571	$91,639	$216,612

Note(s): Numbers may not calculate due to rounding.    

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010); EPA ICR No. 1715.07; and U.S. Bureau of Labor Statistics
Occupational Employment Statistics Series (2005).  



RRP Firms – Costs Related to Certification

The elimination of the opt-out provision is expected to increase the
number of firms seeking certification.  This ICR accounts for the burden
and costs associated with these additional firms seeking certification. 
The average cost associated with initial certification is $111 per
response, based on a response time of 3.5 hours and a loaded renovator
wage rate of $31.64.  The average re-certification cost per response is
about $16.  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.  (Costs have not been updated from 2005 dollars in
order to facilitate comparison with previous information collection
requests, which were also in 2005 dollars.  Consistent with this,
postage costs have not been updated to 2009.)  All firms incur a
recordkeeping cost of $152 per response.

As presented below in   REF _Ref159299612 \h  \* MERGEFORMAT  Exhibit
6.10 , based on the burden estimates provided in section 6(a) and the
wage rates discussed above, the costs associated with certification
applications for all opt-out firms conducting renovations is estimated
to be $29,323,089 in Year 1, $19,112,164 in Year 2, and $19,034,052 in
Year 3.  The average annual cost for these opt-out entities is $22.5
million over the three years covered by this ICR, resulting in an
average cost per opt-out firm of $203. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  10   Opt-Out Firms: Certification
Cost Estimates





Number of Firms	



	Year 1	Year 2	Year 3

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Receiving Initial Certification	111,426	19,974	19,893

Receiving Re-Certification	0	2,219	2,210

Subtotal: Firms Receiving Certification or Re-Certification	111,426
22,193	22,103

Already Certified - Not Receiving Certification or Re-Certification	0
88,775	88,411

Total	111,426	110,968	110,514



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

	Certification Year	Re-Certification Year	Other Years

Average Cost Per Response

Rule Familiarization	$94.92	$0.00	$0.00

Certification Form	$15.82	$15.82	$0.00



Recordkeeping	$151.87	$151.87	$151.87

Material Costs	$0.55	$0.55	$0.00

Total	$263.16	$168.24	$151.87



Total Certification/Recordkeeping Costs - 2005 Dollars

	Year 1	Year 2	Year 3	Average

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Rule Familiarization	$10,576,556	$1,895,932	$1,888,244	$4,786,911

Certification Form	$1,762,759	$351,093	$349,669	$821,174

Recordkeeping	$16,922,489	$16,852,932	$16,783,982	$16,853,135

Material Costs	$61,284	$12,206	$12,157	$28,549

Total	$29,323,089	$19,112,164	$19,034,052	$22,489,768

Note(s): Numbers may not calculate due to rounding.   

Sources:  Economic Economic Analysis for the Opt-Out and Recordkeeping
Final Rule (EPA 2010); EPA ICR No. 1715.07; and U.S. Bureau of Labor
Statistics Occupational Employment Statistics Series (2005).  



RRP Firms – Costs Related to Recordkeeping Checklist Provision

Under the revisions to the 2008 LRRP rule, all renovation firms are
required to provide a copy of the records demonstrating compliance with
the training and work practice requirements of the RRP rule to the owner
and, if different, the occupant of the building being renovated or the
operator of the child-occupied facility.  This additional requirement
would pertain to all firms, those regulated under the 2008 LRRP rule as
well as those that would not have otherwise sought certification and
training without the elimination of the opt-out provision.   Firms
performing work in owner-occupied target housing would be required to
distribute one copy of the checklist while firms performing work in
renter-occupied target housing would be required to provide a copy to
the owner and occupant.  If the work occurs in the common area of an
apartment building, the checklist, or information on how to obtain the
checklist, must be posted on a sign in the common area or delivered to
each of the affected units.  (This analysis always assumes that a sign
will be posted.)  Child-occupied facilities that perform work themselves
must post the checklist, or information on how to obtain the checklist,
on a sign that is accessible to parents or guardians of the children or
mail this information to these individuals.  Similarly, landlords that
perform work would have to supply one copy of the checklist attached to
a sign in the area where the work is being performed or provide a copy
to each affected unit.  Contractors who perform work in owner-occupied
COFs must provide two copies of the checklist: one copy to the owner of
the COF and one copy to be posted on a sign in the COF (they may also
choose to mail this information to the parents or guardians).  In
addition to the two copies required in owner-occupied events,
contractors working in renter-occupied COFs must also provide the
operator of the COF with a third copy of the checklist.

In addition to the time needed to prepare photocopies and distribute the
checklist, entities performing RRP events will also incur the cost of
photocopy materials.  Based on per-page photocopy costs, EPA estimates
that a single copy of the checklist costs $0.08.    REF _Ref159299649 \h
 \* MERGEFORMAT  Exhibit 6.11  presents resulting per-event checklist
costs. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  11   Number of Checklist Copies
and Cost per Event



 	Target Housing Events	Public and Commercial Building Events

	Owner	Renter	In-house / Landlord b	Contractor – Owner c	Contractor 
– Renter d

Labor Cost a	$1.58	$1.58	$1.58	$1.58	$1.58

Material Cost e	$0.08	$0.16	$0.08	$0.16	$0.24

Total Cost	$1.66	$1.74	$1.66	$1.74	$1.82

a.  Based on a burden of 3 minutes, at a wage rate of $31.64, based on
Bureau of Labor Statistics (SOC 47-1011)

b.  RRP is performed by the owner of a public or commercial building.

c.  RRP is performed by a contractor in an owner-occupied public or
commercial building.

d.  RRP is performed by a contractor in a renter-occupied public or
commercial building.

e.  The average price of a photo copy at Copy Cop, Kinkos, Staples, and
Office Max is eight cents.

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010).



  REF _Ref159299670 \h  \* MERGEFORMAT  Exhibit 6.12  presents the
estimated total costs of the recordkeeping checklist provision to
entities performing RRP events.  RRP firms will incur time burden and
material costs, presented in   REF _Ref194399309 \h  \* MERGEFORMAT 
Exhibit 6.7  and   REF _Ref159299649 \h  \* MERGEFORMAT  Exhibit 6.11 ,
respectively.  To estimate total labor costs associated with the
recordkeeping checklist, the total burden estimates in   REF
_Ref194399309 \h  \* MERGEFORMAT  Exhibit 6.7  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 by the corresponding
per-event pamphlet cost estimates in   REF _Ref159299649 \h  \*
MERGEFORMAT  Exhibit 6.11 .

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  12   Total Costs Associated with
the Recordkeeping Checklist Provision



	Year 1	Year 2	Year 3

Total Labor Cost

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

Owner Target Housing 	$11,503,600	$11,456,435	$11,409,464

Entities Currently Regulated under the 2008 LRRP Rule

Owner Target Housing	$2,309,625	$2,300,156	$2,290,725

Renter Target Housing	$15,143,206	$15,081,119	$15,019,286

In-House/Landlord	$158,289	$157,640	$156,994

Owner COF Contractor	$423,238	$421,503	$419,775

Renter COF Contractor	$20,408	$20,324	$20,241

Subtotal	$18,054,766	$17,980,742	$17,907,021

Total - All Entities	$29,558,366	$29,437,177	$29,316,485

Total Materials Cost

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

Owner Target Housing	$581,724	$579,339	$576,964

Entities Currently Regulated under the 2008 LRRP Rule

Owner Target Housing	$116,795	$116,316	$115,839

Renter Target Housing	$1,531,551	$1,525,271	$1,519,018

In-House/Landlord	$8,005	$7,972	$7,939

Owner COF Contractor	$42,805	$42,630	$42,455

Renter COF Contractor	$3,096	$3,083	$3,071

Subtotal	$1,702,252	$1,695,272	$1,688,322

Total - All Entities	$2,283,976	$2,274,612	$2,265,286

Total Cost

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

Owner Target Housing	$12,085,324	$12,035,775	$11,986,428

Entities Currently Regulated under the 2008 LRRP Rule

Owner Target Housing	$2,426,420	$2,416,472	$2,406,564

Renter Target Housing	$16,674,757	$16,606,390	$16,538,304

In-House/Landlord	$166,294	$165,612	$164,933

Owner COF Contractor	$466,044	$464,133	$462,230

Renter COF Contractor	$23,504	$23,407	$23,311

Subtotal	$19,757,018	$19,676,014	$19,595,343

Total - All Entities	$31,842,342	$31,711,789	$31,581,771

Sources:   Economic Analysis for the Opt-Out and Recordkeeping Final
Rule (EPA 2010); EPA ICR No. 1669.04 (2004); U.S. Bureau of Labor
Statistics Occupational Employment Statistics Series (2005); The average
price of a photo copy at Copy Cop, Kinkos, Staples, and Office Max is
eight cents.



	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 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 two tasks as
part of administering the RRP program: 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.  

Agency Cost of Processing Training Notifications

As it is estimated that no training providers will seek accreditation as
a result of the revisions to the 2008 LRRP Rule, EPA will only incur the
cost of processing notifications submitted by training providers prior
to and following each course session.  It is assumed that EPA technical
staff with a fully loaded hourly wage of $34.69 will spend an average of
two minutes processing each notification.

It is estimated that there will be 10,765 training notifications in Year
1, 2,140 in Year 2, and 2,119 in Year 3.  As shown in   REF
_Ref159302141 \h  \* MERGEFORMAT  Exhibit 6.13 , it will cost EPA
$12,477 to process training notifications in the first year of the rule,
$2,475 in Year 2, and $2,450 in Year 3.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  13   Total EPA Cost of Processing
Training Notifications – 2005 Dollars





	

Year 1	

Year 2	

Year 3

Process Training Notification	$12,447 	$2,475 	$2,450 

Total 	$12,447 	$2,475 	$2,450 

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule
(EPA 2010); U.S. Office of Personnel Management:  2005 General Schedule
- Base Annual (OPM 2005).



Agency Costs of Certifying Renovation Firms

The revisions to the 2008 LRRP Rule will require opt-out renovation
establishments to submit a completed application and fee.  For the
purpose of estimating costs, it is assumed that EPA Regions will incur
variable processing costs, and fixed administrative and enforcement
costs.  Regional administrative activities include answering phone
inquires from the public regarding the LRRP program, following up on the
status of applications, providing information to other regions,
coordinating with headquarters, and performing other customer service
activities. Enforcement activities include conducting audits of training
providers and firms.  In addition, it is assumed that EPA Headquarters
will incur fixed administrative costs related to coordination with
regions and maintenance of the central database and registry.  EPA
Headquarters will also support enforcement activities.

 

Certification cost estimates are based on responses from a Time-Motion
Study conducted in support of the 2009 Economic Analysis for the TSCA
section 402 Lead-Based Paint Program Accreditation and Certification Fee
Rule (i.e., the Fee Rule).  In the Time-Motion Study, data were
collected from three EPA Regions: Region 2, Region 4, and Region 9. 
Regions were asked to provide the number of hours and personnel required
to process applications under the TSCA section 402(a) Lead-Based Paint
Activities program (i.e., the Abatement Rule).  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. 

To estimate fees for the LRRP rule, EPA followed the approach used to
estimate fees for the Abatement rule.  To structure the fees, EPA first
considered the variable and fixed costs associated with each applicant
type.  The variable costs reflect the regional processing costs for each
application type.  The fixed costs include the regional and headquarters
administrative and enforcement costs, which apply across all the
applications.  EPA divided the total regional enforcement and
administrative costs and the headquarters costs by the total estimated
number of applicants over the five year projection period to obtain a
fixed cost of $282 for training providers and firms.  

Fixed costs for renovators and sampling technicians were estimated by
dividing the headquarters administrative costs by the total number of
applicants over the five year period to obtain a fixed cost of $6.  As
renovators and sampling technicians are not required to obtain formal
certification, their fixed costs are recouped by the fee charged to RRP
firms.  In addition, tribes will be charged a nominal fee ($20 for firm
applicants, and $10 for individual certifications) and firms applying
for both an Abatement certification and a LRRP certification will only
be charged for the more expensive Abatement certification. Firms that
are ineligible for these discounts will be charged an additional $9 to
cover the costs of the discounts.  See the 2009 Fee Rule for an in-depth
explanation of fee structure methodology and calculations.   REF
_Ref159302281 \h  \* MERGEFORMAT  Exhibit 6.14  presents the fee
schedule developed in the Economic Analysis for the Fees Rule.  The
actual fee charged to firms was rounded to $300; the rounded fee is used
in subsequent calculations.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  14   Fee Schedule for Certifying
Renovation Establishments





	Avg. Processing Cost Per Applicant	Fixed Cost	Additional Fee (to cover
costs of discounts)	Total Fee

Estimated Initial Certification Fee	$11	$282	$9	$301

Estimated Re-Certification Fee	$12	$282	$9	$302

Actual Fee Charged	 	 	 	$300 

Note(s): numbers may not calculate due to rounding.    

Sources:  The Economic Analysis for the TSCA section 402 Lead-Based
Paint Program Accreditation and Certification Fee Rule  (EPA 2009)



As described earlier in   REF _Ref159299188 \h  \* MERGEFORMAT  Exhibit
6.3 , it is estimated that 111,426 firms would become certified in Year
1.  In Year 2, 22,193 firms are expected to seek certification or
re-certification, and in Year 3, 22,103 firms are expected to be
certified or re-certified.  As shown in   REF _Ref159302374 \h  \*
MERGEFORMAT  Exhibit 6.15 , based on these estimates, it will cost EPA
$33 million to certify these firms in Year 1.  EPA’s costs for firm
certifications are estimated to be less than $7 million in Years 2 and
3.    

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  15   Total Costs of Certifying
Renovation Establishments 



	

Year 1	

Year 2	

Year 3

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

Firms Seeking Certification	111,426 	22,193 	22,103 

Total Cost of Certification	$33,427,800 	$6,657,900 	$6,630,900 

Note(s): Numbers may not calculate due to rounding.  

Sources:  Analysis for the Opt-Out and Recordkeeping Final Rule (EPA
2010); The Economic Analysis for the TSCA section 402 Lead-Based Paint
Program Accreditation and Certification Fee Rule  (EPA 2009)



	6(d)  Bottom Line Burden Hours and Cost

The number of respondents is shown in   REF _Ref159303131 \h  \*
MERGEFORMAT  Exhibit 6.16 , and the number of responses in   REF
_Ref159303145 \h  \* MERGEFORMAT  Exhibit 6.17 .  The respondent burden
for the collection of notification information is shown in   REF
_Ref159303172 \h  \* MERGEFORMAT  Exhibit 6.18 .  The annual paperwork
burden over the first three years is estimated to average 1,647,321
hours.  The average annual respondent cost for the collection of
notification information is shown in   REF _Ref237421666 \h  \*
MERGEFORMAT  Exhibit 6.19  and is estimated to be $54 million.  The
Agency cost is estimated to average $15.5 million per year, as shown in 
 REF _Ref159303280 \h  \* MERGEFORMAT  Exhibit 6.20 .  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  16   Number of Respondents









	

Year 1	

Year 2	

Year 3	

Average

Training Providers	168	167	166	167

Opt-Out Entities	111,426	110,968	110,514	110,969

Currently Regulated Entities	211,721	210,853	209,989	210,854

Total	323,315	321,988	320,669	321,991



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  17   Number of Responses









	

Year 1	

Year 2	

Year 3	

Average

Training Provider Notifications	10,765	2,140	2,119	5,008

Opt-Out Firm Initial Certifications	111,426	19,974	19,893	50,431

Opt-Out Firm Re-Certifications	0	2,219	2,210	1,476

Opt-Out Firm Checklist Events	7,271,555	7,241,742	7,212,050	7,241,782

Currently Regulated Firm Checklist Events	11,412,621	11,365,829
11,319,229	11,365,893

Total	18,806,367	18,631,904	18,555,501	18,664,591



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  18   Respondent Burden Hours









	

Year 1	

Year 2	

Year 3	

Average

Training Providers	15,127	3,007	2,977	7,037

Opt-Out Firm Certification	924,836	603,665	601,198	709,899

Opt-Out Firm Checklist	363,578	362,087	360,603	362,089

Currently Regulated Checklist	570,631	568,291	565,961	568,295

Total	1,874,172	1,537,051	1,530,739	1,647,321





Exhibit 6.  SEQ Exhibit_6. \* ARABIC  19   Respondent Cost









	

Year 1	

Year 2	

Year 3	

Average

Training Providers	$465,625 	$92,571 	$91,639 	$216,612 

Opt-Out Firm Certification	$29,323,089 	$19,112,164 	$19,034,052 
$22,489,768 

Opt-Out Firm Checklist	$12,085,324 	$12,035,775 	$11,986,428 
$12,035,842 

Currently Regulated Checklist	$19,757,018 	$19,676,014 	$19,595,343 
$19,676,125 

Total	$61,631,056 	$50,916,523 	$50,707,461 	$54,418,347 



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  20   Agency Cost









	

Year 1	

Year 2	

Year 3	

Average



EPA	$33,440,247 	$6,660,375 	$6,633,350 	$15,577,991 



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  21 : Respondent Summary,
Three-Year Average



	Number of Small Respondents	Number of Respondents	Responses per
Respondent	Burden per Response (hours)	Annual Burden

Training Providers - Existing Respondents, Additional Responses

Pre-notification 	157	167	14	0.16	378

Re-notification	157	167	2	0.16	45

Post-notification	157	167	14	1.55	3,661

Digital Photos	157	167	14	1.25	2,953

Renovators – Private Firms – Additional Respondents

Initial Certification	50,296	50,431	1	8.3	418,577

Re-certification	1,472	1,476	1	5.3	7,825

Non-Certification Year	58,904	59,062	1	4.8	283,498

Recordkeeping Checklist Requirements

Entities Seeking Certification as a Result of Eliminating the Opt-Out
Provision

New third party notification requirement for additional renovator 
respondents

 Private Firms	110,672	110,969	65.26	0.05	362,089

Recordkeeping Checklist Requirements

Entities Currently Regulated by the 2008 LRRP Rule

New third party notification requirement for existing renovator
respondents

 Private Firms	200,202	203,105	55.65	0.05	565,145

 Local Governments	7,138	7,750	8.13	0.05	3,150

Key

   Cells highlighted in yellow are incremental increases from previous
ICR (EPA No. 1715.10, March 2008).  

  Cells highlighted in blue are revised estimates from previous ICR (EPA
No. 1715.10, March 2008).

   Cells highlighted in pink are new requirement that were not in
previous ICR (EPA No. 1715.10, March 2008).  

⁬  Cells that are not highlighted have not changed from the previous
ICR (EPA No. 1715.10, March 2008).  



The total burden in OMB’s inventory for the existing, approved version
of this ICR (EPA ICR No. 1715.10) is 2,157,174 hours.  With the addition
of the 1,647,321 program change hours related to the rule and 5,258
adjustment hours, the total burden requested for this ICR will be
3,809,753 hours.  

6(e)  Reasons For Changes in Burden

	Most of the burden analyzed in this ICR addendum relates directly to
the amended paperwork requirements contained in the rule and results in
a program change increase.  EPA is also correcting some miscalculations
presented in the ICR addendum for the 2008 final RRP rule (ICR #1715.10)
that results in adjustment-related increase in burden.

Program Changes

Most of the burden increase analyzed in this ICR is attributable to
program changes related to the revisions to the 2008 final RRP rule. 
These changes would increase the number of respondents for certain
approved information collection activities in some cases, and in other
cases increase the number of events for certain approved information
collection activities. 

	Additional Respondents Needing Certification

EPA estimates that an additional 110,969 firms would need to be
certified as a result of the elimination of the opt-out provision, and
therefore add a corresponding 110,969 annual responses.  Of these
110,969 annual responses, EPA estimates that over the three years
covered by the ICR, there will be an average of 50,431 new initial
certification responses, 1,476 re-certification responses, and 59,062
non-certification year recordkeeping responses per year. The addition of
these new responses is expected to increase the annual certification
burden by 418,577 hours for firms seeking initial certification, 7,825
hours for firms seeking re-certification, and 283,498 hours for firms
engaged in non-certification year recordkeeping activities 

	Additional Training Events

In direct relation to the increased number of firms that will be
required to be trained and certified, training providers are expected to
hold an additional 14 courses per year to accommodate the increase in
the number of new respondents seeking RRP certification.  Training
providers are required to notify EPA before and after course completion,
and in some instances re-notify if course rosters/schedules change.
Therefore, EPA has increased the estimated number of pre-course and
post-course notifications per firm each by 14, and the number of
re-notifications per firm by 2. The annual notification burden for
training providers related to these additional courses is expected to
increase by 378 hours for pre-course notification, 45 hours for
re-notifications, and 6,614 hours for post-course notification
(including digital photographs).

		New Third-Party Notification Requirements

	EPA estimates that the 3rd-party notification requirements would result
in an average burden increase of 930,384 hours per year.  Each instance
of the required 3rd-party notification is estimated to require about 3
minutes of the respondents’ time.  However, as indicated in Ex. 6.21,
the number of respondents and the estimated number of events per
respondent combine to produce a substantial increase in the overall
annual burden estimate.

Adjustments

	Digital Photographs

EPA incorrectly accounted for the training provider burden associated
with digital photographs of trainees seeking renovation certifications
in the final rule ICR addendum (ICR No. 1715.10).  In that ICR, EPA
estimated that the burden associated with taking a single digital
photograph would be 0.05 hours (3 minutes).  However, EPA inadvertently
utilized this per-photograph estimate as the full burden estimate for a
single course with an assumed training roster of 25 students.  The
digital photograph burden for a single course with an assumed roster of
25 students should be 1.25 hours rather than 0.05 hours.  This
correction results in an adjustment burden increase of approximately
5,254 annual burden hours.

	Estimated Baseline Number of Firms

In addition, this ICR addendum revises the estimated number of RRP firms
upward by a single respondent.  Specifically, EPA estimates that there
will be a single additional respondent engaged in non-certification year
record-keeping. Each respondent engaged in this activity will continue
to have only a single annual response. This change is directly related
to a rounding error and has the impact of adding about 4 hours to the
overall estimated annual burden for this ICR.

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 42 hours per year for training providers.  For firms that
will seek certification as a result eliminating the opt-out provision,
the average incremental burden is estimated to be about 9.7 hours per
year.  For firms that are currently regulated under the 2008 LRRP Rule,
the average incremental burden is estimated to be about 2.7 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.



ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement for this rule-related ICR
addendum are available in the public docket established for the
rulemaking under docket identification number EPA-HQ-OPPT-2005-0049. 
These attachments are available for online viewing at
www.regulations.gov or otherwise accessed as described in section 6(f)
of the supporting statement.

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



Attachment 2	Final 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 8500-27R



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

												

EPA ICR No. 1715.11; 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.   SEQ CHAPTER \h \r 1 

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 2

Final 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. 1715.11; 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. 1715.11; 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. 1715.11; 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. 1715.11; 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. 1715.11; 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:_________________________________________________

Brief Description of Renovation:
_________________________________________________

________________________________________________________________________
____

Name of Assigned
Renovator:____________________________________________________

Name(s) of Trained Workers, if
used:______________________________________________

________________________________________________________________________
____

Name of Dust Sampling Technician, Inspector, or Risk Assessor, if
used:______彟彟彟彟彟彟弍彟彟彟彟彟彟彟彟彟彟彟彟彟
彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟彟
彟

	  SEQ CHAPTER \h \r 1 Copies of renovator and dust sampling
technician qualifications (training certificates, certifications) on
file.  

	Certified renovator provided training to workers on (check all that
apply):  

		Posting warning signs			Setting up plastic containment barriers

		Maintaining containment		Avoiding spread of dust to adjacent
areas	

		Waste handling			Post-renovation cleaning	

	  SEQ CHAPTER \h \r 1 Test kits used by certified renovator to
determine whether lead was present on components affected by renovation
(identify kits used and describe sampling locations and
results):_____________________________________________________________

	_______________________________________________________________________

	_______________________________________________________________________

	Warning signs posted at entrance to work area.  

	Work area contained to prevent spread of dust and debris

		All objects in the work area removed or covered (interiors)

		HVAC ducts in the work area closed and covered (interiors)

		Windows in the work area closed (interiors)

		Windows in and within 20 feet of the work area closed (exteriors)

		Doors in the work area closed and sealed (interiors)

		Doors in and within 20 feet of the work area closed and sealed
(exteriors)

		Doors that must be used in the work area covered to allow passage
but prevent spread of dust  

		Floors in the work area covered with taped-down plastic (interiors)

		Ground covered by plastic extending 10 feet from work
area—plastic anchored to building and weighted down by heavy objects
(exteriors)

		If necessary, vertical containment installed to prevent migration
of dust and debris to adjacent property (exteriors)

	Waste contained on-site and while being transported off-site

	Work site properly cleaned after renovation

		  SEQ CHAPTER \h \r 1 All chips and debris picked up, protective
sheeting misted, folded dirty side inward, and taped for removal

		  SEQ CHAPTER \h \r 1 Work area surfaces and objects cleaned using
HEPA vacuum and/or wet cloths or mops (interiors)

	  SEQ CHAPTER \h \r 1 Certified renovator performed post-renovation
cleaning verification (describe results, including the number of wet and
dry cloths used):________________________________

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	_______________________________________________________________________
_		If dust clearance testing was performed instead, attach a copy of
report.

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

_________________________________________________
________________________

	name and title								date

EPA ICR No. 1715.11; 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 

									

 The 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.

 Only target housing contractors would be affected by the elimination of
the opt-out provision. 

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.

 Certified renovators’ fully loaded wages ($31.64/hour) are estimated
from BLS wage data for First-Line Supervisors/Managers of Construction
Trades and Extraction Workers (Occupation 47-1011) who work in the
residential building construction industry.  Wages are fully loaded to
account for fringe benefits with an average fringe rate for the
construction industry of 23.5 percent.

 EPA used the Office of Personnel Management’s General Salary Table
2005-GS to estimate government employee wage rates.  EPA used the wage
for a GS-11, Step 1 employee and loaded the wage using the standard
government multiplier of 1.6 to cover overhead and fringe benefits. 

December 27, 2005

April 26, 2010	Page   PAGE  5  of   NUMPAGES  38 

December 27, 2005

