  SEQ CHAPTER \h \r 1 Supporting Statement for a Request for OMB Review
under

The Paperwork Reduction Act

1	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)  	Title and Number of the Information Collection

	Title:	Asbestos-Containing Materials in Schools Rule and Revised
Asbestos Model Accreditation Plan Rule

	EPA ICR No.: 1365.09		OMB Control No.: 2070-0091

	1(b) 	Short Characterization

	This ICR addresses reporting and recordkeeping requirements found in
the Asbestos-Containing Materials in Schools Rule (“AHERA Rule”) and
the Asbestos Model Accreditation Plan (MAP) Rule.

	AHERA Rule:  Under Section 203 of the Asbestos Hazard Emergency
Response Act (AHERA, 15 U.S.C. 2641-2656) (see Attachment A), EPA was
required to finalize the Asbestos-Containing Materials in Schools Rule. 
This rule required Local Education Agencies (LEAs) to conduct
inspections, develop management plans, and design or conduct response
actions.  Records must be maintained by all LEAs on inspections and
response action activity, and current management plans must be provided
upon request to EPA and State reviewers for examination.

	MAP:  Additionally, Section 206 of AHERA (see Attachment B) required
that EPA issue a Model Accreditation Plan (MAP) for persons who inspect
for asbestos, develop management plans, and design or conduct response
actions.  States are required to adopt an accreditation plan at least as
stringent as the EPA model.  In 1990, EPA was required to make certain
changes in its original MAP.  Accreditation of laboratories that analyze
asbestos bulk samples and asbestos air samples is also required by
AHERA.  AHERA required the National Institute of Standards and
Technology (NIST) to establish the bulk sampling accreditation program,
and the air sampling program.

	This information collection activity will assure that LEAs continue to
inspect for asbestos and update management plans with accredited
personnel to protect all school building occupants from exposure to
asbestos.  This collection will also assure that persons who inspect for
asbestos, develop management plans, and design or conduct response
actions are properly accredited, and that states will adopt appropriate
accreditation programs.

2	NEED FOR AND USE OF THE COLLECTION

	2(a) 	Need/Authority for the Collection

	AHERA Rule and MAP:  The reporting and recordkeeping requirements
covered by this ICR are required by the Asbestos-Containing Materials in
Schools Rule (40 CFR 763, Subpart E) and the Model Accreditation Plan
(40 CFR 763, Subpart E, Appendix C); see Attachments C and D,
respectively.

	2(b) 	Use/Users of the Data

	AHERA Rule:  The activities pertaining to the use of this information
collection activity help assure that LEAs continue to inspect for
asbestos and update their management plans using accredited personnel. 
This is intended to ensure the protection of all school building
occupants from exposure to asbestos fibers.  All public and private
elementary and secondary schools (unless exempt under provision of the
rule) were required to conduct inspections for asbestos-containing
building materials (ACBM) and develop management plans that describe
necessary actions to be undertaken.  Reinspections by accredited persons
must take place every three years unless all ACBM has been removed. 
Records retention as part of an updated asbestos management plan is
necessary in order to document specific response action activities and
periodic surveillance/3-year reinspection reports, and for an LEA to
demonstrate compliance with the regulations.  Beneficiaries of the
collection activities include the LEA’s asbestos program manager and
staff, accredited professionals who may be called upon to perform
response actions at a school, and Federal and State enforcement
agencies.

	MAP:  This collection will enable EPA, as well as State regulators, to
determine initial compliance and to monitor continued compliance with
the revised MAP standards.  Lacking both the application submissions and
other recordkeeping requirements, regulators would have no meaningful
way of measuring the implementation of the MAP’s statutory mandates. 
Other beneficiaries of the collection activities include 1) individuals
who may desire to obtain asbestos training meeting at least prescribed
minimum quality standards for accreditation and subsequent employment
purposes; 2) LEAs and other building owners and managers seeking to
procure the services of qualified and accredited asbestos consultants
and contractors; and 3) enforcement agencies at the Federal and State
level.

3	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a) 	Non-Duplication

	AHERA Rule:  EPA has tried to identify alternate sources of the
information requested to implement and enforce this recordkeeping, and
was not successful.  This activity does not duplicate information
already required to be reported by another agency or EPA program office.

	MAP:  All of the training and accreditation information collected
pursuant to this ICR is specific to the MAP and does not duplicate any
other collection.  There is no other model accreditation plan for States
other than the MAP, and there is no procedure for the accreditation of
asbestos training programs under the Asbestos School Hazard Abatement
Reauthorization Act (ASHARA) other than what is specifically provided
for in the MAP.

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

	Prior to submission to OMB, this ICR will be made available to the
public for comment through a Federal Register notice.  The public will
have 60 days to provide comments.  Any comments received will be given
consideration when completing the supporting statement that is submitted
to OMB.

	3(c) 	Consultations

		AHERA Rule:  The Asbestos-Containing Materials in Schools Rule was
developed through the regulatory negotiation process.  Participants
included representatives of national educational organizations, labor
unions, asbestos product manufacturers, the environmental community,
asbestos abatement contractor groups, professional associations of
architects, consulting engineers, industrial hygienists, and EPA.

	In December 2003 and January 2004, EPA consulted with the Agency
regional asbestos coordinators and State regulatory agencies to
determine if the creation of charter schools in recent years has led to
additional respondents or respondent burden due to AHERA requirements. 
At this time insufficient information is available to demonstrate that
any additional reporting burden currently exists beyond that already
identified for public schools (which include charter schools) in Section
6 of this ICR.

	MAP:  Consultations occurred with various respondents since development
work on the MAP Rule revision began several years ago.  Exploratory
meetings were held with labor unions (May 1991) and States (June 1991)
to learn of their interests and concerns.  EPA published its proposed
changes to the MAP in the Federal Register on May 13, 1992, and formally
invited public comment.  A public hearing was held June 8, 1992.  An
additional hearing, with the cooperation of the National Conference on
State Legislatures (NCSL), occurred on June 9, 1992.  Collection
activities were discussed with State participants at that time.  They
continued to express support for EPA’s MAP proposals.

	EPA consulted extensively with labor unions, the States, and other
interested parties during the development of the 1994 Interim Final MAP.
 

	For the purposes of the current ICR renewal request, in January 2007,
EPA conducted consultations on the ICR supporting statement with seven
representatives of the regulated community affected by the ICR.  These
individuals included an asbestos MAP training provider listed under the
National Directory of AHERA Accredited Courses (NDAAC), three AHERA
designated persons for LEAs, a laboratory that performs asbestos
testing, an LEA trade association, and a relevant asbestos worker trade
association.  

	NDAAC training providers are accredited by EPA or by a state that has
developed an accreditation program.  AHERA designated persons are
responsible for implementing the requirements under the
Asbestos-Containing Materials in Schools Rule (40 CFR 763 Subpart E)
pursuant to AHERA for their respective local education agency (LEA). 
Laboratories that perform asbestos bulk or air tests also must comply
with the requirements under the Asbestos-Containing Materials in Schools
Rule (40 CFR 763 Subpart E) and be properly accredited by the National
Institute of Standards and Technology.  

	Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with
potential ICR respondents and data users about specific aspects of ICRs
before submitting an original or renewal ICR to OMB for review and
approval.  In accordance with this regulation, EPA will pursue
additional consultations with interested parties during the development
of the renewal of this collection.

	3(d) 	Effects of Less Frequent Collection

	AHERA Rule:  If information were collected less frequently, it would be
difficult to determine whether an LEA properly inspected for
asbestos-containing materials and developed an appropriate management
plan, and kept these documents up-to-date including ongoing activities.

	MAP:  The revised MAP has no routine or repetitive reporting
requirements.  Training course self-certifications, training course
approval applications and State Program approval applications are
one-time submissions.  Once approved, they do not expire.  A less
frequent collection schedule is not feasible.  Recordkeeping
requirements are tied directly to training courses and the issuance of
accreditation certificates to students successfully completing those
courses and passing the requisite exams.  If training providers are
inactive and not offering courses, no new record generation is required
of them.

	3(e) 	General Guidelines

	Except as described in this section, the collection activities in this
ICR adhere to the guidelines stated in the Paperwork Reduction Act,
OMB’s implementing regulations, and applicable OMB and EPA guidance.

	AHERA Rule:  The rule requires that the asbestos management plans be
maintained as a living document, necessary for as long as
asbestos-containing building materials are present in the school
building.  When all asbestos materials have been removed from a
homogeneous area, records pertaining to that homogeneous area must be
retained for three years after the next reinspection date.  As a result,
such records may need to be maintained beyond the three year record
retention period recommended in 5 CFR 1320.5(d)(2)(iv).  EPA believes,
however, that these retention requirements are necessary to satisfy the
statutory mandates in AHERA, which specifically mandates the development
and maintenance of asbestos management plans.  In addition to ensuring
that a management plan is available for public inspection as required by
AHERA, maintaining a current management plan is necessary and critical
for ensuring the proper protection of human health, safety, and the
environment as required by AHERA.  Providing up-to-date information
about the location and status of asbestos-containing building materials
that remain present in the school building is also essential for
ensuring that the material does not subsequently become unintentionally
disturbed or damaged such that it may pose an unreasonable risk to
school employees, children and other building occupants or users.  In
accordance with 5 CFR 1320.5(d)(2), the retention period beyond the
recommended three year period is necessary and appropriate.

	In approving the ICR in 1998, OMB stated the following: “This ICR is
approved for 3 years.  As requested in previous terms of clearance- EPA
will report on amendments to the School Rule as they relate to record
retention periods and reinspection periods.”  The previous terms of
clearance referenced were from 1995 that stated, “This ICR is approved
for three years- as requested.  EPA has done a good job updating labor
rates for school employees.  EPA shall report on the progress of the
Region VII lead amendments to the Schools Rule as it relates to record
retention periods -beyond 3 years- and reinspection periods -3 years-. 
EPA should continue to separate its MAP burden estimates for the schools
estimates.”

	As reflected in the 1995 statement, EPA had initiated an Agency
workgroup in 1994 to evaluate the AHERA Rule for potential amendments
related to enforcement, and this effort was subsequently expanded to
include the consideration of potential amendments to the record
retention and reinspection periods as OMB requested.  This workgroup
effort did not result in any proposed revisions to the AHERA Rule and
has since been abandoned.

	The Agency has concluded that the reinspection interval is necessary to
satisfy the statutory mandates in AHERA, which specifically mandates the
periodic surveillance and reinspection of asbestos-containing materials,
and that the current interval is appropriate and necessary for ensuring
that the asbestos-containing material does not subsequently become
disturbed or damaged such that it is likely to become a potential hazard
to school employees, children and other building occupants or users. 
The existing reinspection period is consistent with the provisions in 5
CFR 1320.5(d)(2).

	MAP:  There are no exceptions to note.

	3(f) 	Confidentiality

	This information collection does not include questions of a
confidential nature.

	3(g) 	Sensitive Questions

	This information collection does not include questions of a sensitive
nature.

4	THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a) 	Respondents/NAICS Codes

	AHERA Rule and MAP:  There are three types of respondents for this
information collection request.  LEAs and States are involved in
recordkeeping and reporting activities associated with the Schools Rule,
while training providers and States are involved in recordkeeping and
reporting activities related to the MAP Rule.  The respondent activities
are different for each respondent type and are discussed in turn.  The
respondents to this information collection activity are elementary and
secondary school districts (NAICS code 61111), and all states (NAICS
code 92311).  Additionally, under ASHARA, the Model Accreditation Plan
(MAP) affects training providers (NAICS code 61143), and State Asbestos
Accreditation Programs (NAICS code 92312).  These respondents are
included because they are the providers and guarantors of accreditation,
respectively.

	

4(b) 	Information Requested

	(i)  Data Items

	AHERA Rule:  There are no specific data collection instruments used to
collect information for this activity.  The AHERA Rule required
management plans to be submitted to the States for review before October
12, 1988.  LEAs must also submit management plans to the States for
review for school buildings that have since come into operation after
October 12, 1988.  The rule continues to require recordkeeping.

	MAP:  Training providers seeking re-approval for their existing
training courses based upon the revised MAP standards, or initial
approval for new training programs based upon the increased MAP
standards, were required in 1994 to report the following data items:

-  a self-certification letter for upgraded approval pursuant to Part
IV.2 of the MAP; or

-  an application for a new training course approval pursuant to Part
III.a of the MAP.

	When a training provider offers approved training programs for
accreditation purposes, certain records must be maintained for a
three-year period in accordance with the MAP Part I.6.  e.g.,

-  copies of all instructional materials used;

-  copies of all instructor resumes and approvals;

-  copies of examinations and test scores; and

-  records relating to accreditation certificates.

	A State seeking re-approval of its existing accreditation program based
upon the new MAP standards, or initial approval of its State
accreditation program based on the new MAP standards, must report the
following data item:

-  an application for EPA approval pursuant to Part II of the MAP.

	There are no recordkeeping requirements in the MAP that relate to State
programs.

(ii)  Respondent Activities 

	MAP:  Training and Accreditation

	Under AHERA, LEAs shall use trained, accredited persons to perform
asbestos-related tasks as defined by the revised MAP.  Specifically, the
MAP shall be used as a tool to accredit persons who:

- conduct inspections or reinspections for asbestos-containing material
(ACM);

- prepare and/or update management plans for elementary and secondary
schools; and

- design or carry out response actions with respect to ACM in those
schools.

ASHARA extended that requirement to similar activities in public and
commercial buildings as well (including residential buildings with 10 or
more dwelling units), with the exception of the preparation of asbestos
management plans.

	Respondents who are training entities will need to perform certain
collection activities:

-  read the regulation;

-  make any required changes to training programs;

-  retain records/materials costs (usual business practice);

-  provide reasonable access to records to EPA and/or the state, as
requested.

	Waiver for State Programs

	The AHERA Rule provides a procedure to allow states to receive a waiver
from some or all of the requirements of the rule if the state has
established and is implementing, or intends to implement, a program of
asbestos inspection and management at least as stringent as the
requirements of the rule.  The rule requires specific information to be
included in the waiver request submitted to EPA.  To date, 11 states
have been granted this waiver under the AHERA Rule.

	Respondents who are state accreditation programs will need to perform
the following collection activities:

-  read the regulation;

-  compare state program authority and the minimum requirements of the
regulation;

-  develop state legislative analysis and adopt new legislation;

-  develop state regulatory analysis and promulgate a new state
regulation;

-  prepare and submit to EPA an application for program approval; and

-  implement a state accreditation program that is not less stringent
than the regulation.

	As of February 2007, 38 states are operating state accreditation
programs under the MAP.

	AHERA Rule:

	Local Education Agencies:  Local education agency (i.e., school or
school district) reporting and recordkeeping under the Schools Rule may
be divided into two main categories:  those associated with the
management plan, and those associated with operations and maintenance
(O&M) activities.  Most of the LEA recordkeeping burden involves the
development and implementation of the management plan.

	The management plan burden varies by school type as well as by the type
of ACM found in a school.  The management plan recordkeeping and
reporting burden items include:

-  Development and submission of the management plan; and

-  Implementation of the management plan including:

		-- Time spent by the program manager to do additional activity
planning, create and gather new information, prepare written activity
reports, and record and review that information;

		-- Time spent by custodians and clerical personnel to gather, record,
process and store asbestos-related information; and

-- Annual notification of parents and other interested parties of the
presence of ACM in a school, as well as the availability of the
management plan for public review.

	The AHERA Rule required management plans to be submitted to the states
for review before October 12, 1988.  LEAs must also submit management
plans to the states for review for school buildings that have since come
into operation after October 12, 1988.  The recordkeeping activities
associated with the management plan implementation are on-going and are
therefore included in burden estimates.

	Recordkeeping Requirements:  The recordkeeping burden associated with
the development of an O&M activity plan was largely completed in the
first year of AHERA Rule implementation.  On an ongoing basis, however
(AHERA regulations also require LEAs to keep known or assumed ACBM under
periodic surveillance), the O&M plan may require updating.  

	The original inspection report and any reinspection reports must be
maintained in the management plan.  Management planner recommendations
and response actions with their air sampling clearance records are also
to be kept.  Records required by the rule also include those pertaining
to fiber release episodes, periodic surveillance, training received by
workers performing operation and maintenance activities, and cleaning
activities that are part of an operations and maintenance program.  The
rule also requires LEAs to collect and retain various records that are
not part of the information included in the management plan.

	The rule requires LEAs to have accredited inspectors conduct
reinspections at least once every three years after the management plan
is in effect.  Results of this reinspection shall be recorded in the
school’s management plan, along with any necessary changes in response
actions recommended or required.

	The rule directs the LEA to select and implement in a timely manner
appropriate response actions for ACBM that are assessed by the
accredited inspector and management planner.  The rule identifies five
major response actions -- operations and maintenance (O&M), repair,
encapsulation, enclosure, and removal -- and describes appropriate
conditions under which they may be selected by the LEA.  The rule also
identifies the steps that shall be taken to properly conduct and
complete the response actions.

	After performing a thorough visual inspection of the area in which the
response action was conducted, air testing is performed to determine
whether a response action has been properly completed.  The rule as it
is in effect at this time (2007) requires the use of transmission
electron microscopy (TEM) for all removal, enclosure, encapsulation, or
repair response actions involving more than 260 linear feet or more than
160 square feet of ACBM.  The use of phase contrast microscopy (PCM) is
allowed by the rule for final air sampling where the amounts of ACBM are
less than the limits above and greater than for small projects of short
duration.

	Response actions that fail to meet prescribed air sampling standards by
the stipulated sampling methods shall have the areas re-cleaned and
re-sampled before being released for reoccupation.  Records of response
actions and subsequent air sampling clearance records must be maintained
by the LEA.

	The rule requires each LEA to maintain a copy of the management plan(s)
in its administrative office, and each school is required to maintain a
copy of its specific management plan in its administrative office. 
These plans are to be made available for inspection by the public
without cost or restriction.  LEAs must notify parent, teacher, and
employee organizations of the availability of the management plans upon
submission of the management plan to the State and at least once each
school year.

	States:  States are involved in both the Schools Rule and the MAP Rule.
 In the first year of the Schools Rule, State governments were required
to establish teams to review and approve management plans submitted by
schools.  This activity, however, is assumed to have been completed, and
is therefore no longer included in burden estimates.

5	THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION METHODOLOGY
AND INFORMATION MANAGEMENT

5(a) 	Agency Activities

	AHERA Rule and MAP include the following:

	-	Distribute guidance to LEAs, state designees, and others on
interpretation of AHERA;

-	Audit training provider courses and records for compliance monitoring
purposes;

-	Review state program applications packages for approval/reapproval as
they are received;

-	Maintain and revise master database of approved training providers as
required to be used as a resource for the public;

-	Revise model criteria as appropriate and develop new curricula for new
training disciplines as required;

-	Provide technical assistance to LEAs and public on implementation and
compliance with AHERA.

	5(b) 	Collection Methodology and Management

	AHERA Rule:  No specific collection methodologies or management
techniques are required.

	MAP:  The rule provides explicit instruction to training providers with
preexisting approvals who wish to upgrade and continue offering asbestos
training courses under the revised MAP standards.  Providers were to
submit a one-time self-certification in the form of a detailed letter to
EPA describing changes made to their courses for the purpose of bringing
them into compliance with the new MAP.  This was required to be done
within six months of the revised MAP taking effect.  Only one letter was
required from each training entity.  EPA then compiled a listing of all
self-certifications received by the deadline and entered them into the
existing data base of approved training providers.  After distribution
to EPA Regional Offices and state program offices, compliance and
program audits may be carried out.  New training providers are to follow
the same procedure.

	The MAP Rule also prescribes the method by which states are to make
application to EPA for accreditation program approval under the revised
MAP.  States wishing to obtain EPA program approval must make a one-time
application to the appropriate EPA Regional Office, demonstrating how
the state’s program is no less stringent than the MAP.

	5(c) 	Small Entity Flexibility

	The impact of the AHERA Rule and the MAP will primarily affect small
asbestos abatement contracting firms or accredited consultants, and
training providers that qualify for “small business” status.  Small
business training providers have a one-time only application process for
training course approvals by MAP approved states that allows for
flexibility in the way information is prepared and presented.  A small
business abatement contractor is required to keep and maintain records
on the accreditation status of supervisors and abatement workers. 
Accreditation records are also kept and maintained by consultants, such
as inspectors, management planners, and project designers.  An advantage
accruing from having those records is that of obtaining and retaining
eligibility to qualify for work in asbestos control and abatement in
schools and public and commercial buildings.  With regard to worker
protection, AHERA and the MAP impose no additional requirements beyond
those that already exist in the OSHA asbestos standard or the EPA Worker
Protection Rule.

	5(d) 	Collection Schedule

	Not applicable for AHERA Rule.

	MAP:  EPA’s receipt of a complete self-certification submission from
a provider constituted immediate re-approval of the training courses. 
Where state legislatures convened in January 1994, a 180-day deadline
was triggered for applying to EPA for new program approval, if needed. 
States not applying for new program approval by the end of the 180-day
deadline forfeited their previous program approval, and they must then
reapply in order to re-establish their state accreditation programs.

	EPA-approved state programs may continue to receive new training course
applications indefinitely into the future.  EPA may continue to receive
state program applications from unapproved states until all states,
territories, and similar entities have ultimately obtained approval.

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

The original ICR for the Asbestos-Containing Materials in Schools Rule
(“Schools Rule”) based its burden estimates on a 30-year projection
to reflect the estimated remaining life span of school buildings with
Asbestos-Containing Materials (ACM).  The previous Schools Rule ICR
renewal (approved in 2007) updated values from the original ICR.  This
ICR renewal further updates values where noted in the sections below. 
Burden estimates based on the Asbestos Model Accreditation Plan (MAP)
Rule were also included in the last ICR.  Those values are also updated.

There are three types of respondents for this ICR: LEAs involved in
recordkeeping and reporting activities associated with the Schools Rule,
and training providers and States involved in recordkeeping and
reporting activities related to the MAP Rule.  The respondent activities
are different for each type of respondent and are discussed in turn in
the following section.

6(a) 	Estimating Respondent Burden

	Local Education Agencies

Local education agency (i.e., school or school district) reporting and
recordkeeping activities under the Schools Rule may be divided into two
main categories: those associated with the management plan and those
associated with operations and maintenance (O&M) activities. Schools
with friable ACM incur burden for the management plan and O&M
activities, while schools with nonfriable ACM (including newly
constructed schools that are certified through an exclusionary statement
not to have specified asbestos-containing building materials in
construction) incur burden only for the management plan.

The management plan burden varies by school type as well as by the type
of ACM found in a school.  Appendix G of the Final Schools Rule Asbestos
Hazard Emergency Response Act Regulatory Impact Analysis (EPA, 1987a)
contains time and cost estimates for management and O&M plan development
and implementation for schools with friable ACM or nonfriable ACM. 
Those activities incurring burden that were not completed during the
initial 10 years of implementation are shown in Worksheet 1.

Worksheet 1 indicates that the annual estimated recordkeeping burden for
schools with friable ACM is approximately 35 hours for public primary
schools and private schools, and 58 hours for public secondary schools. 
For schools with nonfriable ACM only (including newly constructed
schools covered by exclusionary statements), the annual estimated
recordkeeping burden is 15 hours for public primary schools and private
schools, and 28 hours for public secondary schools.  This approach may
overstate the respondent burden for newly constructed schools covered by
exclusionary statements because these schools will not incur a burden
related to records of inspection, re-inspection, response actions and
periodic surveillance.  However, newly constructed schools covered by
exclusionary statements still would need to keep certain information and
records up-to-date.  This includes name and training records for the
AHERA Designated Person and dated copies of each year’s annual
notification of the management plans availability to parents, teachers
and employees, along with a description of the steps taken to provide
the notification.

Worksheet 1: Annual Respondent Burden per Local Education Agency
(Hours)

Burden Hour Elements	School Type

	Public Primary or Private	Public     Secondary

Schools With Friable Asbestos-Containing Materials

Implement Management Plan

Asbestos program manager - Activity planning, create and gather
information, prepare activity reports, record and review information	10
15

Custodial - Gather, record, process and store information	4	8

Clerical - Gather, record, process and store information	16	30

Total Management Plan	30	53



Implement Operations and Maintenance (O&M) Plan

Asbestos program manager - Activity planning, create and gather
information, prepare activity reports, record and review information	2	2

Custodial - Gather, record, process and store information	1	1

Clerical - Gather, record, process and store information	2	2

Total O&M Plan	5	5

Total recordkeeping burden per school with Friable ACM	35	58



Schools With Nonfriable Asbestos-Containing Materials Only

Implement Management Plan

Asbestos program manager - Activity planning, create and gather
information, prepare activity reports, record and review information	5	8

Custodial - Gather, record, process and store information	4	8

Clerical - Gather, record, process and store information	6	12

Total recordkeeping burden per school with Nonfriable ACM	15	28

Source:  EPA. 1987.  AHERA Economic Impact Analysis; Table 11 and
Appendix G: “Second Year Implementation Costs.”  Nonfriable ACM does
not require an O&M Plan. 



States

States are involved in both the Schools Rule and the MAP Rule.  State
activities related to the Schools Rule were completed during the first
10 years of program implementation.  The MAP Rule went into effect in
1994, at which time states were to apply to EPA for new program
approval.  For the purposes of this analysis, all states are assumed to
have completed accreditation program approval during previous ICR
periods.  Therefore, no burden for initial state activities is included
in this ICR.

For all states with EPA-approved accreditation programs, an on-going
burden associated with the MAP Rule is the implementation of state
accreditation programs.  Annual burden estimates from the MAP Rule are
given in Worksheet 2.  These estimates assume that all states have
approved accreditation programs.  In cases where a state does not have
an approved program, the burden would be shifted to EPA.  This
assumption provides the most conservative estimates of state burdens.

Worksheet 2: Annual Respondent Burden per State or Territory (Hours)

Burden Hour Elements	Labor Category	Total Hours

	Management	Technical	Clerical

	Annual activities





Implement a state accreditation program that is not less stringent than
the regulation	8	23	109	140

Total annual activities	8	23	109	140

Source: EPA. 1993. Supplemental ICR for the Asbestos-Containing
Materials in Schools Rule. (EPA ICR #1365).

	

Training Providers

Training providers were required to recertify under the revised MAP. 
Providing access to records is expected to take 5.5 hours per year per
training provider, as indicated in Worksheet 3, while the retention of
the records is considered a customary and usual business practice. 
Therefore, no additional burden is associated with this task.

Worksheet 3: Annual Respondent Burden per Training Provider (Hours)

Burden Hour Elements	Labor Category	Freq/Year	Total Hours

	Clerical



Annual activities



	1.  Retain records	0	N/A	0

2.  Provide reasonable access to records to EPA or state	0.5	11	5.5

Total annual activities	0.5	11	5.5



6(b) 	Estimating Respondent Costs

The cost estimates addressed in this section are based on the burden
estimates discussed above and additional non-wage costs discussed below.
 Wage rates (including benefits) have been updated from the values in
the AHERA RIA (EPA, 1987a), the Supplemental ICR for the
Asbestos-Containing Materials in Schools Rule (EPA, 1993), and the
previous ICR (EPA, 2007) to reflect 2010 levels.  Methods for updating
hourly wage rates to 2010 levels are discussed for each respondent
category.

Local Education Agencies

The implementation cost to LEAs of the Schools Rule includes the wages
associated with the burden estimates in Section 6(a).  Labor costs were
updated to 2010 using mean hourly wage rates from the Bureau of Labor
Statistics’ National Industry-Specific Occupational Employment and
Wage Estimates, the Employment Cost Index for wages and salaries, and
the Employer Costs for Employee Compensation, as follows:

The school asbestos program manager, custodian, and clerical staff
hourly wages were $25.87, $14.06, and $15.69 for 2009, the most recent
year for which data are available.  They are based on the mean hourly
wages for Occupational Health and Safety Specialists and Technicians,
Building and Grounds Cleaning and Maintenance Occupations, and Office
and Administrative Support Occupations, respectively.  These wage rates
are specific to Elementary and Secondary Schools (NAICS 611100) and are
based on data from both public and private schools (BLS, 2010c).

According to the Employment Cost Index, wages and salaries rose by 1.7
percent during the period of May 2009 to May 2010 for these workers, and
wages and salaries used in this analysis have been increased by this
amount (BLS, 2010a).

According to the Employer Costs for Employee Compensation, wages and
salaries accounted for 65.9 percent of total compensation for school
employees as of September 2006.  Based on this information, a loading
factor of 1.517 (1/0.659) was applied to the mean hourly wage rate to
estimate total hourly compensation for school employees (BLS, 2010b).

The updated, estimated 2006 total hourly compensation for school
asbestos program manager, custodian, and clerical staff are $39.91,
$21.69, and $24.21, respectively.

These values were used in Worksheet 4 to calculate current recordkeeping
and reporting costs to schools with friable and/or nonfriable ACM, as
shown below.  In addition, schools are required to provide annual
notification to parents and other interested parties of the presence of
ACM, as well as the availability of the management plan for public
review.  The AHERA RIA estimated the annual notification cost to be $56
per school (EPA, 1987a).  This figure was updated to $93 in 2010 dollars
using the implicit price deflator for the Gross Domestic Product (GDP)
(Dept. of Commerce, 2010).

Worksheet 4 indicates that the annual reporting costs for schools range
from $525 for public primary schools or private schools with only
nonfriable ACM, to $1,649 for public secondary schools with friable ACM.

Worksheet 4: Annual Cost per Local Education Agency (2010$)

Activities

School Type

	Total Hourly Compensation	Public Primary and Private	Public Secondary

Schools With Friable Asbestos-Containing Materials

Implement Management Plan



	Asbestos program manager - Activity planning, create and gather
information, prepare activity reports, record and review information
$39.91	$399	$599

Custodial - Gather, record, process and store information	$21.69	$87
$174

Clerical - Gather, record, process and store information	$24.21	$387
$726

Total Management Plan

$873	$1,499



Implement Operations and Maintenance (O&M) Plan



	Asbestos program manager - Activity planning, create and gather
information, prepare activity reports, record and review information
$39.91	$80	$80

Custodial - Gather, record, process and store information	$21.69	$22	$22

Clerical - Gather, record, process and store information	$24.21	$48	$48

Total O&M Plan

$150	$150

Estimated Cost per School	$1,116	$1,649



Schools With Nonfriable Asbestos-Containing Materials Only

Implement Management Plan



	Asbestos program manager - Activity planning, create and gather
information, prepare activity reports, record and review information
$39.91	$200	$319

Custodial - Gather, record, process and store information	$21.69	$87
$174

Clerical - Gather, record, process and store information	$24.21	$145
$291

Estimated Cost per School	$525	$877

Source:  EPA.  1987.  AHERA Economic Impact Analysis; Table 11 and
Appendix G: "Second Year Implementation Costs."  Nonfriable ACM does not
require O&M. Cost per School includes $88 for Notification Costs.



States

As discussed in Section 6(a), states have no additional costs associated
with the Schools Rule.  Under the MAP Rule, state accreditation programs
are required at least to meet the standards of the revised MAP.  The
burden estimates associated with the MAP Rule are given in Section 6(a).
 No additional costs for materials were given in the Supplemental ICR
for the Asbestos-Containing Materials in Schools Rule (ICR #1365) (EPA,
1993).  Worksheet 5 shows the estimated annual cost of state compliance
with the MAP Rule is $4,436.

Wage rates were updated to 2010 using mean hourly wage rates from the
Bureau of Labor Statistics’ National Industry-Specific Occupational
Employment and Wage Estimates, the Employment Cost Index for wages and
salaries, and the Employer Costs for Employee Compensation, as follows:

The state managerial, technical, and clerical staff hourly wages for
2009, the most recent year for which data are available, were $37.74,
$27.15, and $17.88, based on the mean hourly wages for Management
Occupations, Environmental Scientists and Specialists, Including Health,
Office and Administrative Support Occupations, respectively.  These wage
rates are specific to State Government (NAICS 999200) (BLS, 2010c).

According to the Employment Cost Index, wages and salaries rose by 1.7
percent during the period of May 2009 to May 2010 for these workers, and
wages and salaries were inflated by this amount (BLS, 2010a).

According to the Employer Costs for Employee Compensation, wages and
salaries accounted for 65.9 percent of total compensation for state
employees as of December 2009.  Based on this information, a loading
factor of 1.517  (1.0/0.659) was applied to the mean hourly wage rate to
estimate total hourly compensation for school employees (BLS, 2010b).

The updated estimated 2010 total hourly compensation for state
managerial, technical, and clerical staff are $58.22, $41.89, and
$27.59, respectively.

Worksheet 5 shows the estimated annual cost of State compliance with the
MAP Rule is $4,436 per state.

Worksheet 5: Annual Cost per State/Territory (2010$)

	Labor Categories

	Activities	Management	Technical	Clerical	Total



	$58.22/hour	$41.89/hour	$27.59/our

	Implement a state accreditation program that is not less stringent than
the regulation	$466	

$963	$3,007

	Estimated Cost per State/Territory	$466	$963	$3,007	$4,436



Training Providers

The reporting and recordkeeping burden under the MAP Rule for asbestos
training providers is described in Section 6(a).  Providing access to
records is expected to take 5.5 hours per year per training provider,
and to be done by clerical staff.  Wage rates were updated to 2010 using
mean hourly wage rates from the Bureau of Labor Statistics’ National
Industry-Specific Occupational Employment and Wage Estimates, the
Employment Cost Index for wages and salaries, and the Employer Costs for
Employee Compensation, as follows: 

The training provider clerical staff hourly wage for 2009, the most
recent year for which data are available, was $16.48 based on the mean
hourly wage for Administrative Support Occupations.  This wage rates is
specific to Business Schools and Computer and Management Training (NAICS
611400) (BLS, 2010c).

According to the Employment Cost Index, wages and salaries rose by 1.6
percent during the period of May 2009 to May 2010 for these workers, and
wages and salaries were inflated by this amount (BLS, 2010a).

According to the Employer Costs for Employee Compensation, wages and
salaries accounted for 75.5 percent of total compensation for employees
of service producing private industry as of December 2009.  Based on
this information, a loading factor of 1.325 (1.0/0.755) was applied to
the mean hourly wage rate to estimate total hourly compensation for
training provider staff (BLS, 2010b).

The updated estimated 2010 total hourly compensation for training
provider clerical staff is $22.19.

In addition, training providers are expected to incur materials costs
associated with the annual recordkeeping requirements of the MAP Rule. 
Those costs were estimated to be $436 in the MAP Rule (EPA, 1993), which
was updated to $591 in the previous ICR.  This figure was again updated
to $628 in 2010 dollars using the implicit price deflator for the Gross
Domestic Product (GDP) (Dept. of Commerce, 2010).

Worksheet 6 shows the estimated annual cost of training provider
compliance with the MAP Rule is $750 per training provider.

Worksheet 6: Annual Cost per Training Provider (2010$)

	Labor Category	Freq/Year	Total

	Clerical



	$22.19/hour



Activities

1.  Retain records	N/A	N/A	$628

2.  Provide reasonable access to records to EPA or State	$11.10	11	$122

Estimated Cost per Provider	$11.10	11	$750

	

6(c) 	Estimating Agency Burden and Cost

Agency burden and cost estimates are presented in Worksheets 7 and 8.

EPA Burden

EPA conducts implementation activities associated with the Schools Rule.
 In the AHERA RIA (EPA, 1987a), EPA estimated that Federal
implementation of the Schools Rule would require the services of eight
full-time equivalent (FTEs) employees in the first year, four FTEs in
years two to four, and two FTEs in subsequent years.  Because the rule
is now past the initial four-year period, the remaining EPA burden from
implementing the Schools Rule is two FTEs annually.  This represents an
annual burden of 4,160 hours.

In addition, an estimated 220 hours per year of management and technical
labor are required to respond to questions about the MAP Rule.  The
annual burden from both rules combined is estimated to be 4,380 hours in
subsequent years.

The EPA regional burden associated with auditing training provider
courses and records is expected to be approximately 144 hours per year
per regional office.

Worksheet 7: Annual Agency Burden Estimates for EPA Headquarters and
Regional Offices (Hours)

Activity	Labor Category	Freq/ Year	Total



	Management	Technical



EPA Headquarters	

1.  Perform recordkeeping tasks under the Schools Rule	0	4,160	N/A	4,160

2.  Answer respondent questions about the MAP Rule	20	200	N/A	220

Total Headquarters	20	4,360

4,380

EPA Regional Offices	

1.  Audit training provider courses and records for compliance
monitoring purposes	0	8	18	144

Total per Region	0	8	18	144



EPA Costs

Consistent with previous ICRs, technical tasks are expected to be
completed by staff at the GS-13 level, and management tasks at the GS-15
level.  The 2010 GS-13 level, step 5 hourly compensation was $77.36 for
technical staff, while the 2006 GS-15 level, step 5 hourly compensation
was $107.54 for managerial staff (OPM, 2010).  These hourly rates
include the standard 60 percent loading factor for EPA personnel.

Estimates incorporating these hourly compensation rates and the burden
hour estimates from the previous section are shown in Worksheet 8. 
Total annual costs for EPA Headquarters are estimated at $339,441. 
Total annual costs for EPA Regional Offices are estimated at $11,140 per
region, or $111,400 for all 10 regions.



Worksheet 8: Annual Agency Cost Estimates for EPA Headquarters and
Regional Offices

(2010 $)

Activity

	Labor Category	Freq/Year	Total

	Management

$107.54/hour	Technical

$77.36/hour



EPA Headquarters

1.  Perform recordkeeping tasks under the Schools Rule	$0	$321,818	N/A
$321,818

2.  Answer respondent questions about the MAP Rule	$2,151	$15,472	N/A
$17,623

Total Headquarters	$2,151	$337,290

$339,441

EPA Regional Offices

1.  Audit training provider courses and records for compliance
monitoring purposes	$0	$619	18	$11,140

Total per Region	$0	$619	18	$11,140



6(d) 	Bottom Line Burden Hours and Costs

Table 4 and Appendix G of the AHERA RIA (EPA, 1987a), and Figure 2,
Addendum to ICR #2070-0091 Asbestos in Schools Rule (EPA, 1987b),
estimate the change in number of schools with friable and nonfriable ACM
over the implementation period of the rule.  The intent of the Schools
Rule is that all schools have a management plan, and that schools with
friable ACM also have an O&M plan.  The number of school respondents in
this ICR renewal is based on the average number of affected schools of
each type for years 23 through 25 of program implementation, which is an
extension of the method used in the previous ICR.  The total number of
public and private schools is based on 2007-2008 data obtained from the
U.S. Department of Education’s National Center for Education
Statistics (Dept of Education, 2010).

As in previous ICRs, the total number of training providers is estimated
using the latest National Directory of AHERA Accredited Courses,
compiled by EPA.  According to the most recent 2009 data available,
there are currently 1,268 accredited training providers (EPA, 2009). 
This is a significant increase from the previous ICR, in which there
were 636 accredited training providers listed.  Based on the unit burden
estimates from Section 6(a) and the unit cost estimates from Section
6(b), estimated annual recordkeeping burden for all training providers
is 6,974 hours and the estimated annual cost is $951,000.

The MAP rule affects all 50 states, the District of Columbia, and the
U.S. territories, for a total of 56 states and territories.  Based on
the unit burden estimates from Section 6(a) and the unit cost estimates
from Section 6(b), estimated annual recordkeeping burden for all states
and territories is 7,840 hours and the estimated annual cost is
$248,416.

Based on these estimates of numbers of respondents, unit costs, and
burdens, the total respondent and EPA tallies are shown in the following
tables.

(i) The respondent tally

Average Annual Respondent Aggregation Table

	Number of Entities	Unit Burden	Total Burden	Unit Cost	Total Cost

Local Education Agencies





	Schools with Friable ACM





	Public Primary	3,975	35	139,125	$1,116	$4,436,100

Public Secondary	2,341	58	135,778	$1,649	$3,860,309

Private	2,004	35	70,140	$1,116	$2,236,464

Schools with Nonfriable ACM





	Public Primary	64,293	15	964,395	$525	$33,753,825

Public Secondary	28,307	28	792,596	$877	$24,825,239

Private	31,736	15	476,040	$525	$16,661,400

Subtotal 	132,656

2,578,074

$85,773,337

Training Providers	1,268	5.5	6,974	$750	$951,000

States/Territories	56	140	7,840	$4,436	$248,416

Total	133,980

2,592,888

$86,972,753



(ii) The Agency tally

Average Annual Agency Aggregation Table

	Number of Entities	Unit Burden	Total Burden	Unit Cost	Total Cost

Headquarters	1	4,380	4,380	$339,441	$339,441

Regions	10	144	1,440	$11,140	$111,400

Total

	5,820

$450,841



6(e) 	Reasons For Change in Burden

The average estimated number of schools of each type in the three years
of this ICR renewal period (years 23 through 25 of the implementation
period) is used with the unit burden estimates to derive an annual
burden estimate.  This ICR renewal follows the same methods of
estimating numbers of schools with friable and nonfriable asbestos as
the previous ICR renewal.  

The total burden estimate for respondents has increased since the most
recently approved renewal of this ICR because of adjustments for Local
Education Agencies and Training Providers. While the numbers of schools
with friable ACM have declined, that decrease is less than the increase
in the number of schools with nonfriable ACM, resulting in higher totals
overall. The total annual burden for this information collection is
currently estimated to be 2,592,888 hours per year. This is a 2.3
percent increase above the annual burden of 2,530,600 hours in the most
recently approved clearance of this information collection request. Most
of this increase is associated with the increase in the number of
schools with nonfriable ACM. The number of training providers has almost
doubled since the previous ICR, but this has had only a small impact on
the overall burden from this data collection. 

Changes in Respondent Burden

	Burden Hour Estimates	Percent Change

Respondent Type	Previous	Current	Difference

	Local Education Agencies	2,519,262	2,578,074	58,812	2.3 %

Training Providers	3,498	6,974	3,476	99.4 %

States/Territories	7,840	7,840	0	0 %

Total	2,530,600	2,592,888	62,288	2.5 %



6(f)  	Burden Statement

The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0091, is estimated to be 20.15 hours
per response for schools, 140 hours per response for states, and 5.5
hours per response for training providers.  According to the Paperwork
Reduction Act, “burden” means the total time, effort, or financial
resources expended by persons to generate, maintain, retain, or disclose
or provide information to or for a Federal agency.  For this collection
it includes the time needed to review instructions; develop, acquire,
install, and utilize technology and systems for the purposes of
collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information;
adjust the existing ways to comply with any previously applicable
instructions and requirements; train personnel to be able to respond to
a collection of information; search data sources; complete and review
the collection of information; and transmit or otherwise disclose the
information.  An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a
currently valid OMB control number.  The OMB control number for this
information collection appears above.  The OMB control numbers for
EPA’s regulations in title 40 of the CFR, after appearing in the
Federal Register, are listed in 40 CFR part 9 and included on the
related collection instrument or form, if applicable.

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OPPT-2010-0568.  The docket is available for public viewing at
the Pollution Prevention and Toxics Docket in the EPA Docket Center
(EPA/DC).  The EPA/DC Public Reading Room is located in the EPA West
Building, Room 3334, 1301 Constitution Ave., NW., Washington, DC.  The
EPA/DC 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
EPA/DC Public Reading Room is (202) 566-1744, and the telephone number
for the Pollution Prevention and Toxics Docket is (202) 566-0280.  An
electronic version of the public docket is available through the Federal
Docket Management System (FDMS) at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov .  Use FDMS 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-OPPT-2010-0568 and OMB control number 2070-0091 in any
correspondence.

References

U.S. Bureau of Labor Statistics. 2010a. Employment Cost Index --- March
2010. News Release of April 30, 2010. Table 2. Employment Cost Index for
wages and salaries, by occupational group and industry. Web site
http://www.bls.gov/schedule/archives/eci_nr.htm. 

U.S. Bureau of Labor Statistics. 2010b. Employer Costs for Employee
Compensation ---December 2009. Table 3. Employer costs ... and costs as
a percent of total compensation: State and local government workers ....
Table 5. Employer costs ... and costs as a percent of total
compensation: Private industry workers .... News Release of March 10,
2010. Web site http://www.bls.gov/schedule/archives/ecec_nr.htm. 

U.S. Bureau of Labor Statistics. 2010c. Occupational Employment
Statistics: May 2009 National Industry-Specific Occupational Employment
and Wage Estimates. Web site     HYPERLINK
"http://www.bls.gov/oes/2009/may/naics4_611400.htm for NAICS 611400" 
http://www.bls.gov/oes/2009/may/naics4_611400.htm for NAICS 611400  and
SOCs 29-9011, 37-0000, and 43-0000;   HYPERLINK
"http://www.bls.gov/oes/2009/may/naics4_611100.htm for NAICS 611100" 
http://www.bls.gov/oes/2009/may/naics4_611100.htm for NAICS 611100  and
SOCs 11-0000 and 43-0000; and   HYPERLINK
"http://www.bls.gov/oes/2009/may/naics4_999200.htm for NAICS 999200" 
http://www.bls.gov/oes/2009/may/naics4_999200.htm for NAICS 999200  and
SOCs 11-0000, 19-2041, and 43-0000. 

U.S. Department of Commerce. 2010.  Bureau of Economic Analysis.  Gross
Domestic Product:

Implicit Price Deflator. Accessed through the Saint Louis Federal
Reserve Bank at
http://research.stlouisfed.org/fred2/series/GDPDEF/downloaddata?cid=21.
Series ID GDPDEF, Gross Domestic Product Implicit Price Deflator.  Index
2005=100.   

U.S. Department of Education.  April 2010.  National Center for
Education Statistics.  Digest of Education Statistics: 2009.  Table 86:
Number of public school districts and public and private elementary and
secondary schools.  Web site
http://nces.ed.gov/programs/digest/d09/tables/dt09_086.asp 

 

U.S. EPA. 1987a.  Office of Toxic Substances, Economics and Technology
Division. Asbestos

Hazard Emergency Response Act Regulatory Impact Analysis. September,
1987.

U.S. EPA. 1987b.  Office of Pesticides and Toxic Substances.  Addendum
to ICR #2070-0091 

Asbestos-In-Schools Rule. October, 1987.

U.S. EPA. 1991. ICR Renewal for the Asbestos Hazard Emergency Response
Act (AHERA),

Title II of the Toxic Substances Control Act (TSCA) -
Asbestos-Containing Materials in Schools Rule. OMB No. 2070-0091. EPA
ICR #1365.

U.S. EPA. 1993. Supplemental ICR for the Asbestos-Containing Materials
in Schools Rule. 

OMB No. 2070-0091. EPA ICR #1365.

U.S. EPA. 1994. Renewal ICR for the Asbestos-Containing Materials in
Schools Rule. OMB No.  2070-0091. EPA ICR #1365.

U.S. EPA. 1997. Renewal ICR for the Asbestos-Containing Materials in
Schools Rule. OMB No.

2070-0091. EPA ICR #1365.

U.S. EPA. 2001. Renewal ICR for the Asbestos-Containing Materials in
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2070-0091. EPA ICR #1365.

U.S. EPA. 2004.  Renewal ICR for the Asbestos-Containing Materials in
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No. 2070-0091. EPA ICR #1365.

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No. 2070-0091. EPA ICR #1365.

U.S. EPA. 2009. Office of Pollution Prevention and Toxics. . National
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June 2009. Web site http://www.epa.gov/asbestos/pubs/provname.pdf.

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  HYPERLINK "http://www.opm.gov/oca/06tables/html/dcb.asp" 
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ATTACHMENTS:

Attachment A	Asbestos Hazard Emergency Response Act, Section 203

Attachment B		Asbestos Hazard Emergency Response Act, Section 206

Attachment C	Asbestos-Containing Materials in Schools Rule (40 CFR 763,
Subpart E)

Attachment D	Model Accreditation Plan (40 CFR 763, Subpart E, Appendix
C)

Attachment E           Worksheet A-1: Annual Recordkeeping Burden, by
School Type and      Asbestos Type, Revised for Years 20 through 22 

Worksheet A-2:  Annual Recordkeeping Cost, by School Type and Asbestos
Type, Revised for Years 20 through 22 

Attachment F		Copies of Consultation Letters Sent and Received

 The wage figure used for Occupational Health and Safety Specialists and
Technicians is a weighted average, by employment, of the wages for the
separate groups of Specialists and Technicians, and is for Local
Government specifically. 

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