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

ATTACHMENT 10

Copy of Consultations Message Sent by EPA to Potential Respondents

Date:		December 10, 2010	

From:		Christine Koester

USEPA HQ/OPPT/NPCD 

To: 		[Addressees]

	

Subject:	Request for assistance; renewal of "  SEQ CHAPTER \h \r 1 TSCA
Sections 402 and 404 Training and Certification, Accreditation and
Standards for Lead Based Paint Activities and Renovation, Repair and
Painting" ICR 

	

The U.S. Environmental Protection Agency (EPA) seeks your comments on
the regulation set forth in 40 CFR 745, Subparts E, L, and Q.

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.  The current regulations in 40 CFR part 745,
subpart Q, establish the requirements that State or Tribal programs must
meet for authorization to administer the standards, regulations, or
other requirements established under TSCA Section 402.  

Because the regulation involves the potential collection of information
from a large number of individuals, EPA is required to submit an
Information Collection Request (ICR) to the Office of Management and
Budget (OMB) for approval, and to renew the ICR every three years.  EPA
is currently in the process of renewing the ICR for the above-described
regulation.  A draft copy of the ICR renewal is attached hereto, and
will also be published in the Federal Register sometime in the near
future.

The requirements under this regulation directly impact the members of
your organization.  As such, EPA requests that you complete the attached
questionnaire as thoroughly as possible to represent your organization's
viewpoint on what can be done to change or improve the process.  The
information you provide will have an impact on government efficiency. 

If you have any comments in response to the attached questions, or with
respect to any other part of the information collection, please respond
by return e-mail by February 10, 2011.  EPA will consider those
responses, as well as any public comment received in response to the
Federal Register Notice identified above, in preparing a final document
for OMB review.  Your timely response will be greatly appreciated.

  

Sincerely,

Christine J. Koester

U.S. Environmental Protection Agency

Office of Chemical Safety and Pollution Prevention

Office of Pollution Prevention and Toxics

Lead, Heavy Metals, and Inorganics Branch

202-566-1468

 

EPA solicits your input on the following questions:

1. Are the data EPA seeks under this ICR available from any public
source, or already collected by another EPA office or by another agency?
 If so, where can the data be found?

2. Is it clear what is required for data submission?  If not, are there
any suggestions for clarifying instructions?

Do firms and individuals understand that you must retain records for
three years?

Do training providers understand that you must retain records for as
long as the individual is certified for a period of three and a half
years?

3.  Currently, abatement and evaluation firms may apply online via CDX
(Central Data Exchange).  EPA will not share information provided via
CDX with third parties.

a) If you are an abatement or evaluation firm, are you interested in
using or are you currently using CDX to apply?

b) If you are a renovation, repair, and painting firm, an individual
lead-based paint professional, or a training provider, would you be
interested in using CDX to apply for certification?

4. For electronic submission, how should EPA handle signature
requirements – Private Key Infrastructure, PINS and passwords, signed
paper cover sheet?

5. Do you agree with EPA's estimated burden and costs (the ICR addresses
only the costs associated with paperwork)?  Are the Bureau of Labor
Statistics (BLS) labor rates accurate?  If you have any reason to
consider the BLS labor rates as used by EPA inaccurate or inappropriate,
explain your rationale.

6. Do you have any other comments concerning this Information Collection
Request?

