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

The Paperwork Reduction Act

IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title and Number of the Information Collection

		Title:	Lead-Based Paint Pre-Renovation Information Dissemination – 

			TSCA Sec. 406(b)

		EPA ICR No.:   1669.06	OMB Control No.:	2070-0158

1(b)	Short Characterization

Section 406(b) of Title IV of the Toxic Substances Control Act (TSCA)
(15 U.S.C. 2686) requires the U.S. Environmental Protection Agency (EPA)
to promulgate regulations requiring certain persons who perform
renovations of target housing for compensation to provide a lead hazard
information pamphlet (developed under section 406(a) of TSCA) to the
owner and occupant of such housing no more than 60-days prior to
commencing the renovation.  Section 401 of TSCA defines target housing
as any housing constructed before 1978 except housing for the elderly or
disabled or 0-bedroom dwellings.  Those who fail to provide the
pamphlet, as required, may be subject to both civil and criminal
sanctions under section 16 of TSCA.

	Pursuant to Title IV of TSCA, EPA promulgated regulations applicable to
all renovations of target housing or child-occupied facilities performed
for compensation, except as otherwise specified, at 40 CFR part 745,
subpart E.  The regulations in 40 CFR part 745, subpart E, cover
information distribution requirements, work practice standards,
reporting requirements, and individual and firm certifications, among
other things.  This ICR amendment only addresses the information
distribution requirements which require firms performing renovations to
provide the owner and occupant of any residential dwelling unit or
multi-unit housing with a lead hazard information pamphlet.  After
providing the pamphlet to the owner and occupant and obtaining written
acknowledgment, the firm performing the renovation must keep
acknowledgment records on file for three years after completion of work.

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

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

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

	The following paragraphs describe the activities that firms performing
renovations would take under the information distribution requirements
at 40 CFR part 745, subpart E.

Exemption from Information Distribution Requirements

	Under 40 CFR 745.82, firms performing renovations of target housing or
child-occupied facilities for compensation are not subject to the
regulations in 40 CFR 745.84 if the renovation activities are limited
to: (i) minor repair and maintenance activities (including minor
electrical work and plumbing) that disrupt six square feet or less of
painted surface per room for interior activities or twenty square feet
or less of painted surface for exterior activities where no prohibited
or restricted practices are used and where the work does not involve
window replacement or demolition of painted surfaces; (ii) emergency
renovation operations; (iii) renovations in target housing or
child-occupied facilities in which a written determination has been made
by an inspector (certified pursuant to either Federal regulations at 40
CFR 745.226 or a State or Tribal certification program authorized
pursuant to 40 CFR 745.324) that the components affected by the
renovation are free of paint or other surface coatings that contain lead
equal to or in excess of 1.0 milligram per square centimeter or 0.5
percent by weight, where the firm has obtained a copy of the
determination; or (iv) renovations in target housing or child-occupied
facilities in which a certified renovator, using an EPA recognized test
kit has tested each component affected by the renovation and determined
that  the components are free of paint or other surface coating
containing lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.

Information Distribution Requirements for Renovations in Dwelling Units

	Under 40 CFR 745.84(a), no more than 60 days before beginning
renovation activities in any residential dwelling unit of target
housing, firms performing renovations must provide the owner of the
dwelling unit with the pamphlet, and must comply with the procedures
specified at section 745.84(a)(1)(i) or (ii).  In addition, if the owner
does not occupy the dwelling unit, the renovation firm must provide an
adult occupant of the unit with the pamphlet, and comply with the
procedures specified at section 745.84(a)(2)(i) or (ii).

	Information Distribution Requirements for Renovations in Common Areas

	Under 40 CFR 745.84(b), no more than 60 days before beginning
renovation activities in common areas of multi-unit target housing, a
firm performing renovations must provide the owner of the multi-unit
housing with the pamphlet, and comply with the procedures specified at
section 745.84(b)(1)(i) or (ii).

	In addition, the firm performing renovations must (i) notify in
writing, or ensure written notification of, each affected unit and make
the pamphlet available upon request prior to the start of renovation.
Such notification shall be accomplished by distributing written notice
to each affected unit. The notice shall describe the general nature and
locations of the planned renovation activities; the expected starting
and ending dates; and a statement of how the occupant can obtain the
pamphlet and a copy of the records required by § 745.86(c) and (d), at
no cost to the occupants, or (ii) While the renovation is ongoing, post
informational signs describing the general nature and locations of the
renovation and the anticipated completion date. These signs must be
posted in areas where they are likely to be seen by the occupants of all
of the affected units. The signs must be accompanied by a posted copy of
the pamphlet or information on how interested occupants can review a
copy of the pamphlet or obtain a copy from the renovation firm at no
cost to occupants. The signs must also include information on how
interested occupants can review a copy of the records required by
section 745.86(c) and (d) or obtain a copy from the renovation firm at
no cost to the occupants.  (Section 745.84(b)(2)).

	The firm performing renovations also must prepare, sign, and date a
statement describing the steps performed to notify all occupants of the
intended renovation activities and to provide the pamphlet (section
745.84(b)(3)).  If the scope, locations, or expected starting and ending
dates of the planned renovation activities change after the initial
notification, the firm performing the renovation must provide further
written notification to the owners and occupants providing revised
information on the ongoing or planned activities.  This subsequent
notification must be provided before the firm performing the renovation
initiates work beyond that which was described in the original notice
(section 745.84(b)(4)).

Recordkeeping Requirements

	Under 40 CFR 745.86(a), form performing renovations must retain and, if
requested, make available to EPA all records necessary to demonstrate
compliance with the requirements of 40 CFR part 745, subpart E, for a
period of three years following completion of the renovation activities
in target housing or child-occupied facilities.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	Need and Authority for the Collection

	Section 406(b) of TSCA requires EPA to promulgate regulations requiring
certain persons who perform renovations of target housing for
compensation to provide a lead hazard information pamphlet to the owner
and occupant of such housing prior to commencing the renovation. 
Regulations promulgated under the authority of section 406(b) ensure
that owners and occupants of target housing are provided information
concerning potential hazards of lead-based paint exposure before certain
renovations are begun on that housing.  The Agency believes that the
distribution of the pamphlet will help to reduce the exposures that
cause serious lead poisonings, especially in children under age six, who
are particularly susceptible to the hazards of lead.

2(b)	Practical Utility and Users of the Data

	Owners and occupants of target housing and child-occupied facilities
must be provided with a lead hazard information pamphlet before any
renovation commences.  Information contained in the lead hazard
information pamphlet may be used by owners and occupants of target
housing and child-occupied facilities to take appropriate precautions to
avoid exposure to lead-contaminated dust and lead-based paint debris
that are sometimes generated during renovations.

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

3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Non-Duplication

	EPA has determined that no other Federal agency collection satisfies
the statutory requirements of section 406(b) of TSCA.

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

  SEQ CHAPTER \h \r 1 	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

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

	The information distribution requirements at 40 CFR part 745, subpart
E, do not include any reporting requirements, only recordkeeping
requirements.  Therefore, a collection schedule is not applicable.

3(e)	General Guidelines

	This collection does not exceed any of the Paperwork Reduction Act
guidelines at 5 CFR 1320.5.

	3(f)	Confidentiality

	Since this ICR involves only recordkeeping and 3rd-pary notifications,
EPA does not believe that respondents submit any information to the
Agency or that, in doing so, they would  assert a confidentiality claim
for information collected under this ICR.  However, to the extent
information submitted by respondents is business confidential,
procedures are in place to protect the information from improper
disclosure consistent with section 14 of TSCA; 40 CFR part 2, subpart B;
and 40 CFR 745.84.

	3(g)	Sensitive Questions

	No questions of a sensitive nature are included in the information
collection requirements associated with the distribution of the lead
hazard information pamphlet.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a)	Respondents and NAICS Codes

	The North American Industrial Classification System (NAICS) codes
associated with industries most likely affected by the requirements
covered in this ICR are described below:



NAICS Code	Industrial Sector

23321	Single Family Housing Construction

23322	Multifamily Housing Construction

23511	Plumbing, Heating, and Air-Conditioning Contractors

23521	Painting and Wall Covering Contractors

23531	Electrical Contractors

23541	Masonry and Stone Contractors

23542	Drywall, Plastering, Acoustical, and Insulation Contractors

23543	Tile, Marble, Terrazzo, and Mosaic Contractors

23551	Carpentry Contractors

23552	Floor Laying and Other Floor Contractors

23561	Roofing, Siding, and Sheet Metal Contractors

23571	Concrete Contractors

23581	Water Well Drilling Contractors

23591	Structural Steel Erection Contractors

23592	Glass and Glazing Contractors

23593	Excavation Contractors

23594	Wrecking and Demolition Contractors

23595	Building Equipment and Other Machinery Installation Contractors

23599	All Other Special Trade Contractors

53111	Lessors of Residential Buildings and Dwellings

53119	Lessors of Other Real Estate Property

53121	Offices of Real Estate Agents and Brokers

531311	Residential Property Managers

53132	Offices of Real Estate Appraisers

53139	Other Activities Related to Real Estate

611110	Elementary and Secondary Schools

624410	Child Day Care Services



4(b)	Information Requested

	In the following paragraphs, EPA describes the paperwork requirements
associated with the distribution of the lead hazard information
pamphlet.

Exemption from Information Distribution Requirements

	Under 40 CFR 745.82, firms performing renovations of target housing or
child-occupied facilities for compensation are not subject to the
regulations in 40 CFR 745.84 if the renovation activities are limited
to: (i) minor repair and maintenance activities (including minor
electrical work and plumbing) that disrupt six square feet or less of
painted surface per room for interior activities or twenty square feet
or less of painted surface for exterior activities where no prohibited
or restricted practices are used and where the work does not involve
window replacement or demolition of painted surfaces; (ii) emergency
renovation operations; (iii) renovations in target housing or
child-occupied facilities in which a written determination has been made
by an inspector (certified pursuant to either Federal regulations at 40
CFR 745.226 or a State or Tribal certification program authorized
pursuant to 40 CFR 745.324) that the components affected by the
renovation are free of paint or other surface coatings that contain lead
equal to or in excess of 1.0 milligram per square centimeter or 0.5
percent by weight, where the renovator has obtained a copy of the
determination; or (iv) renovations in target housing or child-occupied
facilities in which a certified renovator, using an EPA recognized test
kit has tested each component affected by the renovation and determined
that  the components are free of paint or other surface coating
containing lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.

(i)	Data Items:

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

(ii)	Respondent Activity:

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

	Information Distribution Requirements for Renovation in Dwelling Units

	Under 40 CFR 745.84(a), no more than 60 days before beginning
renovation activities in any residential dwelling unit of target
housing, a firm performing renovations must provide the owner of the
dwelling unit with the pamphlet, and must comply with the procedures
specified at section 745.84(a)(1)(i) or (ii).  In addition, if the owner
does not occupy the dwelling unit, the firm performing renovations must
provide an adult occupant of the unit with the pamphlet, and comply with
the procedures specified at section 745.84(a)(2)(i) or (ii).

(i)	Data Items:

Lead hazard information pamphlet; and

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

(ii)	Respondent Activities:

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

Prepare acknowledgment and certification forms;

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

Obtaining, from the owner, a written acknowledgment that the owner has
received the pamphlet (section 745.84(a)(1)(i)); or

Obtaining a certificate of mailing at least seven days prior to the
renovation (section 745.84(a)(1)(ii)).

	In addition, if the owner does not occupy the dwelling unit, the firm
performing renovations also must:

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

Obtaining, from the adult occupant, a written acknowledgment that the
occupant has received the pamphlet (section 745.84(a)(2)(i)); or

Certifying in writing that a pamphlet has been delivered to the dwelling
and that the firm performing renovations has been unsuccessful in
obtaining a written acknowledgment from an adult occupant (section
745.84(a)(2)(i)); or

Obtaining a certificate of mailing at least seven days prior to the
renovation (section 745.84(a)(2)(ii)).

	Information Distribution Requirements for Renovations in Common Areas

	Under 40 CFR 745.84(b), no more than 60 days before beginning
renovation activities in common areas of multi-unit housing, a firm
performing renovations must provide the owner of the multi-unit housing
with a lead hazard information pamphlet, and comply with the procedures
specified at section 745.84(b)(1)(i) or (ii).  In addition, the firm
performing renovations must notify in writing, or ensure written
notification of, each affected unit and make the pamphlet available upon
request prior to the start of the renovation.  Such notification shall
be accomplished by distributing written notice to each affected unit
(section 745.84(b)(2)).  Finally, firm performing renovations must
prepare, sign, and date a statement describing the steps performed to
notify all occupants of the intended renovation activities and to
provide the pamphlet (section 745.84(b)(3)).

(i)	Data Items:

Lead hazard information pamphlet;

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

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

(ii)	Respondent Activities:

	A firm performing renovations planning to conduct renovations in common
areas of multi-unit housing must:

Prepare acknowledgment and certification forms;

Provide the owner of multi-unit target housing unit with the pamphlet
and obtain proof that the pamphlet was provided to the owner of the
target housing by:

Obtaining, from the owner, a written acknowledgment that the owner has
received the pamphlet (section 745.84(b)(1)(i)); or

Obtaining a certificate of mailing at least seven days prior to the
renovation (section 745.84(b)(1)(ii));

Notify in writing, or ensure written notification of, each affected unit
of the multi-unit housing and make the pamphlet available upon request
no more than 60-days prior to the start of the renovation;

Prepare, sign, and date a statement describing the steps performed to
notify all occupants of the intended renovation activities and to
provide the pamphlet (section 745.84(b)(3)); and

If the scope, locations, or expected starting and ending dates of the
planned renovation activities change after the initial notification,
provide further written notification to the owners and occupants
providing revised information on the ongoing or planned activities
(section 745.84(b)(4)).

Recordkeeping Requirements

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

(i)	Data Items:

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

Reports certifying that a determination has been made by an inspector
that lead-based paint is not present on the components affected by the
renovation, as described in section 745.82(a);

Signed and dated acknowledgments of receipt as described in sections
745.84(a)(1)(i), (a)(2)(i), (b)(1)(i) (c)(i)(A) and (c)(1)(ii)(A).;

Certifications of attempted delivery as described in section
745.84(a)(2)(i) and (c)(1)(ii)(A);

Certificates of mailing as described in sections 745.84(a)(1)(ii),
(a)(2)(ii), (b)(1)(ii), (c)(1)(i)(B, and (c)(1)(ii)(B); and; and

Records of notification activities performed regarding common area
renovations, as described in sections 745.84(b)(3) and (b)(4) .

(ii)	Respondent Activities:

	Firms performing renovations must maintain records to demonstrate
compliance with the requirements of 40 CFR part 745, subpart E, for a
period of three years following completion of the renovation.

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

5(a)	Agency Activities

	There are no Agency activities associated with the distribution of lead
hazard information pamphlets to owners and occupants of target housing
and child-occupied facilities prior to commencing renovations for
compensation.

	5(b)	Collection Methodology and Management	

	There are no Agency activities associated with the distribution of the
lead hazard information pamphlet to owners and occupants of target
housing and child-occupied facilities prior to commencing renovations
for compensation.  However, under the provisions of 40 CFR 745.87, EPA
may conduct inspections and issue subpoenas pursuant to the provisions
of TSCA section 11 (15 U.S.C. 2610) to ensure compliance with 40 CFR
part 745, subpart E.

	5(c)	Small Entity Flexibility

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

	5(d)	Collection Schedule

	The information distribution requirements at 40 CFR part 745, subpart
E, do not include any reporting requirements, only recordkeeping
requirements.  Therefore, a collection schedule is not applicable.

6.	ESTIMATING BURDEN AND COST OF THE COLLECTION

	This section estimates the incremental burden of reporting and
recordkeeping for the requirements under TSCA section 406(b).  Estimates
for the time (i.e., burden hours) incurred by respondents in complying
with the reporting and recordkeeping requirements were based on
conversations with renovation contractors, building trades groups, and
rental property owners and managers, as reflected in the supporting
statement for the 2008 renewal of this ICR (EPA ICR No. 1669.05).  The
estimates of the number of entities subject to the rule’s requirements
are based on information in 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 (EPA 2008), also
referred to as the Economic Analysis for the RRP rule, and 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 2010), also referred to as the Economic
Analysis for the Opt-out rule.  

	6(a)	Estimating Respondent Burden

	This ICR presents the estimated annual burden and associated annual
costs for the following information collection components of the
pre-renovation information dissemination program:

Prepare Information – Firms performing renovations, including property
managers of rental housing or child-occupied facilities (COFs) doing
their own renovations, must obtain the required pamphlet, prepare the
required acknowledgment/certification form, and prepare the required
notification of renovation activities in the common areas of multi-unit
target housing or in COFs. Firms performing renovations, including
owner/managers, are also required to prepare, sign, and date a statement
describing the steps performed to notify occupants of the intended
renovation activities.

Provide Information – Firms performing renovations, including
owner/managers of rental housing or COFs doing their own renovations,
must provide the owner/occupant with a copy of the pamphlet and document
receipt of the pamphlet by having the owner/occupant sign the
acknowledgment.  In the case of the notification, firms performing
renovations, including owner/managers, must provide notification for
renovation activities in common areas of multi-unit target housing or in
COFs.

Maintain Records – Firms performing renovations, including
owner/managers of rental housing doing their own renovations, must
retain the documentation of distribution, e.g., certification by
owner/occupant.

The pre-renovation education requirements do not apply to events where a
test kit indicates that lead-based paint is not present.  Therefore, it
is assumed that pre-renovation education costs are only incurred for
events where lead-safe work practices (LSWP) are used.  The number of
LSWP events performed was calculated using the approach described in
detail in the cost chapters of the economic analyses for the RRP rule
(EPA 2008) and the Opt-out rule (EPA 2010).  However, unlike the
previous analysis, this ICR renewal analysis is calculated based on a 43
percent average false positive rate for EPA approved test kits for
lead-based paint.  The 43 percent false positive rate assumes that the
test kit market will be split evenly between currently approved kits
that have a false positive rate averaging 22 percent and those that have
a 63 percent average false positive rate.  If EPA recognizes test kits
that meet the false positive response criteria at 40 CFR 745.88 during
the three year period covered by this ICR, the number of responses (and
thus the total estimated respondent burden and cost) will be less than
estimated in this renewal ICR.  Thus, the burden and cost calculations
in this ICR analysis may represent conservative estimates.

For the ICR burden analysis, the average number of responses per
respondent for each category of respondents and activities was estimated
by dividing the total number of annual responses in that activity
(derived by adjusting the estimates in the previous economic analyses)
by the total number of respondents.

Specific steps required to comply with the pre-renovation education
requirements are affected by such factors as whether the renovation is
performed in an owner-occupied building or a rental building, and
whether the work is performed by a contractor or by in-house staff. 
Therefore, the ICR burden analysis is calculated separately for each of
these scenarios.   The analysis begins by discussing the number of
renovation events in target housing where pre-renovation education is
required, followed by a discussion of renovation events in COFs.  

(i)  Events Taking Place in Target Housing

	There are 278,183 respondents (i.e. renovators and rental property
managers) estimated to work in target housing during the three year
period covered by this ICR.  This represents 167,669 renovation firms
and property managers estimated to work in target housing regulated by
the 2008 RRP rule and an additional 110,514 renovation firms estimated
to work in target housing regulated by the 2010 Opt-out rule. 

The pre-renovation education requirements do not apply to events where a
test kit indicates that lead-based paint is not present.  Therefore, it
is assumed that pre-renovation education costs are only incurred for
renovation events where LSWP are used.  The number of LSWP events
performed by landlords and contractors in owner-occupied and rental
target housing was calculated based on the approach described in detail
in the cost chapters of the economic analyses for the RRP rule (EPA
2008) and the Opt-out rule (EPA 2010).  

	This approach estimates an average of 905,610 LSWP renovation events in
owner-occupied housing as a result of the 2008 RRP rule and 4,463,986
LSWP renovation events as a result of the 2010 Opt-out rule, for a total
three-year average of 5,369,596 renovation events per year in
owner-occupied target housing.  

The rule’s requirements in rental housing differ depending on whether
the renovation occurs in an occupied unit, an unoccupied unit, or a
common area shared by tenants in multi-unit housing.  Renovation events
occurring in occupied rental units require firms performing renovations
to prepare acknowledgment forms for, distribute pamphlets to, and obtain
acknowledgments from, both the owner and the tenant of the unit.  On the
other hand, when renovation events take place in unoccupied units or
common areas, these activities (prepare certification form, distribute
pamphlet, and obtain acknowledgment) apply only to owners of the unit. 
For occupants affected by common area renovations, firms performing
renovations are required to ensure written notification of the intended
renovation activity and, if requested, make the pamphlet available to
any tenants making such a request.  The firm performing renovation must
also document this disclosure activity by preparing a written statement
describing the steps performed to notify all occupants of the intended
renovation activities.  This ICR analysis assumes property owners will
post a single copy of the pamphlet in affected common areas, thereby
making the information available to any interested tenants.  

	The Regulatory Impact Analysis for the 406(b) rule concluded that most
renovation activities occur while the unit is vacant in between tenants.
 EPA assumes that only one fourth of the renovations in rental property
will occur while the unit is occupied.  When applied to the estimate
that there are there are an average of 5,789,495 LSWP renovations per
year in rental target housing, this results in an estimate that the
notification provisions of the TSCA section 406(b) rule will apply to
1,447,374 renovations per year in occupied rental units and 4,342,121
renovations per year in vacant units and in common areas.  

As shown in   REF _Ref269986704 \h  \* MERGEFORMAT  Exhibit 6.1 , there
is an average of 11,159,091 LSWP events per year in target housing
affected by the rule.  

	

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  1 : Summary of Renovation Events
in Target Housing



	Year 1	Year 2	Year 3	Average

Owner-Occupied Target Housing

Regulated under the 2008 RRP rule	909,333	905,605	901,892	905,610

Regulated under the 2010 Opt-out rule	4,482,338	4,463,961	4,445,658
4,463,986

Subtotal – Owner-Occupied Events	5,391,671	5,369,566	5,347,550
5,369,596

Rental Target Housing

Occupied Units	1,453,324	1,447,366	1,441,431	1,447,374

Vacant Units and Common Areas	4,359,972	4,342,096	4,324,294	4,342,121

Subtotal – Rental Events	5,813,296	5,789,462	5,765,725	5,789,495

Total Events	11,204,967	11,159,028	11,113,275	11,159,091

Sources: Economic Analysis for the 2008 RRP rule; Economic Analysis for
the 2010 Opt-out rule



  REF _Ref271720414 \h  \* MERGEFORMAT  Exhibit 6.2  shows the
three-year average annual number of respondents and number of responses
by type for the pre-renovation education requirements in target housing.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  2 : Average Annual Number of
Pre-Renovation Education Respondents and Responses for Renovation Work
in Target Housing



	Number of Small Respondents	Number of Respondents	Number of Responses



Owner-Occupied Events	276,119	278,183	5,369,596

Rental Events in Occupied Units	276,119	278,183	1,447,374

Rental Events in Vacant Units and Common Areas	276,119	278,183	4,342,121

Total	276,119	278,183	11,159,091

Sources:  Economic Analysis for the RRP rule (EPA 2008); Economic
Analysis for the Opt-out rule (EPA 2010).



(ii)  Events Taking Place in Public or Commercial Building COFs

	In addition to the change in target housing renovation events, this ICR
includes burden and material cost estimates related to renovations
taking place in public or commercial building child-occupied facilities.
 The 2008 RRP rule extended the pre-renovation information dissemination
requirements to renovation projects performed by contractors or
landlords in public or commercial building COFs.  (The burden estimates
for these entities relating to the pre-renovation education requirements
of the 2008 RRP rule were previously included in ICR 1715.10, but are
now being included in this ICR so that all of the pre-renovation
information dissemination requirements under 406(b) are accounted for in
a single ICR).  This analysis assumes that contractors will work both in
COFs that rent space, and in those that own space.  Landlords will only
work in the buildings that they own.

	Since the pre-renovation education requirements do not apply to events
where a test kit indicates that lead-based paint is not present,
pre-renovation education costs are only incurred for events where LSWP
are used.  The number of LSWP events performed by landlords and
contractors in COFs was calculated using the approach described in
detail in Section 4.4 of the Economic Analysis for the RRP rule (EPA
2008).  The analysis described in Section 4.4 estimated the percentage
of events (by event and facility type) performed by landlords,
contractors, and by the staff of COFs themselves, and the results are
presented in Table 4-91 (EPA 2008).  This ICR analysis applies the
percentages in Table 4-91 to the numbers of LSWP events performed in
each type of COF (see Section 4.4 of Chapter 4 in EPA 2008) to estimate
the number of events where contractors and landlords will need to
distribute pamphlet(s) and obtain proof of pamphlet receipt prior to
beginning renovation work.

(A)  Number of COF Landlord Firms and Events

Landlords are required to comply with the pre-renovation education rule
during each LSWP event they perform.    REF _Ref159223958 \h  \*
MERGEFORMAT  Exhibit 6.3  presents the number of lessor/manager firms
renting space to COFs and the numbers of LSWP events performed by these
firms each year during the first three years of the rule.  There are
13,170 non-residential property manager or lessor firms estimated to
rent space to COFs annually during the reporting period, and they
perform an average of 4,341 LSWP events per year.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  3 : Number of Non-Residential
Property Manager Firms and LSWP Events They Perform



	Year 1	Year 2	Year 3	Average

Number of Lessor/Manager Firms	13,224	13,170	13,116	13,170

Number of LSWP Events Performed	4,359	4,341	4,323	4,341

Source(s): Economic Analysis for the RRP rule (EPA 2008).



(B)  Number of COF Contractor Firms and Events

The number of LSWP events performed by contractors in public or
commercial building COFs was estimated by applying the percentages of
all RRP events performed by contractors in schools and daycare centers
to the total number of LSWP events performed in these buildings in a
given year.  These estimates are based on the number of events
calculated for the Economic Analysis for the RRP rule (EPA 2008). 
Section 4.4 of the Economic Analysis for the RRP rule (EPA 2008)
presents the estimated percentages of RRP events, by event and facility
type, performed by landlords, contractors, and by the COFs themselves.  

  REF _Ref159223974 \h  \* MERGEFORMAT  Exhibit 6.4  presents the number
of events performed by contractors in the first, second, and third years
of the rule in schools, in daycare centers that own their space and in
daycare centers that rent their space.    REF _Ref271710478 \h  \*
MERGEFORMAT  Exhibit 6.5  presents the number of contractor firms
performing work in public or commercial building COFs, and the total
number of those events.  It is estimated that an annual average of 3,197
contractor firms will perform renovations in public or commercial
building COFs that require LSWP.  These contractors will perform an
annual average of 115,721 renovation events that require LSWP in public
or commercial building COFs.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  4 : Number of Contractor LSWP
Events by COF Type

Type of COF	Number of Events Performed by Contractors

	Year 1	Year 2	Year 3	

Average

Public and Private Schoolsa	93,561	93,178	92,795	93,178

Daycare Centers that Own their Spaceb	16,395	16,328	16,261	16,328

     Sub-total in Owner-Occupied COFs	109,956	109,506	109,056	109,506

Daycare Centers that Rent their Spacec	6,241	6,215	6,189	6,215

     Sub-total in COFs that Rent Space	6,241	6,215	6,189	6,215

Total Events	116,197	115,721	115,245	115,721

Notes:

All schools are assumed to own their buildings.

The number of events in daycare centers that own their space is
calculated as the difference between the number of contractor events in
all daycare centers and the number of events in daycare centers that
rent their space.  See Section 4.4 of the Economic Analysis for the RRP
rule (EPA 2008).  

The number of centers renting space was estimated using data from
DOE’s Commercial Building Energy Consumption Survey (CBECS).  HUD data
were used to determine the percentages of work being contracted out. 
See Section 4.4 of the Economic Analysis for the RRP rule (EPA 2008).   


Sources:  Economic Analysis for the RRP rule (EPA 2008). 



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



	Year 1	Year 2	Year 3	Average

Number of Contractor Firms	3,210	3,197	3,183	3,197

Number of LSWP Events Performed	116,197	115,721	115,245	115,721

Source(s): Economic Analysis for the RRP rule (EPA 2008).



(C)  Number of COF Renovation Events Performed In-House by Daycare
Centers and Schools

 

In addition to events performed by landlords and contractors, daycare
centers and schools are expected to perform some renovation events using
in-house staff.  These entities are assumed to comply with the rule by
posting informational signs describing the general nature and locations
of the project, the anticipated completion date, and a copy of the lead
safety pamphlet in a location accessible to parents and guardians.   
REF _Ref271715511 \h  \* MERGEFORMAT  Exhibit 6.6  presents the number
of daycare centers and schools, and the number of in-house events they
perform.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  6 : Number of Entities and Events
for Daycare Centers and Schools Performing In-House Work



	Year 1	Year 2	Year 3	Average

Number of Daycare Centers and Schools	26,062	25,954	25,847	25,954

Number of LSWP Events Performed	61,747	61,494	61,241	61,494

Source(s): Economic Analysis for the RRP rule (EPA 2008).



  REF _Ref191371725 \h  \* MERGEFORMAT  Exhibit 6.7  shows the
three-year average annual number of respondents to the pre-renovation
education requirements in public or commercial building COFs.  Landlords
and contractors working in public or commercial building COFs that own
their buildings comprise a single category, as both must notify only the
COF operator.  Contractors working in COFs that rent their space
constitute a second category, as they must notify both the COF operator
and the owner of the building.  The same set of contractors performs
work in both renter- and owner-occupied COFs; therefore, the 3,197
contractors performing work in renter COFs are included in both
categories.  Daycare centers and schools performing renovations using
in-house staff make up the third group, as they are only required to
post informational signs (including the lead safety pamphlet) that are
accessible to parents and guardians.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  7 : Average Annual Number of
Pre-Renovation Education Respondents and Responses for Renovation Work
in COFs



	Number of Small Respondents	Number of Respondents	Number of Responses

Landlords working in renter COFs and Contractors working in owner COFs  

(Private Entities)	15,242	16,367	113,847

Contractors working in renter COFs 

(Private Entities)	3,137	3,197	6,215

Daycare Centers and Schools Performing Own Renovations 

Private Entities

State/Local Governments	18,236

7,138	18,236

7,718	25,212

36,282

Sources:  Economic Analysis for the RRP rule (EPA 2008).



(D)  Total Number of Respondents and Responses 

The total number of respondents and responses are shown in   REF
_Ref280275970 \h  \* MERGEFORMAT  Exhibit 6.8  and   REF _Ref280275981
\h  \* MERGEFORMAT  Exhibit 6.9 .  This represents a decrease in the
estimated number of respondents and responses compared to the previously
approved ICR.  The reason for the decrease is that the approach for
calculating the number of target housing renovation events has been
updated to reflect a more recent methodology which was used in the
economic analysis of the 2008 RRP rule.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  8 :  Total Respondents



 Type of Respondent	Year 1	Year 2	Year 3	Average

Contractors and rental property managers working in Target Housing
279,327	278,182	277,041	278,183

Landlords working in COFs  	13,224	13,170	13,116	13,170

Contractors working in COFs	3,210	3,197	3,183	3,197

Daycare Centers and Schools Performing Own Renovations	26,062	25,954
25,847	25,954

Total 	321,823	320,503	319,187	320,504



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  9 :  Total Responses



 Renovation Events	Year 1	Year 2	Year 3	Average

Target Housing	11,204,967	11,159,028	11,113,275	11,159,090

COFs – Landlord Firms	4,359	4,341	4,323	4,341

COFs – Contractor Firms	116,197	115,721	115,245	115,721

COFs –Daycare Centers & Schools 	61,747	61,494	61,241	61,494

Total 	11,387,270	11,340,584	11,294,084	11,340,646



(iii) Respondent Burden Related to Pre-Renovation Education

	The burden from the activities covered by this ICR involves the time
for preparing and providing the information needed to perform the
disclosure activities in conjunction with the renovation of target
housing, and public or commercial building COFs as specified by the
rule.  In essence, this includes the following activities:

Preparing written acknowledgment/certification;

Preparing and delivering the pamphlet to individual owner-occupants,
owners of all rental units, and occupants of target housing rental units
where an occupied unit is being renovated;

Obtaining acknowledgment/certification of the delivered pamphlet;

Preparing and posting the notification for common area activities, or
for COFs; and

Preparing a statement describing the steps performed to notify all
occupants of common areas of the intended renovation.

Prior versions of the 406(b) ICR included start-up burden for new
respondents to read and learn the pre-renovation information
dissemination requirements.  Because those requirements are now
discussed as part of the certified renovator training (which was created
after the previous version of this ICR was approved), the start-up
burden is no longer included in this ICR.

(A) Target Housing Event Burden

	In this transaction, the renovator/manager must prepare the appropriate
document, make sufficient copies, distribute the information, and obtain
the acknowledgments or prepare a certification of the delivery failure. 
Since the burden per event is likely to vary greatly, dependent upon
such highly variable factors as the method of delivery chosen, the
frequency of this activity for the individual manager or renovator, the
number of events, experience, and individual efficiencies, EPA has
attempted to make the analysis more straightforward by making some
simplifying assumptions.  The time estimates are based on conversations
with renovation contractors, building trade groups, and rental property
owners and managers.  

	EPA assumed that a written acknowledgement will be prepared for 100% of
the renovations in owner occupied target housing (5,369,596
renovations), and 25% of the renovations in rental target housing taking
place in occupied units (or 1,447,374 renovations).  In addition, a
written acknowledgment will be prepared for 100% of the owners of rental
target housing units (5,789,494 renovations).  

This analysis estimates the burden per event of preparing
acknowledgement and certification forms, distributing pamphlets, and
obtaining proof of pamphlet receipt based on the supporting statement
for the previous version of this ICR – EPA ICR No. 1669.05 (2008) –
with some modifications.  The current ICR estimates that contractors or
landlords will need an average of two minutes to prepare a set of
acknowledgement and certification forms; two minutes to photocopy the
pamphlet; and two minutes to deliver the pamphlet and obtain proof of
pamphlet receipt from each individual involved.  The burden of preparing
the lead hazard pamphlet is a new estimate that was not included as a
separate line item in the previous ICR.  

The current ICR estimates that contractors or landlords will need five
minutes to file all of the signed acknowledgement forms or mailing
certificates.  For renovation events in common areas, these 5 minutes
represent the burden for preparing, signing, and dating a statement of
notification.  (The previous ICR accounted for these two activities
separately.)  Common area renovations are discussed in more detail
below.

	The renovator/manager is also required to distribute the pamphlet and
obtain acknowledgments from all target housing owner occupants
(5,369,596), all owners of rental housing units (5,789,494), and
occupants of rental target housing units where occupied units are
renovated (1,447,374).  The pre-renovation education requirements
provide flexibility to the renovator/manager for their distribution of
the pamphlet or notification.  Since the renovator/manager will already
visit the site on more than one occasion to complete the contract
transaction, evaluate the site for estimation purposes, deliver material
and the like, EPA believes personal delivery, i.e., distribution of the
pamphlet or notification, is likely to be combined with one of these
other activities. Since the manager/renovator must obtain the
acknowledgment from the recipient when the information is provided, or
certify that the information was made available and acknowledgment was
refused, this activity will also occur at this time.  EPA estimates this
transaction may take less than 1 minute, and no more than 4 minutes; EPA
estimated the burden to be 2 minutes per event (0.033 hours) in order to
calculate the total burden for the ICR.

For the sake of simplicity, EPA calculated the burden for all written
acknowledgments based on the time to prepare the document for the first
event, although subsequent events will involve copying the document for
distribution, which takes less time.  Similarly, EPA assumed that 100
percent of the renovation activities in rental housing will involve the
notification of the owner, even though in some cases the renovations
will be conducted by the rental owner’s staff.  All of these
assumptions are consistent with those used in the original RIA for this
rule and with the previous ICR analyses.

	There will be some instances when the manager/renovator will need to
provide a self-certification for failed deliveries, resulting in
additional burden. EPA believes that the other assumptions in the
analysis (including the simplifying assumptions described above) are
sufficiently conservative to offset any added burden associated with
failed deliveries, so that no additional burden need be estimated to
cover these circumstances. Consequently, the calculations in this
analysis assume that all recipients will provide the acknowledgment.

	Renovation activities taking place in the common area also require the
firm performing renovations to provide occupants with general
information about the renovation project and access to the lead hazard
information pamphlet.  In addition, the firm performing renovations must
prepare a statement describing the steps performed to notify each
occupant of the intended renovation.  EPA assumes that all renovators
working in common areas will post a single copy of the pamphlet and a
job-specific information sheet.  For this requirement, EPA is assuming a
time estimate of five minutes per event to prepare and post the
information and pamphlet.  As described above, the time to prepare,
sign, and file the statement of notification is included in the five
minutes attributed to filing the acknowledgment of pamphlet delivery to
the owner of the affected property.

  REF _Ref269986796 \h  \* MERGEFORMAT  Exhibit 6.10  presents the
per-event burden associated with pre-renovation education incurred by
contractors and landlords performing work in owner-occupied and rental
target housing units.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  10 :  Burden Estimates for Target
Housing Renovations by Event and Task (in hours)



Activity	Burden Hours by Type of Event

	Owner-Occupied Events	Rental Events – Occupied Units	Rental Events
– Vacant Units & Common Areas

	Number of Activities

per event	Burden per event	Number of Activities per event	Burden per
event	Number of Activities per event	Burden per event

Photocopy/Print Pamphlet	1	0.033	2	0.066	1	0.033

Preparing Acknowledgement Sheet	1	0.033	2	0.066	1	0.033

Distribution of Pamphlet to Owners/Occupants	1	0.033	2	0.066	1	0.033

Filing and Retaining Acknowledgement and Steps Taken for Common Area
Notification	1	0.083	1	0.083	1	0.083

Other Activities for Common Area/Unoccupied Events

Prepare/Post Pamphlet and Job-Specific Information	-	-	-	-	1	0.083

Total

0.182

0.281

0.265

Note(s): Values rounded to 3 decimal places.

The rule requires the firm performing renovations to prepare and
distribute pamphlets to the owner of the affected property.  In
addition, the firm performing renovations is required to distribute
pamphlets to the tenants of the rental properties (if occupied), or post
a pamphlet in the case of common area rental events.  This analysis may
overestimate the time for vacant, single-unit rental events, as it
assumes a sign will be posted in these cases.

Sources:  Supporting Statement for Lead-Based Paint Pre-Renovation
Information Dissemination - TSCA Sec. 406(b)  EPA ICR No. 1669.05 (2008)



	  SEQ CHAPTER \h \r 1 The recordkeeping burden involves the time for
meeting the pre-renovation education rule's recordkeeping requirements. 
The individual recordkeeping burden for renovation contractors and
property managers performing renovation work is based on the estimated
total annual number of renovations performed, i.e., 11,159,091, and the
total amount of time spent in the recordkeeping activity (approximately
five minutes per event for filing and retaining the acknowledgement form
and if applicable, a statement of notification for common area
activities). 

	  REF _Ref269986821 \h  \* MERGEFORMAT  Exhibit 6.11  presents the
total estimated burden incurred by contractors and landlords in
complying with the pre-renovation education requirements of 406(b) in
target housing.  Total burden estimates represent the products of the
total per-event burden estimates in   REF _Ref269986796 \h  \*
MERGEFORMAT  Exhibit 6.10  with the corresponding total number of
events.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  11 : Pre-Renovation Education
Burden for Target Housing Renovations

Total Burden Hours

 	Year 1	Year 2	Year 3	Average

Owner-Occupied Units	LSWP Events Performed Annually	5,391,671	5,369,566
5,347,550	5,369,596

	Hour Burden per Event	0.182	0.182	0.182	0.182

	Total Burden Hours	981,284	977,261	973,254	977,266

Rental – Occupied Units 	LSWP Events Performed Annually	1,453,324
1,447,366	1,441,431	1,447,374

	Hour Burden per Event	0.281	0.281	0.281	0.281

	Total Burden Hours	408,384	406,710	405,042	406,712

Rental –Vacant Units and Common Areas	LSWP Events Performed Annually
4,359,972	4,342,096	4,324,294	4,342,121

	Hour Burden per Event	0.265	0.265	0.265	0.265

	Total Burden Hours	1,155,393	1,150,655	1,145,938	1,150,662

Total Burden Hours – All Events	2,545,061	2,534,626	2,524,234
2,534,640

Sources: Economic Analysis for the 2008 RRP rule; Economic Analysis for
the 2010 Opt-out rule; Supporting Statement for Lead-Based Paint
Pre-Renovation Information Dissemination - TSCA Sec. 406(b), EPA ICR No.
1669.05 (2008). 



(B)  Public or Commercial Building COF Events Burden

The pre-renovation education burden on entities performing renovation
work in public or commercial building COFs is similar to that for
entities working in target housing.  Landlords, as well as contractors
working in COFs that own their own space, will need to prepare one set
of acknowledgement and certification forms, distribute the pamphlet to
the COF owner only, and obtain proof that the pamphlet was provided to
the COF owner.  Contractors working in COFs that are renting space will
need to prepare two sets of acknowledgement and certification forms (one
for the building owner and the other for the COF owner), distribute the
pamphlet to both individuals, and obtain proof that both individuals
have received the pamphlet.  

This analysis estimates the burden per event of preparing
acknowledgement and certification forms, distributing pamphlets, and
obtaining proof of pamphlet receipt based on the supporting statement
for the previous version of this ICR – EPA ICR No. 1669.05 (2008). 
ICR No. 1669.05 estimated contractors or landlords will need two minutes
to prepare a set of acknowledgement and certification forms; two minutes
to photocopy the pamphlet; two minutes to deliver the pamphlet and
obtain proof of pamphlet receipt from each individual involved, and
three minutes to file all of the signed acknowledgement forms or mailing
certificates.

In addition to those requirements, a renovation firm working in a COF is
required to either distribute the pamphlet and general information on
the renovation project to the parents or guardians of children using the
facility, or post informational signs describing the general nature and
locations of the project and the anticipated completion date.  These
signs must be posted in areas where they can be seen by the parents or
guardians of the children frequenting the COF.  The signs must be
accompanied by a posted copy of the lead hazard information pamphlet or
information on how interested parents and guardians can review a copy of
the pamphlet or obtain a copy from the renovation firm at no cost to the
parent or guardian.  In addition, the firm performing renovations must
prepare a statement describing the steps performed to notify each
occupant of the intended renovation.  The time to prepare, sign, and
file the statement of notification is included in the five minutes used
to file the acknowledgment of pamphlet delivery to the owner of the COF.

  REF _Ref271725815 \h  \* MERGEFORMAT  Exhibit 6.12  presents the
per-event burden associated with pre-renovation education incurred by
contractors and landlords performing work in owner-occupied and rental
COFs.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  12 : Per-Event Burden Estimates by
Task (in hours) for COF Events



Activity	Burden Hours by Type of Event

	Contractor Owner-Occupied, or Landlord COF Events	Contactor Rental COF
Events	In-House COF Events

	Number of Activities

per event	Burden per event	Number of Activities per event	Burden per
event	Number of Activities per event	Burden per event

Photocopy/Print Pamphlet	1	0.033	2	0.066	-	-

Preparing Acknowledgement Sheet	1	0.033	2	0.066	-	-

Distribution of Pamphlet to Owners/Occupants	1	0.033	2	0.066	-	-

Filing and Retaining Acknowledgement and Steps to Notify
Parents/Guardians	1	0.083	1	0.083	1	0.083

Other Activities when Notifying Parents/Guardians

Prepare/Post Pamphlet and Job-Specific Information	1	0.083	1	0.083	1
0.083

Total

0.265

0.364

0.166

Note(s): Values rounded to 3 decimal places.

The rule requires the firm performing renovations to prepare and
distribute pamphlets to the owner of the affected property.  In
addition, the firm performing renovations is required to distribute
pamphlets to the tenant of the rental property.  In all cases, the firm
performing renovations is assumed to post a pamphlet in the affected
COF.

Sources:  Supporting Statement for Lead-Based Paint Pre-Renovation
Information Dissemination - TSCA Sec. 406(b)  EPA ICR No. 1669.05 (2008)



The burden estimates in   REF _Ref271725815 \h  \* MERGEFORMAT  Exhibit
6.12  are combined in   REF _Ref271725806 \h  \* MERGEFORMAT  Exhibit
6.13  with the number of renovation events to estimate the total burden
incurred by contractors and landlords complying with the pre-renovation
education requirements of 406(b) in COFs.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  13 : Pre-Renovation Education
Burden for Renovations in COFs



 Respondent type

Year 1	Year 2	Year 3	Average

Contractor Owner-Occupied or Landlord COF Events	LSWP Events Performed 
114,315	113,847	113,379	113,847

	Burden Hours per Event	0.265	0.265	0.265	0.265

	Total Burden Hours	30,293	30,169	30,046	30,169

Contractor Rental COF Events	LSWP Events Performed 	6,241	6,215	6,189
6,215

	Burden Hours per Event	0.364	0.364	0.364	0.364

	Total Burden Hours	2,272	2,262	2,253	2,262

In-House COF Events	LSWP Events Performed 	61,747	61,494	61,241	61,494

	Burden Hours per Event	0.166	0.166	0.166	0.166

	Total Burden Hours	10,250	10,208	10,166	10,208

Total Burden Hours – All Events	42,815	42,639	42,465	42,639

Sources: Economic Analysis for the 2008 RRP rule; Supporting Statement
for Lead-Based Paint Pre-Renovation Information Dissemination - TSCA
Sec. 406(b), EPA ICR No. 1669.05 (2008). 



(C)  Total Burden Hours

Total burden hours are shown in   REF _Ref280277333 \h  \* MERGEFORMAT 
Exhibit 6.14 .

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  14 :  Total Burden Hours



 Renovation Events	Year 1	Year 2	Year 3	Average

Target Housing	2,545,061	2,534,626	2,524,234	2,534,640

Contractor Owner-Occupied or Landlord COF Events	30,293	30,169	30,046
30,169

Contractor Rental COF Events	2,272	2,262	2,253	2,262

In-House COF Events	10,250	10,208	10,166	10,208

Total 	2,587,876	2,577,265	2,566,699	2,577,280



	6(b)	Estimating Respondent Costs

	

Respondent costs are estimated by combining burden estimates from the
previous section with loaded wage rate, and adding in materials costs. 
The loaded hourly wage rate for renovation contractors and property
managers is estimated to be $45.81 per hour, based on wage data from the
Bureau of Labor Statistics and assuming a 53 percent markup to account
for fringe benefits and overhead.    

	The costs associated with the pamphlet, the acknowledgment forms, the
certification forms, and notification signs are all considered to be
materials costs and are not included in the estimated burden and
corresponding labor cost estimate.  The “materials” costs consist of
the cost for purchasing or duplicating the Lead Hazard Pamphlets, and
the materials associated with the preparation of the acknowledgment form
and notifications, as well as any certification forms. Certification
forms are expected to be used infrequently, but there is no numerical
information available on that frequency. The materials cost for
certification forms is expected to be negligible in comparison to the
cost of acknowledgment forms and therefore has not been separately
estimated. 

	In addition to the time needed to prepare acknowledgement forms and
distribute the pamphlet, contractors and landlords will incur the costs
of either photocopying or purchasing the renovation-specific lead safety
pamphlets.  The Lead Hazard Pamphlets are 11 pages, printed
single-sided, black and white, and on standard paper.  Based on per-page
photocopy costs, EPA estimates that a single pamphlet costs $1.10 to
photocopy.  

Target Housing Event Costs

EPA assumes that all owner-occupied renovation events in target housing
will require one copy of the lead-safety pamphlet for the
owner/occupant.  Rental housing renovation events taking place in
occupied rental units will require two copies of the pamphlet: one for
the property owner and a second for the current tenant.  Rental housing
renovation events taking place in vacant rental units will require one
copy of the pamphlet for the property owner.  For a renovation event
taking place in the common area of a rental housing unit, EPA assumes
firm performing renovations will provide a copy of the lead-safety
pamphlet to the property owner and post a second copy so that it is
accessible to all occupants of the building.  In addition, common area
events would require the firm performing renovations to post a sheet
containing general information about the specific renovation event.  

It is assumed that for every renovation event there is one copy of the
written acknowledgment.  Firms performing renovations are assumed to
generate two document sets (one for the renovator and one for the
occupant or owner), for a total of two copies, at approximately $0.10
per page.  For common area events, it is assumed firms performing
renovations will make one copy of the statement describing the steps
taken to notify occupants.    REF _Ref269986933 \h  \* MERGEFORMAT 
Exhibit 6.15  presents the resulting pamphlet costs per event.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  15 : Per-Event Materials Cost for
Target Housing Renovations



Activity	Materials Cost by Type of Activity

	Owner-Occupied Events	Rental Events –Occupied Units	Rental Events
–Vacant Units & Common Areas

	Number of Copies

per event	Cost per event	Number of Copies per event	Cost per event
Number of Copies per event	Cost per event

Lead Hazard Pamphlet	1	$1.10	2	$2.20	2	$2.20

Acknowledgement Sheet	2	$0.20	4	$0.40	2	$0.20

Other Materials for Common Area/Unoccupied Events

Job-Specific Information Sheet	-	-	-	-	1	$0.10

Description of Notification Process (Sign Posting)	-	-	-	-	1	$0.10

Total

$1.30	 	$2.60	 	$2.60

Notes:

The rule requires the firms performing renovations to prepare and
distribute pamphlets to the owner of the affected property.  In
addition, the firm performing renovations is required to distribute
pamphlets to the tenants of the rental properties (if occupied), or post
a pamphlet and job-specific information sheet in the case of common area
rental events.  It is assumed that the firm performing renovations will
make two copies of each acknowledgement sheet.  This analysis may
overestimate the cost for vacant, single-unit rental events, as it
assumes a sign will be posted in these cases.

Sources: Personal communication with Staples, September 9, 2010



  REF _Ref269986998 \h  \* MERGEFORMAT  Exhibit 6.16  presents the
estimated total costs of pre-renovation education to contractors and
property managers performing work in target housing.  Contractors and
landlords will incur time burden and material costs, presented in   REF
_Ref269986796 \h  \* MERGEFORMAT  Exhibit 6.10  and   REF _Ref269986933
\h  \* MERGEFORMAT  Exhibit 6.15 , respectively.  To estimate total
labor costs associated with pre-renovation education, the total burden
estimates in   REF _Ref269986821 \h  \* MERGEFORMAT  Exhibit 6.11  were
multiplied by the loaded wage rate for renovation firms ($45.81 per
hour).  Total pamphlet costs were estimated by multiplying the numbers
of events in   REF _Ref269986821 \h  \* MERGEFORMAT  Exhibit 6.11  by
the corresponding per-event pamphlet cost estimates in   REF
_Ref269986933 \h  \* MERGEFORMAT  Exhibit 6.15 .  The average cost of
the rule for target housing events over the three years of this ICR is
estimated to be $138 million per year.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  16 : Pre-Renovation Education
Costs for Renovations in Target Housing



 	Year 1	Year 2	Year 3	Average

Total Labor Cost

Owner-Occupied Units	$44,952,620	$44,768,326	$44,584,766	$44,768,555

Rental – Occupied Units	$18,708,071	$18,631,385	$18,554,974
$18,631,477

Rental – Vacant Units and Common Areas	$52,928,553	$52,711,506
$52,495,420	$52,711,826

Subtotal – Labor Cost	$116,589,244	$116,111,217	$115,635,160
$116,111,858

Total Material Cost

Owner-Occupied Units	$7,009,172	$6,980,436	$6,951,815	$6,980,475

Rental – Occupied Units	$3,778,642	$3,763,152	$3,747,721	$3,763,172

Rental – Vacant Units and Common Areas	$11,335,927	$11,289,450
$11,243,164	$11,289,515

Subtotal – Material Cost	$22,123,742	$22,033,037	$21,942,700
$22,033,162

Total Cost

Owner-Occupied Units	$51,961,792	$51,748,762	$51,536,581	$51,749,030

Rental – Occupied Units	$22,486,713	$22,394,537	$22,302,695
$22,394,649

Rental – Vacant Units and Common Areas	$64,264,481	$64,000,955
$63,738,584	$64,001,341

Total Cost	$138,712,986	$138,144,254	$137,577,860	$138,145,020



(ii) Public or Commercial Building COF Event Costs

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

In addition to the time needed to prepare acknowledgement forms and
distribute the pamphlet, contractors and landlords will also incur the
costs of either photocopying or purchasing the renovation-specific lead
safety pamphlets.  Based on per-page photocopy costs reported by
Staples, EPA estimates that a single pamphlet costs $1.10 to photocopy. 


It is assumed that for every renovation event there is one copy of the
written acknowledgment.  Firms performing renovations are assumed to
generate two document sets (one for the firm performing renovations and
one for the occupant or owner), for a total of two copies, at
approximately $0.10 each page. It is assumed firms performing
renovations will make one copy of the statement describing the steps
taken to notify parents and guardians of the renovation.    REF
_Ref271805494 \h  \* MERGEFORMAT  Exhibit 6.17  presents resulting
per-event pamphlet costs for COF events.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  17 : Per-Event Materials Cost for
Renovations in Public or Commercial Building COFs



Activity	Materials Cost by Type of Event

	Contractor Owner-Occupied COF Events	Contractor Rental COF Events
In-House COF Events

	Number of Copies	Cost	Number of Copies	Cost	Number of Copies	Cost

Lead Hazard Pamphlet	2	$2.20	3	$3.30	1	$1.10

Acknowledgement Sheet	2	$0.20	4	$0.40	-	-

Other Materials when Notifying Parents/Guardians

Job-Specific Information Sheet	1	$0.10	1	$0.10	1	$0.10

Description of Notification Process (Sign Posting)	1	$0.10	1	$0.10	1
$0.10

Total

$2.60

$3.90

$1.30

Notes:

The rule requires the firms performing renovations to prepare and
distribute pamphlets to the owner of the affected property.  In
addition, the firm performing renovations is required to distribute
pamphlets to the tenants of the rental properties.  It is assumed that
the firm performing renovations will make two copies of each
acknowledgement sheet.  In all cases, the firm performing renovations is
assumed to post a pamphlet and job-specific information sheet in the
affected COF.

Sources: Personal communication with Staples, September 9, 2010



  REF _Ref271805639 \h  \* MERGEFORMAT  Exhibit 6.18  presents the
estimated total costs of pre-renovation education to contractors,
property managers, and in-house staff performing work in COFs. 
Contractors, landlords, and in-house staff will incur time burden and
material costs, presented in   REF _Ref271725815 \h  \* MERGEFORMAT 
Exhibit 6.12  and   REF _Ref271805494 \h  \* MERGEFORMAT  Exhibit 6.17 ,
respectively.  To estimate total labor costs associated with
pre-renovation education, the total burden estimates in   REF
_Ref271725806 \h  \* MERGEFORMAT  Exhibit 6.13  were multiplied by the
loaded wage rate for renovation firms ($45.81 per hour).  Total pamphlet
costs were estimated by multiplying the numbers of events in   REF
_Ref271725806 \h  \* MERGEFORMAT  Exhibit 6.13  by the corresponding
per-event pamphlet cost estimates in   REF _Ref271805494 \h  \*
MERGEFORMAT  Exhibit 6.17 .  The average cost of the rule for COF events
over the three years of this ICR is estimated to be $2.4 million per
year.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  18 : Pre-Renovation Education
Costs for Renovations in Child Occupied Facilities



 	Year 1	Year 2	Year 3	Average

Total Labor Cost

Landlords	$52,911	$52,682	$52,498	$52,682

Contractors in Rental Units	$104,080	$103,622	$103,210	$103,622

Contractors in Owner-Occupied Units	$1,334,812	$1,329,360	$1,323,909
$1,329,360

Daycare Centers and Schools, In-House	$469,553	$467,628	$465,704
$467,628

Subtotal – Labor Cost	$1,961,355	$1,953,293	$1,945,322	$1,953,293

Total Material Cost

Landlords	$11,333	$11,287	$11,240	$11,287

Contractors in Rental Units	$24,340	$24,239	$24,137	$24,239

Contractors in Owner-Occupied Units	$285,886	$284,716	$283,546	$284,716

Daycare Centers and Schools, In-House	$80,271	$79,942	$79,613	$79,942

Subtotal – Material Cost	$401,830	$400,183	$398,536	$400,183

Total Cost

Landlords	$64,244	$63,968	$63,738	$63,968

Contractors in Rental Units	$128,420	$127,861	$127,347	$127,861

Contractors in Owner-Occupied Units	$1,620,697	$1,614,076	$1,607,455
$1,614,076

Daycare Centers and Schools, In-House	$549,824	$547,571	$545,318
$547,571

Total Cost	$2,363,185	$2,353,475	$2,343,857	$2,353,475



	6(c)	Estimating Agency Burden and Cost

	Not applicable.  This is a third party notification rule.

	6(d)	Bottom Line Burden Hours and Costs/Master Table

	  REF _Ref269986974 \h  \* MERGEFORMAT  Exhibit 6.19  presents the
total bottom line numbers for the ICR renewal.    REF _Ref271805915 \h 
\* MERGEFORMAT  Exhibit 6.20  presents three-year averages by type of
respondent.  The total annual burden for this ICR is therefore 2,577,280
hours and the total annual cost is an estimated $140,498,539.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  19 : Bottom Line Burden and Costs



 	Year 1	Year 2	Year 3	Average

Number of Respondents	321,823	320,503	319,187	320,504

Number of Responses	11,387,270	11,340,584	11,294,084	11,340,646

Total Burden Hours	2,587,876	2,577,265	2,566,699	2,577,280

Total Cost	$141,076,171	$140,497,730	$139,921,717	$140,498,539



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  20 : Respondent Summary,
Three-Year Average



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

1. Contractors Working in Owner Occupied Target Housing  

(Private Firms)	276,119	278,183	19.30239	0.182	977,267

2. Contractors Working in Occupied Target Housing Rental Units 

(Private Firms)	276,119	278,183	5.20296	0.281	406,712

3. Contractors Working in Vacant Target Housing Rental Units and Common
Areas (Private Firms)	276,119	278,183	15.608870	0.265	1,150,662

4. Contractor Working in Owner-Occupied COFs or Landlord Working in
Rental COFs (Private Firms)	15,242	16,367	6.95589	0.265	30,169

5. Contractor Working in Rental COFs (Private Firms)	3,137	3,197
1.944010	0.364	2,262

6. In-House COF Events (Private Firms – Schools & Daycare Centers)
18,236	18,236	1.38255	0.166	4,185

7. In-House COF Events 

(Local Governments – Schools)	7,138	7,718	4.70093	0.166	6,023

Total	316,735	320,504	 	 	2,577,280

a The total number of respondents and small respondents is the sum of
rows numbered 1, 4, 6, and 7, since the same contractors from these rows
are included in other rows (e.g., the same 276,119 contractors are
included in the rows numbered 1, 2, and 3).  



	6(e)	Reasons for Changes in Burden

	This request reflects a net decrease of 545,206 hours (from 3,122,486
hours to 2,577,280 hours) from the total respondent burden currently in
the OMB inventory.  The primary reason for the decrease is a change in
methodology for calculating the number of target housing renovation
events to that used in the 2008 RRP rule analysis.  This change reflects
an adjustment rather than a program change.  EPA estimates there will be
an average of 11,340,646 responses per year under this renewal ICR.

This ICR renewal also incorporates changes to the per-activity burden
assumptions.  These changes all reflect adjustments rather than program
changes. 

	Finally, this ICR includes burden and material cost estimates related
to renovations taking place in public or commercial building COFs.  The
burden estimates for these entities relating to the pre-renovation
education requirements of the 2008 RRP rule were previously included in
ICR 1715.10.  This is also an adjustment rather than a program change.

	6(f)	Burden Statement

	The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0158, is estimated to be 0.23 hours
per response (i.e., 2,577,280 burden hours for an estimated 11,340,646
responses).  Burden is defined in 5 CFR 1320.3(b).  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA’s regulations in
title 40 of the CFR, after appearing in the Federal Register, are listed
in 40 CFR part 9 and included on the related collection instrument or
form, if applicable.

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OPPT-2010-0911.  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 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-2010-0911 and OMB control number
2070-0158 in any correspondence.

	

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public
docket established for this ICR under docket identification number
EPA-HQ-OPPT-2007-0271.  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:	15 U.S.C. 2686 - Section 406 of the Toxic Substances
Control Act. 



Attachment 2:	40 CFR part 745, Subpart E - Residential Property
Renovation. 



Attachment 3:	Lead Hazard Information Pamphlet (“Renovate Right”).
Also available online at the   HYPERLINK
"http://epa.gov/lead/pubs/renovaterightbrochure.pdf"  EPA Website 

 

Attachment 4:	Record of Consultations with Potential ICR Respondents 





 Common areas are portions of a building generally accessible to all
occupants, including – but not limited to – hallways, stairways,
laundry rooms, recreational rooms, playgrounds, and community centers.

 Regulatory Impact Analysis of Lead-Based Paint Hazard Disclosure
Regulation for Residential Renovation, U.S. Environmental Protection
Agency, April 1998.

As discussed in detail in Section 4.4 of the Economic Analysis for the
RRP rule (EPA 2008), public schools, private schools with more than 100
students, landlords that rent space to daycare centers in public or
commercial buildings, and daycare centers in religious or other
non-profit establishments are expected to perform all of their own
painting and window/door projects, as well as one unscheduled
maintenance event per building every year.   Contractors are expected to
perform all electric and plumbing/HVAC, as well as all remaining
unscheduled maintenance projects in these COFs.  Furthermore,
contractors are expected to perform all RRP projects in private schools
with less than 100 students, and in daycare centers that own their
buildings.

 The previous ICR estimated that there would be 17,754,180 renovation
events per year subject to 406(b) requirements.

 Economic Analysis for the TSCA Lead Renovation, Repair, and Painting
Program Final Rule for Target Housing and Child-Occupied Facilities,
U.S. Environmental Protection Agency, March 2008.

 Certified renovators’ unloaded wage ($29.94/hour) is drawn from the
2009 full-time mean hourly earnings annual data for First-line
Supervisors/managers of construction trades and extraction workers in
the Bureau of Labor Statistics (BLS) National Compensation Survey:
Occupational Wages in the United States, June 2010, Table 2-2 (Private
industry, selected occupations, mean hourly earnings). According to 2009
BLS data for employer costs for employee compensation, wages and
salaries accounted for 69.2% of employee compensation, implying a wage
multiplier of 1.445 for fringe benefits.  An additional 8.3% was added
to the employer cost multiplier to account for overhead.  This is based
on the Appendix I of the National Association of Home Builders' 2010
Cost of Doing Business Study, which reported a factor of 3.5% of sales
price for indirect construction costs, and 4% for general and
administrative costs.  (The sum of 3.5% and 4% is 7.5%.  Subtracting out
the 10% that NAHB reports for profit, direct and indirect costs are 90%
of sales price.  Taking 7.5% of 90% yields a labor overhead rate of 8.3%
of wages and salaries.)  an additional Adding an 8.3% overhead factor to
the 44.5 % fringe benefits factor results in was added to the employer
cost multiplier for overhead to estimate a multiplier of 1.53 for fully
loading wages.  .

 Represents a cost of $0.10 per page to email file for printing
(personal communication with Staples, September 9, 2010).

Page   PAGE  31  of   NUMPAGES  31 

