  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: TSCA Sections 402 and Section 404 Training, Certification,
Accreditation and Standards for Lead-Based Paint Activities and
Renovation, Repair, and Painting

	EPA ICR No.:  1715.13	OMB Control No:  2070-0155

	1(b)	Short Characterization

This information collection request (ICR) combines existing ICRs 1715.09
(ICR for lead-based paint activities), 1715.10 (ICR addendum for the
2008 RRP final rule), and 1715.12 (ICR for the 2010 RRP opt-out and
recordkeeping final rule) covering the reporting and recordkeeping
requirements for individuals or firms conducting lead-based paint
activities or renovation in or on houses, apartments, or child-occupied
facilities built before 1978, under the authority of sections 402 and
404 of the Toxic Substances Control Act (TSCA) (15 U. S. C. 2682, 2684;
see Attachment 1).  

Sections 402(a) and 402(c)(3) of TSCA require EPA to develop and
administer a training and certification program as well as work practice
standards for persons who perform lead-based paint activities and/or
renovations.  The current regulations in 40 CFR part 745, subpart E,
cover work practice standards, recordkeeping and reporting requirements,
individual and firm certification, and enforcement  for  renovations
done in target housing or child-occupied facilities.  The current
regulations in 40 CFR part 745, subpart L, cover inspections, lead
hazard screens, risk assessments, and abatement activities (referred to
as “lead-based paint activities”) done in target housing and
child-occupied facilities.  Section 401 of TSCA defines target housing
as any housing constructed before 1978 except housing for the elderly or
disabled or 0-bedroom dwellings.  

	Sections 402(a) and 402(c)(3) of TSCA require reporting and/or
recordkeeping from four entities: firms engaged in lead-based paint
activities or renovations in target housing and child-occupied
facilities; individuals who perform lead-based paint activities in
target housing and child-occupied facilities; training providers; and
states/territories/tribes/Alaskan native villages (hereafter, the term
“states” includes territories/tribes/villages).  The following
sections provide a general overview for each entity:

Firms: Firms that wish to engage in renovations or lead-based paint
activities in target housing or child-occupied facilities must obtain
certification from EPA/states.  This includes firms consisting only of
one self-employed individual.  To receive certification, a firm must
submit a letter to EPA/states certifying that it will employ certified
individuals and conduct work in target housing and child-occupied
facilities in accordance with the applicable work practice standards. 
Renovation, repair, and painting firms must apply for re-certification
every five years, while firms performing lead-based paint activities
must apply for re-certification every three years.  The rule also
requires firms to develop and retain records of the lead-based paint
activities and renovations they undertake to demonstrate compliance with
standards and provide a written record for future reference.  Firms must
notify the Agency prior to commencement of lead-based paint abatement
activities.  In addition, for work in child-occupied facilities located
in public or commercial buildings, the rule requires firms to provide
the building owner and adult representative of the child-occupied
facility with a lead hazard information pamphlet.  (Existing regulations
require the distribution of a lead hazard pamphlet, and the associated
recordkeeping, before renovations in all target housing.  This burden is
reflected in EPA ICR No. 1669.05 Lead-Based Paint Pre-Renovation
Information Dissemination- TSCA Sec. 406(b), and is approved under OMB
Control No. 2070-0158.)  These notification, reporting, and
recordkeeping requirements are necessary to provide EPA compliance
monitoring and enforcement personnel with information necessary to track
compliance activity and to prioritize inspections.

Individuals:  Individuals who wish to perform lead-based paint
activities in target housing or child-occupied facilities must also
receive certification from EPA/states.  To obtain certification, an
individual must complete an accredited training course and receive a
course completion certificate, pass a third-party certification exam,
meet specific education/experience requirements, and demonstrate this to
EPA/states.

Individuals certified to perform lead-based paint activities must take a
refresher course and apply for re-certification every three years (five
for individuals who have passed a proficiency test as part of their
training).  The rule also requires individuals to develop records of the
lead-based paint activities and renovations they undertake to
demonstrate compliance with standards and provide a written record for
future reference.  These notification and recordkeeping requirements are
necessary to provide EPA compliance monitoring and enforcement personnel
with information necessary to track compliance activity and to
prioritize inspections.      

Training providers: Training programs seeking to offer training for
inspectors, risk assessors, project designers, abatement supervisors,
abatement workers, renovators or dust sampling technicians must obtain
EPA/state accreditation.  In order for EPA/states to have the
information necessary to evaluate and accredit the training programs,
training providers must prepare and submit application packages. 
Training programs also must certain records related to their students
and training personnel qualifications.  Training programs are required
to notify the Agency prior to (i) prior to providing training courses,
and (ii) following completion of training courses.  Training programs
must apply for re-accreditation every four years.  These notification
requirements are necessary to provide EPA compliance monitoring and
enforcement personnel with information necessary to track compliance
activity and to prioritize inspections.

States: Under TSCA section 404, EPA must review and assess state
submissions to determine whether to grant authorization to administer a
program addressing training, certification, accreditation and standards
for lead-based paint activities or renovation, repair, and painting.  A
state seeking authorization will need to provide information to EPA so
the Agency may determine whether its program is at least as protective
of human health and the environment as the federal program and whether
it provides adequate enforcement.  Authorized states need to provide a
report to EPA on their activities.

2.	NEED FOR AND USE OF THE COLLECTION

            2(a)	Need/Authority for the Collection

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

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

	-	Minimum requirements for the accreditation of training providers;

	-	Minimum training curricula requirements;

	-	Minimum training hour requirements;

	-	Minimum hands-on training requirements;

	-	Minimum training competency and proficiency requirements;

	-	Minimum requirements for training program quality.

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

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

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

	2(b)	Practical Utility/Users of the Data

Public or commercial building owners, child-occupied facility operators,
and parents/guardians

The owner of a public or commercial building containing a child-occupied
facility must be provided with a lead hazard information pamphlet before
any renovation in the child-occupied facility commences.  In addition,
if the child-occupied facility is not operated by the owner of the
building, an adult representative of the child-occupied facility must
also be provided with a lead hazard information pamphlet.  Parents and
guardians of children using child-occupied facilities must be provided
with general information on the renovation as well as the pamphlet, or
information on how to obtain a copy of the pamphlet.  Information
contained in this pamphlet may be used by homeowners, public or
commercial building owners, child-occupied facility operators, and
parents or guardians to take appropriate precautions to minimize the
exposure of children to lead-based paint hazards created by renovations.
 Parents and guardians may also use general information about the
renovation for the purpose of minimizing the exposure of their children
to lead-based paint hazards created by renovations.

EPA

	This information collection will provide EPA with materials necessary
to authorize state renovation and training rule programs and to serve as
the accrediting and certifying body in states without authorized
programs (discussed further below).

EPA/States 

This collection will enable EPA/states to determine compliance with and
enforce the requirements for training, certification, accreditation, and
work practice standards for renovations and lead-based paint activities.
 Without this collection, there would be no meaningful way of ensuring
the implementation of the statutory objective: to ensure that trained
individuals conduct renovations and lead-based paint activities in such
a way as to minimize potential harm to occupants.  The rule provides
flexibility for individuals conducting renovations and lead-based paint
activities, by relying on guidance and training to help individuals
determine the best approaches for renovations and lead-based paint
activities.  The Agency believes this is the best method for
accommodating a variety of projects and site-specific conditions.    

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

The re-certification and re-accreditation requirements for individuals
and training programs are meant to ensure that training programs
incorporate new developments and technologies in their courses and
provide training to individuals.  The Agency believes this will ensure
that individuals and firms conduct renovations and lead-based paint
activities in the safest and most effective manner possible.   

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

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

3(a)	Non-Duplication

The Agency’s collection pursuant to the TSCA 402/404 regulations does
not duplicate any other collection.  There is no other model program for
lead-based paint activities or renovations and there are currently no
other federal requirements for the training and certification of
individuals engaged in these activities, or lead hazard information
distribution requirements for renovations in child-occupied facilities. 


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

	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 and Public Comments

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

Due to the nature of this regulation and its collection, less frequent
collection is not feasible.  In particular, each individual and firm
must obtain certification and re-certification, each training program
must obtain accreditation and re-accreditation as well as specific
notification and documentation prior to commencement and upon completion
of each lead-based paint activity and renovation course, and each
lead-based paint activity is a separate and unique event requiring
specific notification and documentation.  Program approval for states is
a one-time activity, although there is ongoing reporting.

3(e)	General Guidelines

This ICR is consistent with OMB’s general guidelines.  The Agency
requires that individuals and firms maintain records for three years. 
Authorized states report once a year for the first three years and
biannually thereafter.

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

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 INFORMATION REQUESTED

4(a)	Respondents/NAICS Codes

	Respondents to the lead-based paint activities rule include:

firms and individuals engaged in lead-based paint activities 

training programs providing training services in lead-based paint
activities 

state programs

Respondents to the renovation, repair, and painting rule include:

firms and individuals engaged in residential renovations or renovations
in child-occupied facilities

training programs providing training services in renovations

state programs

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

23321  Single Family Housing Construction

		23331  Manufacturing and Industrial Building Construction

		23332  Commercial and Institutional Building Construction

		23521  Painting and Wall Covering Contractors

		23542  Drywall, Plastering, Acoustical, and Insulation Contractors

		23551  Carpentry Contractors

		23561  Roofing, Siding, and Sheet Metal Contractors

		23594  Wrecking and Demolition Contractors

		23599  All Other Special Trade Contractors

236118 Residential Remodelers

238210 Electrical Contractors

238220 Plumbing, Heating, and Air-Conditioning Contractors

238320 Painting and Wall Covering Contractors

238350 Finish Carpentry Contractors

238310 Drywall and Insulation Contractors

238170 Siding Contractors

238340 Tile and Terrazzo Contractors

238150 Glass and Glazing Contractors

238390 Other Building Finishing Contractors

238290 Other Building Equipment Contractors

531110 Lessors of Residential Buildings and Dwellings

531311 Residential Property Managers	

541330 Engineering Services	

541350 Building Inspection Services

611110 Elementary and Secondary Schools		

611513  Apprenticeship Training

		611519  Other Technical and Trade Schools

		611699  All Other Miscellaneous Schools and Instruction

624410 Child Day Care Services

		92312  Administration of Public Health Programs

92411  Administration of Air and Water Resource and Solid Waste
Management Programs

		92511  Administration of Housing Programs

	4(b)	Information Requested

	

	The lead-based paint activities and renovation, repair, and painting
regulations specify reporting and recordkeeping for training providers
and individuals/firms undertaking lead-based paint activities and/or
renovations in target housing and child-occupied facilities.  

	(i)	Data Items

	States

	In order to obtain authorization from EPA to administer and enforce a
program under section 404, states must prepare:

	

A notice of intent to seek authorization

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

States that receive authorization for lead-based paint activities and/or
renovation programs must submit to EPA a report summarizing
implementation and enforcement activities, including a list of
enforcement actions taken and any changes in content, administration, or
enforcement of the state program.

Training Providers

To receive accreditation to provide lead-based paint activities or
renovation training, training providers must submit the following
documents to EPA/state, using the form entitled “Application and
Instructions for Training Providers” or a similar form containing the
required information:

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

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

A copy of the course agenda

A copy of the student and instructor manuals if the training provider
does not use the EPA model training materials

A copy of the course test blueprint

A description of activities and procedures used for hands-on training 

A description of the facilities and equipment to be used for lecture and
hands-on training

Before giving a lead-based paint activity or renovation/dust sampling
technician course, training providers must provide notification to the
Agency, using either the sample form entitled “Lead-Based Paint
Activities and Renovation Training Notification” or a similar form
containing the required information.  Training providers may provide
electronic submissions using the Agency’s secure, Internet-based
Central Data Exchange (CDX).  (The paperwork activities, related burden
and costs with CDX user registration are described in an ICR approved
under OMB Control No. 2025-0003.)  The initial notice must include the
following: 

Notification type (original, updated, cancellation)

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

Course discipline, type (initial, refreshers), and language used in
course

Date(s) and time(s) of training 

Training location’s phone number and street address

Principal instructor’s name

Training manager’s name and signature

Training providers must update the Agency regarding any changes to
training dates, course locations, course cancellations, or other changes
to the original notice.

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

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

Course discipline and type (initial, refresher)

Date(s) of training

The following information for each student who took the course:

Name

Address

Date of birth

Course completion certificate number

Student test score

Training manager’s name and signature

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

	Training course providers must maintain the following records:

Records regarding qualifications of training manager and principal
instructor

Current curriculum and course materials

Course test blueprints

Information regarding how hands-on assessments are conducted

Quality control plan

Results of students’ hands-on assessments and course tests

Record of each student’s course completion certificate

Individuals/Firms

To obtain certification to perform lead-based paint activities or
renovations in target housing or child-occupied facilities, firms must
submit specific materials to EPA/state, using the sample EPA form
“Application for Firms to Conduct Lead-based Paint Activities or
Renovations” or a similar form requiring the same information:

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

Explanation of any violations of lead-based paint

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

Firms may later amend their applications to add or modify information. 
Lead-based paint activities firms must be recertified every three years,
while renovation firms must be recertified every five years.

Firms conducting renovations are required to maintain records
demonstrating compliance with the final rule requirements for using
certified renovators and properly trained workers, posting signs,
containing and cleaning the renovation work area, and performing a
post-renovation cleaning verification or dust clearance testing after
renovation activity is finished.   

To obtain certification, individuals engaged in lead-based paint
activities are required to submit specific materials to EPA/state:

Inspectors, risk assessors, supervisors: accredited training course
completion certificate, statement certifying the individual meets the
education/experience prerequisites, proof of passage of the third-party
exam

Project designers: statement certifying individual meets the
education/experience prerequisites, accredited training course
completion certificate

Workers: accredited training course completion certificate

In the performance of lead-based paint activities, firms/individuals
must complete and retain a number of reports (contingent on the activity
conducted), including:

An inspection report describing the surfaces sampled for lead-based
paint and the sampling results

A lead hazard screen report, which includes an accounting of any paint
or dust sampling results

A risk assessment report, which includes an accounting of paint, dust,
or soil sampling results and existing hazards

An occupant protection plan identifying the measures that will be taken
to protect building occupants from lead-based paint hazards

An abatement report detailing the activities undertaken to eliminate the
hazard

Certified firms must notify EPA prior to beginning lead-based paint
abatement activities (except in emergency situations) and provide an
updated notice if needed, using either the sample form entitled
“Notification of Lead-Based Paint Abatement Activities” or a similar
form containing the required information.  Certified firms may provide
electronic submissions using the Agency’s CDX.  Notices should include
the following information:

Notification type (original, updated, cancellation)

Date when lead-based paint abatement activities will start and end
(approximation using best professional judgment)

Firm’s name, EPA certification number, address, phone number

Type of building (e.g. single family dwelling, multi-family dwelling,
child-occupied facilities) on/in which abatement work will be performed

Property name 

Property address including apartment/unit number (if applicable) for
abatement work

Documentation showing evidence of an EBL determination or a copy of the
federal/state/tribal/local emergency abatement order (if applicable)

Name and EPA certification number of the project supervisor

Approximate square footage/acreage to be abated

Brief description of abatement activities to be performed

Name, title, and signature of the representative of the certified firm
who prepared the notification

(ii)	Respondent Activities

The rule specifies reporting and recordkeeping for authorized states,
training providers, and individuals/firms undertaking lead-based paint
activities and renovations.  The rule does not require specific forms or
applications for submissions.

	States seeking authorization for the training rule and/or renovation
program will perform the following activities:

Read the regulation

Compare any existing state program requirements to the minimum
requirements of the federal regulation

Develop and adopt new legislation as necessary

Develop and promulgate new regulations as necessary

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

Prepare and submit to EPA an application for program approval

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

Submit an annual report to EPA

Training providers must perform the following activities: 

Read the regulation

Prepare and submit an accreditation application to accrediting entity

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

Provide notice of completion of all courses offered and retain records

Provide accrediting entity access to records as requested

Firms must perform the following activities:

Read the regulation

Submit applications for certification which includes proof of passage of
third-party exam and/or course completion certificate, and 

Statement certifying individual meets education/experience requirements
(applicable to risk assessors, supervisors, and project designers)

Submit notification of abatement work (does not apply to firms applying
for renovation only)

Prepare and retain records 

Individuals seeking certification perform the following activities:

Read the regulation

Submit a proof of passage of third-party exam and/or course completion
certificate, and statement certifying individual meets
education/experience requirements

Retain records, if individual is incorporated or acting as a firm.

5.	AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

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

Receive, review, and act on applications from states

Receive, review, and file reports from authorized states

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

Receive, review, and file notices of trainings from training providers 

Receive, review, and file materials sent from accredited training
providers

Receive, review, and act on certification applications from
firms/individuals

Receive, review, and file notices of abatement activities from certified
abatement firms.

5(b)	Collection Methodology and Management

This section details the data elements for each type of respondent and
for each reporting or recordkeeping activity.  Note that EPA is cited as
the accrediting and certifying body, as state programs may not
necessarily adopt a program requiring the submission or retention of
exactly the same materials as in the federal program.  For the purposes
of estimating burden in section 6 of this ICR, however, the Agency
assumes that states adopt the federal program requirements for reporting
and recordkeeping.  In states without authorized programs, EPA is the
accrediting and certifying body.

	The rule provides general instructions to states seeking EPA
authorization under this regulation.  A state may submit an application
to EPA any time.  The elements necessary for application are as follows:

A public notice of intent to seek authorization, with an opportunity for
public hearing

A transmittal letter from the Governor or tribal equivalent requesting
program approval

An Attorney General or tribal equivalent statement certifying the
adequacy of the state’s program authority

Copies of all applicable state statutes and regulations

The name of the primary agency that is or will be responsible for
administering and enforcing the program and functions of any other
agencies involved in administering the program

A description of the program elements and an analysis of how these
elements relate to the federal program elements under section 402

A description of the resources the state intends to devote to the
administration and enforcement of the program

States authorized for this rule will need to provide a report (or
separate reports) to EPA describing any significant changes in the
programs and enforcement activities.

	The rule instructs training programs seeking accreditation for initial
training programs to submit a one-time application to EPA covering the
following elements:

The training program’s name, address, and telephone number

A list of courses for which it is applying for accreditation

A statement, signed by the training program manager, that certifies that
the training program meets the minimum requirements  (e.g., training
hours) established in the rule

A copy of the test blueprint, which describes the proportion of test
questions devoted to each major course topic

A detailed description of the facilities and equipment available for
lecture and hands-on training

A detailed description of the procedures for conducting the assessment
of hands-on skills

A copy of the program’s quality control plan

For programs that do not adopt the EPA model curriculum, the program
must submit, in addition to the above materials, a copy of the student
manuals and instructor notebooks to be used for each course, and a copy
of the course agenda, which includes the time allocated for each course
topic

Training programs must submit the following information to seek
accreditation for refresher training courses (note that applications for
refresher training may be simultaneously submitted with applications for
full-length training programs):

The training program’s name, address, and telephone number

A list of refresher courses for which it is seeking accreditation

A copy of student manuals and instructor notebooks

A statement signed by the training manager certifying compliance with
rule provisions

	Training programs must also seek re-accreditation from EPA every four
years.  In order to receive re-accreditation, the training program must
submit:

The training program’s name, address, and telephone number

A list of courses for which it is applying for re-accreditation

A description of any changes or updates to the training facility or
equipment that would adversely affect a student’s ability to learn,
since its last application was approved

A statement from the training program manager that the training program
complies at all times with all rule requirements

	The rule specifies that training programs must retain the following
records for three years and six months and make them available upon EPA
request:

Qualifications of training managers and work practice instructors

Current curriculum/course materials, and documents reflecting any
changes made to these materials

The course test blueprint

Information on how the hands-on assessment is conducted

The quality control plan

Results of the students’ hands-on skills assessments and course tests,
and a copy of each student’s course completion certificate

Any other material the program submitted to EPA as part of its
accreditation application

	The rule provides general instructions to individuals seeking
certification to perform lead-based paint activities.  Individuals must
submit an application to EPA, including the following elements:

Proof of training (for all individuals)

Evidence that the individual meets the education or experience
prerequisites (applicable to all but workers and inspectors)

Proof of completing the standardized certification exam (applicable to
all but workers and project designers).

	Under the rule’s provisions, individuals must seek re-certification
every three years (five years for individuals who have passed a
proficiency test as part of their training), submitting to EPA an
application and a copy of the refresher course completion certificate.

	The rule provides specific requirements for firms seeking
certification.  A firm must submit to EPA a letter indicating that the
firm will employ only certified individuals to conduct lead-based paint
activities and follow the work practice standards.

	The rule requires that individuals/firms prepare reports during the
conduct of lead-based paint activities and maintain the reports for no
fewer than three years.  The requirements are specific to the
disciplines.

	Following the conduct of an inspection, the inspector must prepare a
report documenting the following:

Date of inspection

Address of building and units

Date of construction of building and units

Unit numbers (if applicable)

Name, address, and telephone number of the owner of building and units

Name, signature, and certification number of each certified inspector
and/or risk assessor conducting testing

Name, address and telephone of the certified firm employing the
individual (if applicable)

Each testing method and device and/or sampling procedure employed,
including quality control data, and, if used, the serial number of the
XRF device

Specific locations of each painted component tested for lead-based paint

Result of the inspection expressed according to the particular sampling
method.

	For a risk assessment:

Date of risk assessment

Address of residences and buildings

Date of construction of residences and buildings

Unit numbers (if applicable)

Name, address and telephone number of the owner of residences and
buildings

Name, signature, and certification number of risk assessor conducting
the assessment

Name, address, and telephone number of certified firm employing the risk
assessor (if applicable)

Results of visual inspection

Name, address, and telephone of each recognized laboratory conducting
analyses of samples

Testing methods and sampling procedures for paint analysis employed

Specific locations of each painted component tested for the presence of
LBP

All data collected from on-site testing

All results of laboratory analyses on samples

Any other sampling results

Any background information collected prior to the activity

An evaluation of any previous inspections, analyses, or assessments of
LBP, if applicable

Description of the location and type of identified LBP hazards

Description of options for addressing any LBP hazards.

	For a lead hazard screen:

First 15 items on the risk assessment list above

Recommendations concerning desirability of follow-up risk assessment.

	For all abatements, the individual/firm must first submit to EPA prior
notification of abatement activities.

	Before an abatement, the individual/firm must prepare an occupant
protection plan describing the measures that the individual/firm will
take during the abatement to protect building occupants from exposure to
lead-contaminated dust and debris.

	Following the abatement, the individual or supervisor must prepare a
report detailing the following:

Start and completion dates

Name and address of each individual or firm conducting the abatement(s)
and each supervisor assigned to the project

The occupant protection plan

Name, address, and signature of each certified risk assessor or
inspector conducting sampling and the date of clearance testing

Results of clearance testing and all soil analyses, and name of
laboratory conducting them

A detailed description of the abatement, including method employed,
locations of rooms and/or components, reasons for selecting abatement
methods for particular components

	The Agency will make use of existing technology to simplify the
application and notification processes where available.  In addition to
the more traditional methods (mail, commercial delivery service, or hand
delivery), the Agency will accept faxed course notifications from
training providers as well as notifications through the Central Data
Exchange (CDX).  In addition, lead abatement and evaluation firms may
use CDX to apply for certification and re-certification, but
individuals, renovation, repair, and painting firms must apply by mail.

	5(c)	Small Entity Flexibility

	EPA has attempted to ensure that regulatory requirements do not unduly
burden small businesses.  The certification process for firms and
individuals is very simple.  EPA allows flexibility in the way that
information is prepared and presented, in that there are no mandatory
forms to complete, CDX can be used in many instances, and faxed
notifications are also permitted.     

	5(d)	Collection Schedule

	For authorization, certification and accreditation, collection
activities will occur according to the following schedule:

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

Training providers may apply for accreditation at any time

Training programs must apply for re-accreditation every four years
following initial accreditation

Firms/individuals may apply for certification at any time

Firms must apply for re-certification every five years after initial
certification for renovations

Firms/individuals must apply for re-certification every three years
(five for individuals who have passed a proficiency test as part of
their training) after initial certification for lead-based paint
activities

	The Agency believes that receipt of notification of five and seven
business days respectively prior to conducting lead-based paint
abatement activities or training courses is necessary to facilitate the
inspection of abatement and training locations.  The regulation also
includes provisions for updating the original notification.  The Agency
determined that the time periods for initial notification will also
apply to a change in course location, or if the course is to be
presented earlier than described in the original notification.  Other
changes, including cancellation of courses or abatement projects, need
only be received by the Agency at least two business days before a
training course is scheduled to begin, or by the start date of an
abatement activity.  Such notification periods are appropriate to allow
proper allocation of EPA compliance monitoring and enforcement
resources, and to prevent the arrival of Agency personnel at the wrong
location or time.

6.	ESTIMATING THE BURDEN AND COST

This section estimates the burden of reporting and recordkeeping for the
lead-based paint (LBP) activity requirements under sections 402 (a) and
404 of TSCA and the renovation, repair, and painting (RRP) requirements
under TSCA section 402(c)(3).  This burden combines the burdens approved
under three previously approved ICRs:  (1) EPA ICR No. 1715.09 (the ICR
renewal for the lead-based paint activities/abatement program), (2) EPA
ICR No. 1715.10 (the ICR addendum for the 2008 RRP final rule), and (3)
EPA ICR No. 1715.12 (the ICR addendum for the 2010 RRP opt-out and
recordkeeping final rule).  This supporting statement provides average
annual burden and cost estimates for the next three years of the
program.  All costs are presented in year 2009 dollars.

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

	6(a)	Estimating Respondent Burden

	This section presents the estimated hour burden associated with this
information collection.  Five types of respondents will be affected by
this information collection activity:

 

LBP training providers: training providers who are accredited to offer
LBP evaluation and abatement training courses; 

RRP training providers: training providers who are accredited to offer
Renovator training courses;

LBP firms: firms who are certified to perform lead-based paint
evaluation and abatement activities;

RRP firms: firms who are certified to perform renovation, repair, or
painting (RRP) activities; and

LBP professionals: individuals who are certified to perform lead-based
paint evaluation and abatement activities.  

The burdens and costs fall into the following categories: 1) applying
for initial accreditation or certification, 2) applying for renewal of
accreditation or certification, 3) annual reporting (or reporting during
the course of the year), and 4) annual recordkeeping (or recordkeeping
during the course of the year).  The reporting burden estimates include
the time associated with completing and sending the reports to the
appropriate authority, as well as the time required for collecting
information needed to complete the report.  The recordkeeping burden
estimates include the time associated with copying, filing and
maintaining the records.  In addition, states, tribes, other
governmental entities administering authorized programs, and the federal
government will be affected in their role as administrators of the
programs.

Training Provider Burden: Number of Training Providers and Accreditation
Applications

EPA estimated the numbers of two different types of training providers:
(1) training providers offering lead-based paint evaluation and
abatement activity courses (LBP training providers), and (2) training
providers offering renovator courses (RRP training providers).  The
number of LBP training providers was estimated from the number of
accredited training provider applications in EPA administered regions in
2007-2009 according to the Federal Lead-Based Paint Program (FLPP)
database.  Since these data only pertain to LBP training providers who
operate in areas administered by EPA, the number of LBP training
providers operating nationwide was estimated assuming that the number of
entities and activities in EPA administered areas represents 17 percent
of the national number of entities and activities.  This value is
derived in EPA’s 1999 Economic Analysis of the Final TSCA Section
402(a)(3) Lead-Based Paint Accreditation And Certification Fee Rule,
which estimated that 17 percent of the lead-based paint hazards
nationwide are in EPA administered states compared to states
administering their own programs.

There were 325 training providers accredited to offer lead-based paint
activities courses in EPA administered areas during the period
2007-2009.  As described above, the number of training providers
accredited nationally is estimated as 325 divided by 17 percent, or
1,912 LBP training providers.  Based on the number of initial
accreditation and renewal accreditation applications received by EPA, it
appears that most training providers file one of these applications each
year.  There are 10 different lead-based paint activities courses, an
initial and a refresher course for five different disciplines, and while
one application can be used to apply for multiple accreditations, it
appears that rather than renewing all accreditations once every four
years, training providers stagger their renewal accreditation
applications, renewing accreditation for a few courses each year.  Based
on the average number of applications received between 2007 and 2009, it
was estimated that about 150 training providers file an initial
accreditation application and 130 file a renewal accreditation
application with EPA in a given year.  Thus, by dividing these numbers
by 17 percent the national number of applications is estimated to be 882
initial accreditation applications and 765 renewal accreditation
applications for LBP training providers.  

EPA expects there will be approximately 600 training providers
accredited for Renovator training.  Since renewal accreditation is
required every 4 years, it was estimated that one quarter of training
providers will seek accreditation in a given year.  Based on the number
of LBP training provider applications recorded in the FLPP database
between 2007 and 2009, 54 percent of accreditations are initial
accreditations, implying that either there is a high rate of turnover
for training providers, or that training providers may let their
accreditation lapse if they offer these courses infrequently. Since 54
percent of LBP training provider accreditation applications are initial
applications, this implies a turnover rate of about 14% per year
(14%=54% divided by 4 years).  Based on this, it is estimated that EPA
will receive 81 initial accreditation applications and 69 refresher
accreditation applications each year over the next three years for RRP
training providers.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  1 : Annual Number of Training
Providers

Entity Type	Number of Entities a

LBP Activity Training Providers

	       Initial Accreditation	883

       Renewal Accreditation	765

       Cohort not applying for accreditation	265

    Total	1,912

Renovator Training Providers

	       Initial Accreditation	81

       Renewal Accreditation	69

       Cohort not applying for accreditation	450

    Total	600

a Number of entities estimated based on data in EPA’s FLPP database.
See text above table for detailed description.



Training Provider Burden: Accreditation and Notification Burden

  REF _Ref270314875 \h  \* MERGEFORMAT  Exhibit 6.2  presents the hour
burden for training providers offering LBP evaluation and abatement
courses as a result of this information collection.  Training providers
applying for their initial accreditation incur a burden associated with
becoming familiar with the rule’s requirements and completing an
accreditation statement and quality control plan.  Those applying for
renewal accreditation incur a burden associated with the renewal
accreditation statement.  All training providers incur recordkeeping and
reporting burdens associated with notifying EPA about upcoming course
offerings and providing EPA with notifications that list the individuals
who have completed their courses.  The estimates of burden hours per
response are adopted from previous ICR renewals, and the numbers of
notifications are estimated based on the number of notifications
received between 2007 and 2009.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  2 : Annual LBP Training Provider
Hour Burden

Activities	Professional Hours a	Clerical Hours a	Burden Hours Per

Activity a	Number of Training Providers b	Number of Events Per Provider
c	Total Burden Hours

Initial accreditation cohort	 	 	 	 	 	 

      Rule Familiarization	8.00	-	8.00	882	1	7,056

      Accreditation Statement	7.60	2.00	9.60	882	1	8,467

      Quality Control Plan	8.00	2.00	10.00	882	1	8,820

Re-accreditation cohort	 	 	 	 	 	 

      Accreditation Statement	3.80	1.00	4.80	765	1	3,672

      Audit	0.20	0.40	0.60	765	1	459

All Firms	 	 	 	 	 	 

      Pre-Notification	-	0.20	0.20	1,912	7	2,677

      Re-Notification	-	0.20	0.20	1,912	3	1,147

      Post-Notification	-	1.60	1.60	1,912	4	12,237

      Recordkeeping	-	0.80	0.80	1,912	1	1,530

   Total Reporting	 	 	 	 	 	44,535

   Total Recordkeeping	 	 	 	 	 	1,530

   Total Reporting and

   Recordkeeping	 	 	 	 	 	46,065

a Hour estimates are from the previously approved ICR for LBP activity
training providers (EPA ICR No. 1715.09). The hour estimates were
rounded to one significant digit for this ICR.

b See   REF _Ref272477168 \h  \* MERGEFORMAT  Exhibit 6.1 .

c Number of notifications are estimated based on the average number of
notifications received by EPA between 2007 and 2009.



  REF _Ref270330313 \h  \* MERGEFORMAT  Exhibit 6.3  presents the hour
burden for RRP training providers offering Renovator courses as a result
of this information collection.  Training providers applying for their
initial accreditation incur a burden associated with becoming familiar
with the rule’s requirements and completing an accreditation
application.  Those applying for renewal accreditation incur a burden
associated with completing the application.  All training providers
incur recordkeeping and reporting burdens associated with notifying EPA
about upcoming course offerings and providing EPA with notifications and
digital photos of the individuals who have completed their courses.  

The estimates for burden hours per response for training providers were
slightly higher in the previously approved ICR for LBP activity training
providers (EPA ICR No. 1715.09) compared to the previously approved ICR
for RRP activity training providers (EPA ICR No. 1715.10).  For
consistency the estimates for burden hours per response from the
previously approved ICR for LBP activity training providers are adopted
here for both types of training providers. The estimated numbers of
notifications per provider are taken from previously approved ICRs for
RRP training providers (EPA ICR No. 1715.10 and 1715.12).

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  3 : Annual RRP Training Provider
Hour Burden

Activity	Professional Hours a	Clerical Hours a	Burden Hours Per

Activity a	Number of Training Providers b	Number of Events Per Provider
c	Total Burden Hours

Initial accreditation cohort	 	 	 	 	 	 

      Rule Familiarization	8.00	0.00	8.00	81	1	648

      Accreditation Statement	7.60	2.00	9.60	81	1	778

      Quality Control Plan	8.00	2.00	10.00	81	1	810

Re-accreditation cohort	 	 	 	 	 	 

      Accreditation Statement	3.80	1.00	4.80	69	1	331

      Audit	0.20	0.40	0.60	69	1	41

All Firms	 	 	 	 	 	 

      Pre-Notification	0.00	0.20	0.20	600	14	1,680

      Re-Notification	0.00	0.20	0.20	600	2	240

      Post-Notification	0.00	1.60	1.60	600	14	13,440

      Digital Photo	0.00	1.30	1.30	600	14	10,920

      Recordkeeping	0.00	0.80	0.80	600	1	480

   Total Reporting	 	 	 	 	 	28,888

   Total Recordkeeping	 	 	 	 	 	480

   Total Reporting and

   Recordkeeping	 	 	 	 	 	29,368

a Hour estimates are from the previously approved ICR for LBP activity
training providers (EPA ICR No. 1715.09). The hour estimates were
rounded to one significant digit for this ICR.

b See   REF _Ref272477168 \h  \* MERGEFORMAT  Exhibit 6.1 .

c Number of notifications are from the previously approved ICRs for RRP
activity training providers (EPA ICR No. 1715.10 and 1715.12). They were
rounded to the nearest digit for this ICR.



Firm Burden: Number of Firms and Certification Applications

  REF _Ref270332164 \h  \* MERGEFORMAT  Exhibit 6.4  presents EPA’s
estimates of the annual number of firms and certification applications. 
During the 2007-2009 period, LBP firms submitted an average of 754 and
791 initial and renewal certification applications per year,
respectively, to EPA.  Since renewal certification is required every
three years, it was estimated that one third of firms will seek
certification in each year.  As described above, the number of national
LBP firm certifications (4,435 initial and 4,653 renewal) is estimated
by dividing the EPA administered estimates (754 initial and 791 renewal)
by 17 percent.  The number of LBP firms in the 2nd year cohort is
assumed to be equal to half the number applying for either initial or
renewal certification.  

The number of RRP firms (312,785 private firms and 7,718 government
firms) affected by this information collection request was taken from
EPA’s (2008) Economic Analysis for the TSCA Lead Renovation, Repair,
and Painting Program Final Rule for Target Housing and Child-Occupied
Facilities and EPA’s (2010) Economic Analysis for the TSCA Lead
Renovation, Repair, and Painting Program Opt-out and Recordkeeping Final
Rule for Target Housing and Child-Occupied Facilities. These economic
analyses estimated a turnover rate of about 18 percent per year,
implying that 18 percent of the stock of certified firms will be
applying for initial certification annually.  Based on this, it is
estimated that EPA will receive 56,301 private firm and 1,389 government
firm initial certification applications each year over the next three
years.  Since this is a recent rule no renewal certifications are
expected during this reporting period.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  4 : Annual Number of Firms and
Certification Applications

Entity Type	Number of Entities a

LBP Activity Firms

	       Initial Certification	4,435

       Renewal Certification	4,653

       2nd year cohort b 	4,544

    Total	13,632

RRP Private Firms

	       Initial Certification	56,301

       Renewal Certification	-

       2nd, 3rd and 4th year cohort	256,484

    Total	312,785

RRP Government Firms

	       Initial Certification	1,389

       Renewal Certification	-

       2nd, 3rd and 4th year cohort	6,329

    Total	7,718

a Number of LBP firms estimated based on data in EPA’s FLPP database.
Number of RRP firms estimated based on related RRP economic analyses in
2008 and 2010. See text above table for detailed description.

b The number of LBP activity firms in the 2nd year cohort is estimated
as the average of those in the initial and renewal certification
cohorts.



Firm Burden: Certification, Reporting and Recordkeeping Burden

  REF _Ref270493465 \h  \* MERGEFORMAT  Exhibit 6.5  presents the hour
burden for LBP activity firms as a result of this information
collection.  Firms applying for their initial certification incur a
burden associated with becoming familiar with the rule’s requirements
and completing the certification application.  Those applying for
renewal certification incur a burden associated with the renewal
certification application.  All LBP firms incur recordkeeping and
reporting burdens associated with lead hazard evaluation reports,
notifying EPA about upcoming abatements, preparing occupant protection
plans, and preparing post-abatement reports.

Assumptions developed for previous LBP activity ICR renewals are the
basis for the estimated burden hours per response and the number of
evaluation reports per LBP firm.  The number of initial certifications,
renewal certifications, notifications, and abatements per firm are
estimated from the average number of applications and notifications
received by EPA between 2007 and 2009.  As described above, the number
of activities in EPA administered areas is divided by 17 percent to
extrapolate to national estimates.  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  5 : Annual LBP Firm Certification,
Reporting, and Recordkeeping Burden Hours

Activity	 Professional

Hours a	 Clerical Hours a	Burden Hours Per 

Activity a 	Number of Firms b	Number of Events Per Firm c	Total Burden
Hours

Initial certification cohort	 	 	 	 	 	 

      Initial Certification	7.50	- 	7.50	4,435	1	33,263

      Certification recordkeeping	 -	0.01	0.01	4,435	1	44

Renewal certification cohort	 	 	 	 	 	 

      Renewal certification	1.50	- 	1.50	4,653	1	6,980

      Certification recordkeeping	 -	0.01	0.01	4,653	1	47

All Firms	 	 	 	 

 

      Evaluation reports	1.86	- 	1.86	13,632	16	405,688

      Pre-abatement notifications	0.50	- 	0.50	13,632	2	13,632

      Abatement re-notifications	0.22	- 	0.22	2,616	1	576

      Occupant protection plan	1.00	- 	1.00	13,632	2	27,264

      Post-abatement report	2.00	- 	2.00	13,632	2	54,528

      Recordkeeping for reports

      and notifications	- 	0.01	0.01	13,632	22	2,999

      Recordkeeping for re-

      notifications	- 	0.01	0.01	2,616	1	26

   Total Reporting	 	 	 	 	 	541,930

   Total Recordkeeping	 	 	 	 	 	3,116

   Total Burden	 	 	 	 	 	545,046

a Hour estimates are from the previously approved ICR for LBP activities
(EPA ICR No. 1715.09). The hour estimates were rounded to two
significant digits for this ICR.  Certifications and notifications are
prepared by Supervisors, evaluation reports are prepared by Inspectors
and Risk Assessors, and occupant protection plans are prepared by
Project Designers.

b  See   REF _Ref270332164 \h  \* MERGEFORMAT  Exhibit 6.4 .

c Number of certifications, notifications, protection plans, and post
abatement reports are estimated based on data in EPA’s FLPP database
between 2007 and 2009.  The number of evaluations is estimated based on
the previously approved ICR (EPA ICR No. 1715.09).  The number of
recordkeeping events is estimated as the sum of the reports and
notifications. Numbers were rounded to the nearest two digits for this
ICR.



The burden for RRP firms differs from that for LBP firms because of
different regulatory requirements.    REF _Ref270343375 \h  \*
MERGEFORMAT  Exhibit 6.6  estimates the burden hours for privately owned
RRP firms as a result of this information collection.    REF
_Ref272737169 \h  \* MERGEFORMAT  Exhibit 6.7  presents the hour burden
for public schools that will be certified RRP firms as a result of this
information collection.  Firms applying for their initial certification
incur a burden associated with becoming familiar with the rule’s
requirements and completing the certification application.  Those
applying for renewal certification incur a burden associated with the
renewal certification application.  All firms incur recordkeeping and
reporting burdens associated with providing owners and occupants with
checklists that document the measures taken to ensure the work was
performed in a lead-safe manner.  The estimates of the numbers of
activities and the burden hours per response are adopted from EPA’s
(2008) Economic Analysis for the TSCA Lead Renovation, Repair, and
Painting Program Final Rule for Target Housing and Child-Occupied
Facilities and EPA’s (2010) Economic Analysis for the TSCA Lead
Renovation, Repair, and Painting Program Opt-out and Recordkeeping Final
Rule for Target Housing and Child-Occupied Facilities.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  6 : Private RRP Firm
Certification, Reporting, and Recordkeeping Burden Hours

Activity	 Professional Hours a	Number of Firms a	Number of Events Per
Firm a	Total Burden Hours

Initial Certification	3.50	56,301	1	197,054

Checklist Provision	 	 	 	 

      Owner-occupied housing	0.05	312,785	28	437,899

      Renter-occupied housing	0.05	312,785	30	469,178

      Owner-performed COFb	0.05	37,534	1	1,877

      Contractor, owner-occ. COFb	0.05	265,867	1	13,293

      Contractor, renter-occ. COFb	0.05	12,511	1	626

Recordkeeping	4.80	312,785	1	1,501,368

Total	 	 	 	2,621,294

a The estimates of the numbers of firms, activities and the burden hours
per response are adopted from EPA’s (2008) Economic Analysis for the
TSCA Lead Renovation, Repair, and Painting Program Final Rule for Target
Housing and Child-Occupied Facilities and EPA’s (2010) Economic
Analysis for the TSCA Lead Renovation, Repair, and Painting Program
Opt-out and Recordkeeping Final Rule for Target Housing and
Child-Occupied Facilities.

b Child Occupied Facility (COF)



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  7 : Government (Public Schools)
RRP Firm Certification, Reporting, 

and Recordkeeping Burden Hours

Burden Element	Professional Hours a	Number of Firms a	Number of Events
Per Firm a	Total Burden Hours

Initial Certification	3.50	1,389	1	4,862

Checklist Provision	 	 	 	 

      Owner-performed COF b	0.05	7,718	8	3,087

Recordkeeping	4.80	7,718	1	37,046

Total	 	 	 	44,995

a The estimates of the numbers of firms, activities and the burden hours
per response are adopted from EPA’s (2008) Economic Analysis for the
TSCA Lead Renovation, Repair, and Painting Program Final Rule for Target
Housing and Child-Occupied Facilities and EPA’s (2010) Economic
Analysis for the TSCA Lead Renovation, Repair, and Painting Program
Opt-out and Recordkeeping Final Rule for Target Housing and
Child-Occupied Facilities.

b Child Occupied Facility (COF)



Individual Reporting Burden

  REF _Ref270409823 \h  \* MERGEFORMAT  Exhibit 6.8  presents the hour
burden for individuals engaged in LBP activities as a result of this
information collection.  Note that there is no burden for individuals
under the RRP program associated with this ICR because Renovators are
not required to send an application to EPA.  Individuals incur burdens
associated with completing the applications for initial and renewal
certification.  The burden per individual is the same as estimated under
previous ICR renewals and the numbers of affected individuals are
estimated from the average numbers of applications received by EPA
between 2007 and 2009.  As described above, the number of individuals in
EPA administered areas is divided by 17 percent to extrapolate to
national estimates.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  8 : LBP Individual Certification
Burden Hours

Burden Element	Professional Hours	Number of Individuals a	Total Burden
Hours

Initial Inspector Certification	1.00	1,696	1,696

Renewal Inspector Certification	1.00	1,167	1,167

Initial Risk Assessor Certification	1.00	5,294	5,294

Renewal Risk Assessor Certification	1.00	6,312	6,312

Initial Supervisor Certification	1.00	3,410	3,410

Renewal Supervisor Certification	1.00	3,212	3,212

Initial Worker Certification	0.50	6,704	3,352

Renewal Worker Certification	0.50	2,792	1,396

Initial Project Designer Certification	0.50	265	133

Renewal Project Designer Certification	0.50	316	158

Total Individual Burden

	26,130

a The numbers of affected individuals are estimated from the average
numbers of applications received by EPA between 2007 and 2009.  As
described above, the number of individuals in EPA administered areas is
divided by 17 percent to extrapolate to national estimates.



	6(b)	Estimating Respondent Costs

	

	The cost estimates addressed in this section are based on the burden
estimates discussed in section 6(a).  Wage rates for each category of
personnel are derived with methods and from sources either identical to
or very similar to those used in previous ICR renewals and related
economic analyses.  However, to simplify the calculations a uniform
loading factor of 60 percent for fringe benefits and overhead was
applied to all categories of labor for this ICR, whereas earlier related
economic analyses utilized occupation-specific loading rates in some
cases. 

Non-governmental wages are drawn from the 2009 full-time mean hourly
earnings annual data 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).  The BLS occupational categories have been revised since the
most previous ICR renewals, and therefore the wages for the occupations
that best match the ICR labor categories were selected as shown in   REF
_Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9 .

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  9 : Private Sector Wage Rates for
Calculating Labor Costs (2009$)

ICR Labor Category	BLS Occupation Category	June 2009 Wage Rate	Wage with
Fringe and Overhead

Training Provider Professional	Professional and related	$32.16	$51.46

Training Provider and LBP Firm Clerical	Office and administrative
support occupations	$16.28	$26.05

Inspector or Risk Assessor	Environmental engineering technicians	$22.48
$35.97

Project Designer	Environmental Engineer	$39.74	$63.58

Supervisor/Renovator	Supervisors/managers of construction trades and
extraction workers	$29.94	$47.90

Abatement Worker	Construction and extraction occupations	$17.50	$28.00

	

Training Provider Cost: Accreditation and Notification Cost

  REF _Ref270486428 \h  \* MERGEFORMAT  Exhibit 6.10  and   REF
_Ref270489077 \h  \* MERGEFORMAT  Exhibit 6.11  present the costs
associated with this information collection for training providers
offering LBP activity courses and Renovator courses, respectively.  The
estimates of the material costs per response are based on the
assumptions from ICR renewals, updated to 2009 dollars.  These costs are
calculated using the burden estimates presented in   REF _Ref270314875
\h  \* MERGEFORMAT  Exhibit 6.2  and   REF _Ref270330313 \h  \*
MERGEFORMAT  Exhibit 6.3 , the wage rates presented above in   REF
_Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9 , and a notification
material cost of $0.10 for a photocopy, $0.03 for an envelope, and $0.44
for a stamp. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  10 : LBP Training Provider Cost
(2009$)

Cost Element	 Number of Training Providers	 Events per Training Provider
Material Cost Per Event 	Total Material Cost a	Total Labor Cost b	Total
Cost

Initial accreditation cohort	 	 	 	 	 	 

      Rule Familiarization	882	1	-	-	$363,102	$363,102

      Accreditation Statement	882	1	-	-	$390,899	$390,899

      Quality Control Plan	882	1	-	-	$409,054	$409,054

Re-accreditation cohort	 	 	 	 	 	 

      Accreditation Statement	765	1	-	-	$169,522	$169,522

      Audit	765	1	-	-	$15,845	$15,845

All Firms	 	 	 	 	 	 

      Pre-Notification	1,912	7	$0.57	$7,629	$69,731	$77,360

      Re-Notification	1,912	3	$0.57	$3,270	$29,885	$33,154

      Post-Notification	1,912	4	$0.57	$4,359	$318,769	$323,128

      Recordkeeping	1,912	1	-	-	$39,846	$39,846

   Total Reporting	 	 	 	$15,258	$1,766,806	$1,782,063

   Total Recordkeeping	 	 	 	-	$39,846	$39,846

   Total Reporting and

   Recordkeeping	 	 	 	$15,258	$1,806,652	$1,821,909

a Material costs for notifications include $0.10 for a photocopy, $0.03
for an envelope, and $0.44 for a stamp.

b Wage rates of $51.46 and $26.05 are applied to the professional and
clerical hour burdens, respectively, presented in   REF _Ref270314875 \h
 \* MERGEFORMAT  Exhibit 6.2 . See   REF _Ref270431967 \h  \*
MERGEFORMAT  Exhibit 6.9  for a summary of wage rate definitions and
sources.



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  11 : RRP Training Provider Cost
(2009$)

Cost Element	 Number of Training Providers	 Events per Training Provider
Material Cost Per Event 	Total Material Cost a	Total Labor Cost b	Total
Cost

Initial accreditation







      Rule Familiarization	81	1	$0.00	$0	$33,346	$33,346

      Accreditation Statement	81	1	$0.00	$0	$35,899	$35,899

      Quality Control Plan	81	1	$0.00	$0	$37,566	$37,566

Re-accreditation cohort	 	 	 	 	 	 

      Accreditation Statement	69	1	$0.00	$0	$15,290	$15,290

      Audit	69	1	$0.00	$0	$1,429	$1,429

All firms	 	 	 	 	 	 

      Pre-Notification	600	14	$0.57	$4,788	$43,764	$48,552

      Re-Notification	600	2	$0.57	$684	$6,252	$6,936

      Post-Notification	600	14	$0.57	$4,788	$350,112	$354,900

      Digital Photo	600	14	$0.57	$4,788	$284,466	$289,254

      Recordkeeping	600	1	$0.00	$0	$12,504	$12,504

   Total Reporting	 	 	 	$15,048	$808,125	$823,173

   Total Recordkeeping	 	 	 	$0	$12,504	$12,504

   Total Reporting and

   Recordkeeping	 	 	 	$15,048	$820,629	$835,677

a Material costs for notifications include $0.10 for a photocopy, $0.03
for an envelope, and $0.44 for a stamp.

b Wage rates of $51.46 and $26.05 are applied to the professional and
clerical hour burdens, respectively, presented in   REF _Ref270330313 \h
 \* MERGEFORMAT  Exhibit 6.3 . See   REF _Ref270431967 \h  \*
MERGEFORMAT  Exhibit 6.9  for a summary of wage rate definitions and
sources.



Firm Certification, Reporting and Recordkeeping Costs

  REF _Ref272739990 \h  \* MERGEFORMAT  Exhibit 6.12 ,   REF
_Ref272739992 \h  \* MERGEFORMAT  Exhibit 6.13 , and   REF _Ref272740514
\h  \* MERGEFORMAT  Exhibit 6.14  present the costs associated with this
information collection for LBP activity firms, private RRP firms, and
government RRP firms, respectively.  The estimates of the material costs
per response are based on assumptions developed for previous ICR
renewals, updated to 2009 dollars.  These costs are calculated using the
burden estimates presented in   REF _Ref270493465 \h  \* MERGEFORMAT 
Exhibit 6.5 ,   REF _Ref270343375 \h  \* MERGEFORMAT  Exhibit 6.6 , and 
 REF _Ref272737169 \h  \* MERGEFORMAT  Exhibit 6.7 ; the wage rates used
are presented in   REF _Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9 
and the material costs used are $0.10 per photocopy, $0.03 for an
envelope, and $0.44 for a stamp. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  12 : LBP Firm Cost (2009$)

Cost Element	 Number of Firms	 Events per Firm	Material Cost Per Event 
Total Material 

Cost a	Total Labor Cost b	Total Cost

Initial certification cohort

 	 	 	 	 

      Initial certification	4,435	1	$0.20	$887	$1,593,274	$1,594,161

      Certification recordkeeping	4,435	1	$0.00	$0	$1,155	$1,155

Renewal certification cohort	 	 	 	 	 	 

      Renewal certification	4,653	1	$0.20	$931	$334,318	$335,249

      Certification recordkeeping	4,653	1	$0.00	$0	$1,212	$1,212

All Firms	 	 	 	 	 	 

      Evaluation reports	13,632	16	$0.30	$65,434	$14,592,609	$14,658,042

      Pre-abatement notifications	13,632	2	$0.67	$18,267	$652,973
$671,240

      Abatement re-notifications	2,616	1	$0.67	$1,753	$27,567	$29,320

      Occupant protection plan	13,632	2	$0.30	$8,179	$1,733,445
$1,741,624

      Post-abatement report	13,632	2	$0.30	$8,179	$2,611,891	$2,620,070

      Recordkeeping for reports

      and notifications	13,632	22	$0.00	$0	$78,125	$78,125

      Recordkeeping for re-

      notifications	2,616	1	$0.00	$0	$681	$681

   Total Reporting	 	 	 	$103,629	$21,546,077	$21,649,706

   Total Recordkeeping	 	 	 	$0	$81,174	$81,174

   Total Reporting and

   Recordkeeping	 	 	 	$103,629	$21,627,251	$21,730,880

a Material costs include $0.10 per copy for photocopies. For
notifications, material costs include $0.03 for an envelope and $0.44
for a stamp.

b Wage rates of $47.90 (Supervisor) are applied to the professional hour
burdens presented in   REF _Ref270493465 \h  \* MERGEFORMAT  Exhibit 6.5
 for certifications and notifications.  The Inspector/Risk Assessor wage
rate ($35.97) is applied to the evaluation report burden presented in  
REF _Ref270493465 \h  \* MERGEFORMAT  Exhibit 6.5 . The Project Designer
wage rate ($63.58) is applied to the occupant protection plan burden
presented in   REF _Ref270493465 \h  \* MERGEFORMAT  Exhibit 6.5 . See  
REF _Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9  for a summary of wage
rate definitions and sources.



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  13 : Private RRP Firm Cost (2009$)

Cost Element	 Number of Firms	 Events per Firm	Material Cost Per Event 
Total Material Cost a	Total Labor Cost b	Total Cost

Initial Certification	56,301	1	$0.57	$32,092	$9,438,863	$9,470,954

Checklist Provision	 	 	 	 	 	 

      Owner-occupied housing	312,785	28	$0.10	$875,798	$20,975,362
$21,851,160

      Renter-occupied housing	312,785	30	$0.20	$1,876,710	$22,473,602
$24,350,312

      Owner-performed COF	37,534	1	$0.10	$3,753	$89,894	$93,647

      Contractor, owner-occ. COF	265,867	1	$0.10	$26,587	$636,751
$663,338

      Contractor, renter-occ. COF	12,511	1	$0.30	$3,753	$29,964	$33,717

Recordkeeping	312,785	1	-	-	$71,915,527	$71,915,527

   Total	 	 	 	$2,818,693	$125,559,963	$128,378,656

Note: Since this is a recent rule no renewal certifications are expected
during this reporting period.

a Material costs include $0.10 per copy for photocopies. For initial
certification, material costs include $0.03 for an envelope and $0.44
for a stamp.

b Wage rates of $47.90 (Renovator) are applied to the professional hour
burdens presented in   REF _Ref270343375 \h  \* MERGEFORMAT  Exhibit 6.6
.  See   REF _Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9  for a
summary of wage rate definitions and sources.



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  14 : Government RRP Firm Cost
(2009$)

Cost Element	 Number of Firms	 Events per Firm	Material Cost Per Event 
Total Material Cost a	Total Labor Cost b	Total Cost

Initial Certification	1,389	1	$0.57	$792	$232,866	$233,658

Checklist Provision	 

 	 	 	 

      Owner-performed COF	7,718	8	$0.10	$6,174	$147,877	$154,051

Recordkeeping	7,718	1	-	-	$1,774,523	$1,774,523

   Total	 	 	 	$6,966	$2,155,265	$2,162,231

a Material costs include $0.10 per copy for photocopies. For initial
certification, material costs include $0.03 for an envelope and $0.44
for a stamp.

b Wage rates of $47.90 (Renovator) are applied to the professional hour
burdens presented in   REF _Ref272737169 \h  \* MERGEFORMAT  Exhibit 6.7
.  See   REF _Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9  for a
summary of wage rate definitions and sources.



Individual Certification, Reporting and Recordkeeping Costs

  REF _Ref270494702 \h  \* MERGEFORMAT  Exhibit 6.15  presents the costs
associated with this information collection for individuals performing
LBP activities.  These costs are calculated using the burden estimates
presented in   REF _Ref270409823 \h  \* MERGEFORMAT  Exhibit 6.8  and
the wage rates presented in   REF _Ref270431967 \h  \* MERGEFORMAT 
Exhibit 6.9 .

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  15 : Individual Costs (2009$)

Cost Element	Number Respondents	Wage Rate	Total Cost

Initial Inspector Certification	1,696	$35.97	$61,005

Renewal Inspector Certification	1,167	$35.97	$41,977

Initial Risk Assessor Certification	5,294	$35.97	$190,425

Renewal Risk Assessor Certification	6,312	$35.97	$227,043

Initial Supervisor Certification	3,410	$47.90	$163,339

Renewal Supervisor Certification	3,212	$47.90	$153,855

Initial Worker Certification	6,704	$28.00	$93,856

Renewal Worker Certification	2,792	$28.00	$39,088

Initial Project Designer Certification	265	$63.58	$8,424

Renewal Project Designer Certification	316	$63.58	$10,046

Total Individual Costs	 	 	$989,058

See   REF _Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9  for a summary
of wage rate definitions and sources.  These wage rates are applied to
the professional burden hours presented in   REF _Ref270409823 \h  \*
MERGEFORMAT  Exhibit 6.8 



	6(c)	Estimating Agency Cost

Government Wage Rates 

The wage rates for state and federal government employees are taken from
the federal government’s GS Salary Table for hourly wages, effective
January 2009 (See   REF _Ref273454450 \h  \* MERGEFORMAT  Exhibit 6.16
).  The wages for EPA headquarters workers are taken from the table
including locality pay for the Washington-Baltimore area. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  16 : Government Wage Rates

ICR Labor Category	Government Occupation Category	2009 Wage Rate	Wage
With Fringe And Overhead

State and EPA Region Professional	GS 11, step 1	$27.03	$43.25

State and EPA Region Clerical	GS 6, step 1	$16.44	$26.30

State and EPA Region Managerial	GS 13, step 1	$38.53	$61.65

Headquarters Professional	GS 11, step 1; DC area	$29.22	$46.75



Authorized Program Costs 

	This ICR renewal includes an estimate for the entities authorized to
administer the LBP and RRP programs.  As discussed in section 6(a) of
this ICR, 39 states and three tribal areas, as well as Puerto Rico and
the District of Columbia, have sought and been granted authorization to
administer their own LBP activity programs under TSCA section 402.  The
labor hours incurred by authorized programs includes the following
activities:

Application processing and recordkeeping 

Certification exam processing and recordkeeping

Training course audits

Fee transactions and waivers

Issuance of certification documents

Public assistance/outreach

Reporting (to overseeing agencies)

Other management

	  REF _Ref273454325 \h  \* MERGEFORMAT  Exhibit 6.17  presents the
labor hours incurred by states, tribes, and other government entities
authorized to administer LBP activity programs.  The estimated hours per
activity incurred by authorized programs were derived in EPA’s (2009)
Economic Analysis for the TSCA Section 402 Lead-Based Paint Program
Accreditation and Certification Fee Rule.  The numbers of events are
estimated as described above for each respondent type.  Following the
previously approved ICR, 83 percent of LBP activity events nationwide
are estimated to occur in areas administered by authorized programs. EPA
expects there will be 20 states total in the next 3 years with the
authorization to administer the RRP program (about 40% of the states).
For example, since there are 44 authorized programs, 765 renewal LBP
activity training provider accreditations and 69 renewal RRP training
provider applications, it is estimated that there are 15 renewal
training provider accreditation applications on average for authorized
programs: 15=(83%*765)/44+(40%*69)/44.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  17 : Authorized Program Labor
Hours 

	Authorized Programs a	Number 

Events Per Program b	Labor Hours Per-Event c	Total 

Labor Hours



	Prof.	Cler.	Mgmt.

	Initial Training Provider Accreditation.	44	18	0.03	17.37	0.16	13,908

Renewal Training Provider Accreditation	44	15	0.01	3.66	0.25	2,587

Initial Firm Certification	44	608	0.05	0.59	0.00	17,121

Renewal Firm Certification	44	88	0.04	0.74	0.00	3,020

Initial Individual Certification	44	328	0.07	0.69	0.01	11,113

Renewal Individual Certification	44	260	0.05	0.81	0.01	9,953

Other Administrative Activities	44	1,317	0.01	0.01	0.01	1,738

   Total	 	 	 	 	 	59,440

a 39 states and three tribal areas, as well as Puerto Rico and the
District of Columbia, have sought and been granted authorization to
administer their own LBP activity programs under TSCA section 402. About
half of the states authorized to administer the LBP activity program are
projected to obtain authorization to administer the RRP program over the
next three years.

b The numbers of events are estimated as described above for each
respondent type, and following the previously approved ICR (EPA ICR No.
1715.09), 83 percent of LBP activity events nationwide are estimated to
occur in areas administered by authorized programs. 

c The estimated labor hours  incurred by authorized programs were
derived in EPA’s (2009) Economic Analysis for the TSCA Section 402
Lead-Based Paint Program Accreditation and Certification Fee Rule. Time
estimates were rounded to the nearest significant two digits and
estimates less than 0.01 were rounded up to 0.01.



This ICR renewal includes a cost estimate for the administration of the
LBP and RRP programs by authorized programs.  As discussed in section
6(a) of this ICR, 39 states and three tribal areas, as well as Puerto
Rico and the District of Columbia,  have sought and been granted
authorization to administer their own programs under TSCA section 402.  
 REF _Ref273539907 \h  \* MERGEFORMAT  Exhibit 6.18  presents the
average annual total costs to authorized programs from this information
collection. 

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  18 : Authorized Program Costs
(2009$)

Cost Element	Total Cost

Initial Training Provider Accreditation	$370,650

Renewal Training Provider Accreditation	$73,988

Initial Firm Certification	$472,962

Renewal Firm Certification	$82,055

Initial Individual Certification	$314,488

Renewal Individual Certification	$275,498

Other State Program Administration Activities	$76,028

Total	$1,665,669

Total costs are calculated by applying the wage rates of $43.25, $26.30,
and $61.65 to the hour burdens presented in   REF _Ref273454325 \h  \*
MERGEFORMAT  Exhibit 6.17  for professional, clerical and managerial,
respectively. See   REF _Ref270431967 \h  \* MERGEFORMAT  Exhibit 6.9 
for a summary of wage rate definitions and sources.  



EPA Costs 

This ICR renewal includes a cost estimate for the administration of the
LBP and RRP programs by the Agency.    REF _Ref270513209 \h  \*
MERGEFORMAT  Exhibit 6.19  presents the average annual total costs to
EPA from this information collection.  The per-activity burdens are
taken from those derived in EPA’s (2009) Economic Analysis for the
TSCA Section 402 Lead-Based Paint Program Accreditation and
Certification Fee Rule.  The labor costs are estimated by applying the
labor burdens shown in   REF _Ref270513209 \h  \* MERGEFORMAT  Exhibit
6.19  by $43.25, $26.30, $61.65, and $46.75 for EPA Region professional,
EPA Region clerical, and EPA Region managerial, and EPA Headquarters
professional labor, respectively (See   REF _Ref270431967 \h  \*
MERGEFORMAT  Exhibit 6.9  for a summary of wage rate definitions and
sources). 

The numbers of events are estimated for each respondent type, and
following the previously approved ICR (EPA ICR No. 1715.09), 17 percent
of LBP activity events nationwide are estimated to occur in areas
administered by EPA. Since about 20 states are projected to obtain
authorization to administer the RRP program over the next few years, it
is estimated that 60 percent of RRP activity events nationwide will
occur in areas administered by EPA Regions during the three year period
covered by this ICR renewal. For example, since there are 765 renewal
LBP activity training provider accreditations, 69 renewal RRP training
provider applications, and 660 occur in areas with authorized programs,
174 (174 = 765 + 69 - 660) are estimated to occur in areas administered
by EPA Regions.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  19 : EPA Labor Hours and Cost

Activity	Number of

 Events a	Labor Hours Per Event 	Total Labor Hours 	Total Labor Cost	

Contract Cost Per Event	Total Cost



Prof.	Cler.	Mgmt.





EPA Region Labor









Initial T. Provider Accred.	171	0.03	17.37	0.16	3,003	$80,027	 	$80,027

Renewal T. Provider Accred.	174	0.01	3.66	0.25	682	$19,506	 	$19,506

Initial Firm Certification	35,373	0.05	0.59	0.00	22,639	$625,377	 
$625,377

Renewal Firm Certification	781	0.04	0.74	0.00	609	$16,551	 	$16,551

Initial Individual Certification	2,937	0.07	0.69	0.01	2,261	$64,000	 
$64,000

Renewal Individual Cert.	2,359	0.05	0.81	0.01	2,052	$56,809	 	$56,809

Other Admin. Activities	41,795	0.01	0.01	0.01	1,254	$54,835	 	$54,835

Total EPA Region Labor	 	 	 	 	32,500	 	 	$917,105

EPA Headquarters Labor	 	 	 	 	 	 	 	 

Headquarters Support	1	4,160	0	0	4,160	$194,480	 	$194,480

Contractor application processing	83,590	 	 	 	 	 	$5.48	$458,073

Contractor database maintenance	1	 	 	 	 	 	$197,397	$197,397

Total EPA HQ Labor	 	 	 	 	4,160	 	 	$849,950

Total EPA Labor	 	 	 	 	36,660	 	 	$1,767,055

a The numbers of events are estimated as described above for each
respondent type, and following the previously approved ICR (EPA ICR No.
1715.09), 17 percent of LBP activity events nationwide are estimated to
occur in areas administered by EPA. 



	6(d)	Bottom Line Burden Hours and Cost

The number of respondents, responses, average per-respondent burden,
total burden, and total costs are shown in   REF _Ref270514243 \h  \*
MERGEFORMAT  Exhibit 6.20 ,   REF _Ref272762804 \h  \* MERGEFORMAT 
Exhibit 6.21 ,   REF _Ref272762806 \h  \* MERGEFORMAT  Exhibit 6.22 ,
and   REF _Ref272762807 \h  \* MERGEFORMAT  Exhibit 6.23 .  The
estimates of the numbers of small firms and governments are estimated
from the previous ICR renewals and related economic analyses.  The
average annual paperwork burden is estimated be 3,312,524 hours.  The
total annual respondent cost for the collection of notification
information is estimated to be $155,901,692.  The Agency cost is
estimated to average $3,432,724 per year, as shown in   REF
_Ref270514462 \h  \* MERGEFORMAT  Exhibit 6.24 .  

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  20 : Total Respondent Burden and
Cost for Individuals

Respondent Type	Number Respondents	Responses Per Respondent	Number
Responses	Average Burden Hours Per Response	Total Burden Hours	Total
Cost

Initial Inspector	1,696	1	1,696	1.00	1,696.00	$61,005.12 

Renewal Inspector	1,167	1	1,167	1.00	1,167.00	$41,976.99 

Initial Risk Assessor	5,294	1	5,294	1.00	5,294.00	$190,425.18 

Renewal Risk Assessor	6,312	1	6,312	1.00	6,312.00	$227,042.64 

Initial Supervisor	3,410	1	3,410	1.00	3,410.00	$163,339.00 

Renewal Supervisor	3,212	1	3,212	1.00	3,212.00	$153,854.80 

Initial Worker	6,704	1	6,704	0.50	3,352.00	$93,856.00 

Renewal Worker	2,792	1	2,792	0.50	1,396.00	$39,088.00 

Initial Project Designer	265	1	265	0.50	132.50	$8,424.35 

Renewal Project Designer	316	1	316	0.50	158.00	$10,045.64 

Total	31,168	1	31,168	0.8383438142	26,130	$989,058 



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  21 : Total Respondent Burden and
Cost for Private Firms

Respondent Type	Number of Small Respon-dents	Number of Respondents
Responses Per Respondent	Number of Responses	Average Burden Per Response
Total Burden Hours	Total Cost

Reporting Burden

LBP Training Providers







	Initial Accreditation	829	882	1	882	27.60	24,343.20	$1,163,054.59

Renewal Accreditation	719	765	1	765	5.40	4,131.00	$185,367.15

Pre-Notification	1,798	1,912	7	13,384	0.20	2,676.80	$77,359.52

Re-Notification	1,798	1,912	3	5,736	0.20	1,147.20	$33,154.08

Post-Notification	1,798	1,912	4	7,648	1.60	12,236.80	$323,128.00

RRP Training Providers







	Initial Accreditation	76	81	1	81	27.60	2,235.60	$106,811.14 

Pre-Notification	564	600	14	8,400	0.20	1680	$48,552.00 

Re-Notification	564	600	2	1200	0.20	240	$6,936.00 

Post-Notification	564	600	14	8,400	1.60	13,440.00	$354,900.00 

RRP Training Provider Digital Photos	564	600	14	8,400	1.30	10,920.00
$289,254.00 

LBP Activity Firms

Initial Certification	4,390	4,435	1	4,435	7.50	33,262.50	$1,594,160.75 

Renewal Certification	4,606	4,653	1	4,653	1.50	6,979.50	$335,248.65 

Evaluation reports	13,493	13,632	16	218,112	1.86	405,688.32
$14,658,042.47 

Pre-abatement notifications	13,493	13,632	2	27,264	0.50	13,632.00
$671,239.68 

Abatement re-notifications	2,589	2,616	1	2,616	0.22	575.52	$29,320.13 

Occupant protection plan	13,493	13,632	2	27,264	1.00	27,264.00
$1,741,624.32 

Post-abatement report	13,493	13,632	2	27,264	2.00	54,528.00
$2,620,070.40 

Private RRP Firms

Initial Certification	55,727	56,301	1	56,301	3.50	197,053.50
$9,470,954.22 

Recordkeeping

LBP Training Provider	1,893	1,912	1	1,912	0.80	1,529.60	$39,846.08 

RRP Training Provider 	594	600	1	600	0.80	480.00	$12,504.00 

LBP Firm Certification.	8,995	9,088	1	9,088	0.01	90.88	$2,367.42 

LBP Firm Reports	13,493	13,632	22	299,904	0.01	2,999.04	$78,124.99 

LBP Firm Re-notifications	2,589	2,616	1	2,616	0.01	26.16	$681.47 

RRP Firm Recordkeeping	309,598	312,785	1	312,785	4.80	1,501,368.00
$71,915,527.20 

Third Party Disclosure: RRP Firm Checklists

RRP Firm Checklist Owner TH	309,598	312,785	28	8,757,980	0.05	437,899.00
$21,851,160.10

RRP Firm Checklist Renter TH	309,598	312,785	30	9,383,550	0.05
469,177.50	$24,350,312.25

RRP Firm Checklist In house/Landlord	37,152	37,534	1	37,534	0.05
1,876.70	$93,647.33

RRP Firm Checklist COF Owner Contractor	263,158	265,867	1	265,867	0.05
13,293.35	$663,338.17

RRP Firm Checklist COF Renter Contractor	12,384	12,511	1	12,511	0.05
625.55	$33,717.15

Overall Private Firm Bottom Line

Reporting subtotal	325,453	328,929	1.285399	422,805	1.9205874	812,034
$33,709,177 

Recordkeeping subtotal	325,453	328,929	1.9058976	626,905	2.4030653
1,506,494	$72,049,051 

Third party disclosure subtotal	309,598	312,785	59.0099973	18,457,442
0.05	922,872	$46,992,175 

Total	325,453	328,929	59.3050537	19,507,152	0.1661647	3,241,400
$152,750,403 



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  22 : Total Respondent Burden and
Cost for Government Firms

Respondent Type	Number of Small Respon-dents	Number of Respondents
Responses Per Respondent	Number  of Responses	Average Burden Per
Response	Total Burden Hours	Total Cost

Reporting Burden

Initial Certification	1,375	1,389	1	1,389	3.50	4,861.50	$233,657.58

Recordkeeping

RRP Firm Recordkeeping	7,639	7,718	1	7,718	4.80	37,046.40	$1,774,522.56

Third Party Disclosure: RRP Firm Checklists

Checklist COF In- house/Landlord	7,639	7,718	8	61,744	0.05	3,087.20
$154,051.28

Overall Government Firm Bottom Line

Total	7,639	7,718	9.17997	70,851	0.63507	44,995	$2,162,231 



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  23 : Overall Respondent Bottom
Line Burden and Cost

Respondent Type	Number of Small Respon-dents	Number of Respondents
Responses Per Respondent	Number of Responses	Average Burden Per Response
Total Burden Hours	Total Cost

Individuals	n.a.	31,168	1	31,168	0.8383438142	26,130	$989,058 

Private Firms	325,453	328,929	59.3050537	19,507,152	0.1661647	3,241,400
$152,750,403 

Governments	7,639	7,718	9.17997	70,851	0.63507	44,995	$2,162,231 

Total	333,092	367,815	-	19,609,171	-	3,312,524	$155,901,692 



Exhibit 6.  SEQ Exhibit_6. \* ARABIC  24 : EPA Labor Hours and Cost

Type	Total Cost



	Authorized Programs	$1,665,669 

EPA Regions 	$917,105 

EPA HQ 	$849,950 

Total EPA 	$3,432,724 



6(e)	Reasons For Changes in Burden

	

This information collection combines the burdens from three previously
approved ICRs, EPA ICR No. 1715.09, EPA ICR No. 1715.10, and EPA ICR No.
1715.12.  The total combined burden from these three previously approved
ICRs was 3,804,495 hours.  The total burden requested for this ICR is
3,312,524 hours. Note that the pre-renovation education burden for Child
Occupied Facilities is no longer accounted for in this ICR, but was
included in EPA ICR No. 1715.10.  This pre-renovation education burden
has been moved from this ICR to the renewal request for the
pre-renovation education ICR, EPA ICR No. 1669. The difference between
the current burden request and the previously approved requests are due
to adjustments in EPA’s estimates of the burden.  Several adjustments
to the estimates were made, including:

Revisions to the estimated number of respondents based on the number of
respondents reporting to EPA for the prior information collection;

Revisions to the per-activity burden estimates to simplify some
assumptions (e.g., rounding a per-activity burden to 0.01 from 0.0083)
and to make estimation methods consistent across the three different
ICRs (e.g., include envelope costs for all notifications, where not all
previously approved ICRs included envelope costs); and

Burden hours and costs to authorized programs are accounted for as
Agency burden rather than respondent burden for this ICR.

The total combined cost burden from these three previously approved ICRs
was $127,139,355.  The total cost burden requested for this ICR will be
$155,901,692.  The difference between the current cost burden request
and the previously approved requests are due only to adjustments in
EPA’s estimates of the burden.  In addition to the adjustments listed
above, the wage rates and material costs were revised to reflect 2009
dollars for this information collection request.    REF _Ref273436103 \h
 \* MERGEFORMAT  Exhibit 6.25  presents a comparison of the current and
previously approved information collection requests.  The primary
reasons for the differences are as follows:

The overall burden for individuals performing LBP activities is higher
since more individuals are estimated to apply for certification in the
current ICR.  This higher estimate is due to an increase in the number
of individual applications received by EPA between 2007 and 2009.

The overall burden for LBP activity training providers is higher for
this ICR despite a decrease in the number of training providers. Based
on the number of accreditation applications received by EPA between 2007
and 2009, each training provider submits more accreditation applications
than previously estimated. This appears to be because training providers
are submitting separate applications for separate courses rather than
applying for accreditation in multiple courses at one time. The decrease
in the number of training providers is due to a decrease in the number
of EPA accredited providers over the 2007 to 2009 period.

The overall burden for RRP training providers is higher for this ICR
despite a lower burden estimate per provider.  The burden per RRP
training provider is lower because all training providers needed to
apply for initial accreditation during the previous reporting period
which covered the initial implementation of the rule.  Most RRP training
providers will not need to renew their accreditation during this
reporting period. This ICR estimates an increase in the estimated number
of accredited RRP training providers.  

The overall burden for LBP firms is lower for this ICR as the effect of
a lower burden per firm dominates the effect of the increase in the
estimated number of firms.  The lower estimated burden per firm is
because EPA received substantially fewer notifications per firm between
2007 and 2009 than was estimated for the previous information collection
request. Specifically, the average firm during 2007-2009 performed one
abatement instead of the 14 abatements estimated in the previously
approved ICR.

The overall burden for private and government RRP firms is lower for
this ICR primarily due to a lower burden per firm. The burden per firm
is lower because most firms applied for certification at the end of the
previous reporting period and will not need to renew it during this
reporting period. The number of firms is estimated to be slightly
smaller for this reporting period following the related economic
analyses, which assumed that the number of firms would decline slightly
over time with the size of the pre-1978 housing stock.

The burden for authorized programs is accounted for along with agency
costs in the current ICR, rather than as respondent burden.

Exhibit 6.  SEQ Exhibit_6. \* ARABIC  25 : Comparison of Current and
Previous Information Collection Request

Respondent Type	Number of Respondents	Burden Per Respondent	Respondent
Burden Hours

Previously Approved Information Collection

LBP Individuals	11,336	0.83	9,420

LBP Training Providers	2,483	1.74	4,322

RRP Training Providers	167	127.88	21,356

LBP Firms	8,466	80.13	678,384

Private RRP Firms	314,074	9.42	2,960,028

Government RRP Firms	7,750	6.92	53,629

Authorized Programs	44	1,877.59	82,614

Total	344,320	11.06	3,809,753

Current Information Collection Request

LBP Individuals	31,168	0.84	26,130

LBP Training Providers	1,912	24.09	46,065

RRP Training Providers	600	48.95	29,368

LBP Firms	13,632	39.98	545,046

Private RRP Firms	312,785	8.38	2,621,294

Government RRP Firms	7,718	5.83	44,995

Authorized Programs	0	0.00	0

Total	367,815	9.01	3,312,524

Difference In Estimates

LBP Individuals	19,832	0.01	16,710

LBP Training Providers	-571	22.35	41,743

RRP Training Providers	433	-78.93	8,012

LBP Firms	5,166	-40.15	-133,338

Private RRP Firms	-1,289	-1.04	-338,734

Government RRP Firms	-32	-1.09	-8,634

Authorized Programs	-44	-1877.59	-82,614

Total	23,495	-2.05	-497,229



6(f)	Burden Statement

The annual public burden for this collection of information, which is
approved under OMB Control No. 2070-0155, is estimated to average 0.8
hours for individuals, 9.9 hours for firms, and 5.8 hours for
governments (calculated from the number of respondents and total hour
burden presented in   REF _Ref272762807 \h  \* MERGEFORMAT  Exhibit 6.23
).  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 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.

	The Agency has established a public docket for this ICR under Docket ID
No. EPA-HQ-OPPT-2010-1007, which is available for online viewing at
www.regulations.gov, or in person viewing at the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington,
DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Pollution Prevention and Toxics Docket is (202)
566-0280.  You may submit comments regarding 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.

Submit your comments, referencing Docket ID No. EPA-HQ-OPPT-2010-1007
and OMB Control No. 2070-0155, to (1) EPA online using
www.regulations.gov (our preferred method), or by mail to: Document
Control Office (DCO), Office of Pollution Prevention and Toxics (OPPT),
Environmental Protection Agency, Mail Code: 7407T, 1200 Pennsylvania
Ave., NW,  Washington, D.C. 20460, and (2) OMB by mail to: Office of
Information and Regulatory Affairs, Office of Management and Budget
(OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington,
DC 20503.

 EPA ICR No. 1715.11 was the ICR addendum for the opt-out and
recordkeeping proposed rule, and was superseded by the ICR addendum for
the final rule.

 EPA ICR No. 1715.11 was the ICR addendum for the opt-out and
recordkeeping proposed rule, and was superseded by the ICR addendum for
the final rule.

 The FLPP database indicates that there were about 300 initial
accreditation applications for the worker discipline course, which is
the most frequently offered course.  Since there are two types of worker
courses (initial and refresher), 300 was divided by two to estimate that
150 training providers apply for initial accreditation annually. Thus,
it is assumed that training providers applying for accreditation in
other disciplines are applying for worker course accreditation at the
same time.  The number of training providers applying for renewal
accreditation is estimated using the same method and assumptions (there
were about 259 renewal accreditation applications for the worker
discipline course).

 Burdens were rounded to the nearest significant two digits and burdens
less than 0.01 were rounded up to 0.01.

