            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 [RIN 2070-AK02]

	EPA ICR No.:  2502.01	OMB Control No:  2070-NEW

	1(b)	Short Characterization
      
      This information collection request (ICR) addendum revises an existing, approved ICR (EPA ICR No. 1715.13, OMB Control No. 2070-0155) which covers 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). This addendum incorporates reporting and recordkeeping requirements in a proposed rule that would eliminate the hands-on requirement from the renovator refresher training course.  If this change is implemented, EPA expects training providers that are currently accredited to teach the renovator refresher training to apply for accreditation to teach the course via e-learning (i.e., via the internet). Only changes that would result from the proposed rule are included in this addendum.  Portions of the existing ICR that are not affected by the proposed rule are not included in this document. 
      

2.	NEED FOR AND USE OF THE COLLECTION

            2(a)	Need/Authority for the Collection

	No Change

	2(b)	Practical Utility/Users of the Data

      No Change


3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
      
      3(a)	Non-Duplication
      
      No Change
      
      3(b)	Public Notice Required Prior to ICR Submission to OMB
      
	The notice of proposed rulemaking serves as the public notice for this ICR addendum.  Interested parties should submit comments to the address listed at the end of this document.  Responses will be taken into account in developing the final rulemaking.
		
	3(c)	Consultations and Public Comments

      No Change

 	3(d)	Effects of Less Frequent Collection

      No Change.
      
      3(e)	General Guidelines
      
      No Change
      
      3(f)	Confidentiality
      
	No Change

	3(g)	Sensitive Questions

	No Change


4.	THE RESPONDENTS AND INFORMATION REQUESTED

      4(a)	Respondents/NAICS Codes
      
	No Change

	4(b)	Information Requested
	
	No Change

		(i)	Data Items
	
      To receive accreditation to provide lead-based paint activities or renovation training, training providers must submit documents to EPA/state, using the form entitled "Application and Instructions for Training Providers" (see Attachment 3) or a similar form containing the required information. Under the proposed rule that this ICR addendum addresses, EPA expects training providers accredited for the renovator refresher course to apply for accreditation to teach the e-learning version of the course.  Accredited training providers are eligible for an expedited e-learning course accreditation if they want to teach an already reviewed and accepted e-learning course. Currently-accredited training providers seeking accreditation for the e-learning refresher course must submit the following information to EPA.  
   *          A cover letter
   *          A training provider application to amend their accreditation; 
   *          An e-learning quality control (QC) plan.  
      (ii)	Respondent Activities
      
         No Change


5.	AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

   5(a)	Agency Activities
   
         No Change

      5(b)	Collection Methodology and Management
   
      This section includes the data elements for training providers that are expected to be impacted by the proposed rule.  Under the proposed rule, EPA expects training providers accredited for the renovator refresher course to apply for accreditation to teach the e-learning version of the course.  Accredited training providers are eligible for an expedited e-learning course accreditation if they want to teach an already reviewed and accepted e-learning course. Currently-accredited training providers must submit to EPA the following information to seek accreditation for the e-learning refresher course:  
   *          A cover letter
   *          A training provider application to amend their accreditation (see Attachment 3); 
   *          An e-learning quality control (QC) plan.  
 	5(c)	Small Entity Flexibility
 
 	No Change     

	5(d)	Collection Schedule

	No Change     


ESTIMATING THE BURDEN AND COST

	This section estimates the incremental reporting burden for training providers that may result from the proposed revisions to EPA's renovation, repair, and painting (RRP) program requirements.  This burden is incremental to the burden for EPA's lead paint program that has already been accounted for in an existing, approved ICR (EPA ICR No. 1715.13, OMB Control No. 2070-0155). This supporting statement provides burden and cost estimates for three years of the program.  All costs are presented in year 2014 dollars.  

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

	The majority of RRP training providers are predicted to attain accreditation for an e-learning refresher training course as a result of the proposed rule. Accredited training providers may add an already-reviewed e-learning curriculum through an expedited course approval process. Impacts are estimated for training providers currently offering an accredited refresher training course that are assumed to seek accreditation for an e-learning course.	

Estimating Respondent Burden
	
	The burden estimates in this information collection request are for training providers that are accredited to offer renovator refresher training courses. Training providers currently accredited for the renovator refresher training course are expected to apply for an additional accreditation for an e-learning refresher training course as result of the proposed rule.  Therefore they would incur an incremental paperwork burden associated with becoming familiar with the rule's requirements and with applying for accreditation to teach an online version of the renovator refresher training. All requests to add an already-reviewed e-learning curriculum to an already-accredited training provider's record must include a cover letter; a training provider application to amend their accreditation; and an e-learning quality control (QC) plan.  The e-learning QC plan must address issues such as how the trainer will ensure that students successfully complete the e-learning modules and the e-learning module final assessment. Recordkeeping burdens and reporting burdens associated with notification are not incorporated into the incremental burden because they are incurred with or without this proposed rule, and are accounted for under the existing approved ICR (EPA ICR No. 1715.13). 

      There are 275 training providers with accredited renovator refresher training programs (see Exhibit 6.1). Training provider accreditation data are taken from the Federal Lead-based Paint Program (FLPP) database.

Exhibit 6.1 Number of RPP Training Providers 
                                  Entity Type
                   Number of Entities Accredited in Year 1  
RPP Training Provider
                                      275
      
      Exhibit 6.2 presents the number of burden hours per activity and Exhibit 6.3 presents total and average burden hours per training provider. Unit burden hour estimates are assumed to be half of the burden hour estimates from the previously approved ICR (EPA ICR No. 1715.13) because less information needs to be provided, given that the training provider has already been accredited for an in-person course. As presented in Exhibit 6.3, the burden for all training providers is estimated to be 3,795 hours in Year 1, and 0 hours in Year 2 and Year 3. (The burden is 0 hours in Year 2 and Year 3 because all 275 training providers are assumed to apply for accreditation for the e-learning course in Year 1.) The average annual aggregate burden for training providers over the three years covered by this ICR is 1,265 hours. 

Exhibit 6.2 RRP Training Providers: Accreditation Burden
Activity
          Number of Activities per Training Provider in first Year[1]
                        Reporting Hours per Activity[2]

                                       
                              Professional Hours
                                Clerical Hours
                                  Total Hours
Rule Familiarization
                                       1
                                      4.0
                                      0.0
                                      4.0
Accreditation Statement
                                       1
                                      3.8
                                      1.0
                                      4.8
Quality Control Plan
                                       1
                                      4.0
                                      1.0
                                      5.0
Annual Total
                                       
                                     11.8
                                      2.0
                                     13.8
[1]Number of activities are from the previously approved EPA ICR No. 1715.13. 
[2]Burden hour per activity are assumed to be half the vales in the previously approved EPA ICR No. 1715.13. The hour estimates were rounded to one decimal place for this ICR.

Exhibit 6.3 Total and Average Accreditation Burden Hours
                                     Year
                             Number of Respondents
                             Burden Per-Respondent
                                 Total Burden
                                       1
                                      275
                                     13.8
                                     3,795
                                       2
                                       
                                       -
                                       -
                                       3
                                       
                                       -
                                       -
                                3-Year Average
                                       
                                      4.6
                                     1,265

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.  Exhibit 6.4 presents loaded wage rates for training provider professional and clerical staff, which are $53.66 and $26.79, respectively. Wage and fringe benefit data are taken from the Employer Cost for Employee Compensation data series published by the Bureau of Labor Statistics (BLS).  Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPI for All Urban Consumers published by the BLS. The overhead data is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Program. The overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage to derive the fully loaded wage (see Exhibit 6.4).
 
Exhibit 6.4 Private Sector Wage Rates for Calculating Labor Costs (2014$)
Labor Category
BLS Occupation Category[1]
                                     Date
                                    Wage[1]
                                Fringe Benefit
                             Fringe
(% of Wage)[1]
                            Overhead
(% of Wage)[2]
                                Wage Multiplier
                                Loaded Wages[3]



                                      (a)
                                      (b)
                                      (c)
                                   =(b)/(a)
                                      (d)
                                      (e)
                                  =1+(c)+(d)
                                      (f)
                                   =(a)*(e)
Professional
Professional and related
                                     9/12
                                    $33.96
                                    $13.92
                                      41%
                                      17%
                                     1.58
                                    $53.66
Clerical
Office and administrative support
                                     9/12
                                    $16.64
                                     $7.32
                                      44%
                                      17%
                                     1.61
                                    $26.79
[1]Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation - September 2013." Private industry workers, goods-producing and service-producing.
[2]U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. Environmental Protection  Agency, Office of Environmental Information, Environmental Analysis Division, Analytical Support Branch.
[3]Wage rates are rounded to the closest penny.
 
      Exhibit 6.5 estimates the cost per activity associated with this information collection for training providers offering renovator courses. This yields an average cost of $687 per training provider. As shown in Exhibit 6.6, total training provider costs are estimated to be $188,925 in the first year of the rule, and $0 in the second and third years.  The average annual cost over the three years covered by this ICR is $62,975. 
 
Exhibit 6.5 RRP Training Providers: Accreditation Cost Estimates (2014$)
Activity
                        Reporting Hours per Activity[1]
                          Reporting Cost per Activity

                              Professional Hours
                                Clerical Hours
                                  Total Hours
                                 Professional 
                                  (53.66/Hr)
                                   Clerical
                                 ($26.79/Hr) 
                                    Total 
Rule Familiarization
                                      4.0
                                      0.0
                                      4.0
                                    $214.64
                                     $0.00
                                    $214.64
Accreditation Statement
                                      3.8
                                      1.0
                                      4.8
                                    $203.91
                                    $26.79
                                    $230.70
Quality Control Plan
                                      4.0
                                      1.0
                                      5.0
                                    $214.64
                                    $26.79
                                    $241.43
Total
                                     11.8
                                      2.0
                                     13.8
                                   $633.19 
                                    $53.58 
                                    $686.77
[1]Hour estimates are derived from the previously approved EPA ICR No. 1715.13. The hour estimates were rounded to one decimal place for this ICR.

Exhibit 6.6 Total and Average RPP Training Provider Accreditation Costs (2014$)
                                     Year
                             Number of Respondents
                              Cost Per-Respondent
                                 Total Burden
                                       1
                                      275
                                     $687
                                   $188,925 
                                       2
                                       
                                       -
                                       -
                                       3
                                       
                                       -
                                       -
                                3-Year Average
                                       
                                     $229
                                    $62,975

Estimating Agency Cost
	
	There are also government costs associated with reviewing the expedited e-learning applications.  EPA estimates that it will take 4 hours apiece for an Agency employee to review the 275 training provider e-learning program accreditation applications.  The base wage rate of the federal government employee reviewing applications is taken from the 2014 General Schedule (GS) Locality Pay Table for Washington-Baltimore-Northern Virginia, published by the Office of Personnel Management.  A loaded wage rate of $78.13 is then derived by applying a multiplier of 1.6 to account for fringe benefits and overhead to the base wage rate of a GS-13 Step 5 government employee ($48.83).

	Exhibit 6.7 presents the costs to EPA for Years 1, 2, and 3, as well as the average annual costs.  The costs are calculated by applying the government employee wage rate to the 4 hours of time for each of the 275 accreditation applications.

Exhibit 6.7 EPA Costs (2014$)
                                    Year 1
                                    Year 2
                                    Year 3
                                     Avg.
                                   $85,943 
                                      $0 
                                      $0 
                                    $28,648

Bottom Line Burden Hours and Cost

      Exhibit 6.8 presents a summary of the number of respondents, the respondent burden, and the respondent costs over 3 years. The three year average annual paperwork burden is estimated to be 1,265 hours.  The three year average annual respondent cost is estimated to be $62,975.  The Agency cost is estimated to average $28,648 per year, as shown in Exhibit 6.9.  
      
Exhibit 6.8 Respondent Burden and Cost Summary
                                     Year
                             Number of Respondents
                        Number of Small Respondents[1]
                             Burden Per-Respondent
                                 Total Burden
                              Cost Per-Respondent
                                  Total Cost
                                       1
                                      275
                                      259
                                     13.8
                                     3,795
                                     $687
                                   $188,861
                                       2
                                       
                                       
                                       -
                                       -
                                       -
                                       -
                                       3
                                       
                                       
                                       -
                                       -
                                       -
                                       -
                                3-Year Average
                                       
                                       
                                      4.6
                                     1,265
                                     $229
                                    $62,975
[1]Consistent with the previously approved EPA ICR No. 1715.13, 94% of training providers are assumed to be small entities.
      
Exhibit 6.9 EPA Costs
 
                                    Year 1
                                    Year 2
                                    Year 3
                                     Avg.
EPA
                                   $85,943 
                                      $0 
                                      $0 
                                    $28,648
      
      The total burden in OMB's inventory for the existing, approved ICR for the lead paint program (EPA ICR No. 1715.13) is 3,312,524 hours.  With the addition of the 1,265 program change hours related to the proposed rule, the total burden requested for the lead paint program will be 3,313,789 hours.  
      
Reasons For Changes in Burden
      
      The burden analyzed in this ICR addendum relates to EPA's proposed program change to remove the hands-on requirement from the refresher renovator training.  This is expected to result in a number of training providers applying for accreditation to offer e-learning refresher courses.
      
Program Changes: Additional Respondents Applying for Renovator Refresher Course Accreditation

	EPA estimates that 275 RRP training providers would apply for an accreditation for an e-learning refresher training course as a result of the provision to eliminate the course's hands-on training requirement from the course curriculum.  The addition of these new responses is expected to increase the annual accreditation burden by 1,265 hours.  
      
Burden Statement

      The incremental public burden for this collection of information is estimated to average 13.8 hours per response.  Burden is defined in 5 CFR 1320.3(b).  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA's regulations 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-2014-0304, which is available for online viewing at www.regulations.gov, or in-person viewing at the EPA Docket Center (EPA/DC), EPA William Jefferson Clinton 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-2014-0304 and OMB Control No. 2070-[NEW], 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: 7407M, 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. 



      
      

                       ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this ICR under docket identification number EPA-HQ-OPPT-2014-0304.

                                 Attachment 1:
15 U.S.C. 2682 - Toxic Substances Control Act Sections 402 

                                 Attachment 2:
Accreditation of training programs:  target housing and child-occupied facilities
40 CFR 745.225
                                 Attachment 3:
Application and Instructions for Training Providers - Applying for Accreditation of Lead-Based Paint Activity Training Programs - EPA Form 8500-25. 

      



                 EPA ICR No. 2502.01; OMB Control No. 2070-NEW











                                 ATTACHMENT 1
                                       
                  Toxic Substances Control Act Sections 402 
                                15 U.S.C. 2682

Sec. 2682. Lead-based paint activities training and certification

     (a) Regulations
      (1) In general 
      Not later than 18 months after October 28, 1992, the Administrator shall, in consultation with the Secretary of Labor, the Secretary of Housing and Urban Development, and the Secretary of Health and Human Services (acting through the Director of the National Institute for Occupational Safety and Health), promulgate final regulations governing lead-based paint activities to ensure that individuals engaged in such activities are properly trained; that training programs are accredited; and that contractors engaged in such activities are certified. Such regulations shall contain standards for performing lead-based paint activities, taking into account reliability, effectiveness, and safety. Such regulations shall require that all risk assessment, inspection, and abatement activities performed in target housing shall be performed by certified contractors, as such term is defined in section 4851b of title 42. The provisions of this section shall supersede the provisions set forth under the heading `'Lead Abatement Training and Certification'` and under the heading `'Training Grants'` in title III of the Act entitled `'An Act making appropriations for the Departments of Veterans Affairs and Housing and Urban Development, and for sundry independent agencies, commissions, corporations, and offices for the fiscal year ending September 30, 1992, and for other purposes'`, Public Law 102-139 (105 Stat. 765, 42 U.S.C. 4822 note), and upon October 28, 1992, the provisions set forth in such public law under such headings shall cease to have any force and effect. 
	(2) Accreditation of training programs 
      Final regulations promulgated under paragraph (1) shall contain specific requirements for the accreditation of lead-based paint activities training programs for workers, supervisors, inspectors and planners, and other individuals involved in lead-based paint activities, including, but not limited to, each of the following: 
               (A) Minimum requirements for the accreditation of training providers. 
               (B) Minimum training curriculum requirements. 
               (C) Minimum training hour requirements. 
               (D) Minimum hands-on training requirements. 
               (E) Minimum trainee competency and proficiency requirements. 
               (F) Minimum requirements for training program quality control.
	(3) Accreditation and certification fees 
      The Administrator (or the State in the case of an authorized State program) shall impose a fee on - 
               (A) persons operating training programs accredited under this subchapter; and 
               (B) lead-based paint activities contractors certified in accordance with paragraph (1). 
      The fees shall be established at such level as is necessary to cover the costs of administering and enforcing the standards and regulations under this section which are applicable to such programs and contractors. The fee shall not be imposed on any State, local government, or nonprofit training program. The Administrator (or the State in the case of an authorized State program) may waive the fee for lead-based paint activities contractors under subparagraph (A) for the purpose of training their own employees.

     (b) Lead-based paint activities 
      For purposes of this subchapter, the term `'lead-based paint activities'` means - 
      (1) in the case of target housing, risk assessment, inspection,  and abatement; and 
      (2) in the case of any public building constructed before 1978, commercial building, bridge, or other structure or superstructure, identification of lead-based paint and materials containing lead-based paint, deleading, removal of lead from bridges, and demolition. For purposes of paragraph (2), the term `'deleading'` means activities conducted by a person who offers to eliminate lead-based paint or lead-based paint hazards or to plan such activities. 

     (c) Renovation and remodeling 
	(1) Guidelines 
      In order to reduce the risk of exposure to lead in connection with renovation and remodeling of target housing, public buildings constructed before 1978, and commercial buildings, the Administrator shall, within 18 months after October 28, 1992, promulgate guidelines for the conduct of such renovation and remodeling activities which may create a risk of exposure to dangerous levels of lead. The Administrator shall disseminate such guidelines to persons engaged in such renovation and remodeling through hardware and paint stores, employee organizations, trade groups, State and local agencies, and through other appropriate means. 
      (2) Study of certification 
      The Administrator shall conduct a study of the extent to which persons engaged in various types of renovation and remodeling activities in target housing, public buildings constructed before 1978, and commercial buildings are exposed to lead in the conduct of such activities or disturb lead and create a lead-based paint hazard on a regular or occasional basis. The Administrator shall complete such study and publish the results thereof within 30 months after October 28, 1992. 
	(3) Certification determination 
      Within 4 years after October 28, 1992, the Administrator shall revise the regulations under subsection (a) of this section to apply the regulations to renovation or remodeling activities in target housing, public buildings constructed before 1978, and commercial buildings that create lead-based paint hazards. In determining which contractors are engaged in such activities, the Administrator shall utilize the results of the study under paragraph (2) and consult with the representatives of labor organizations, lead-based paint activities contractors, persons engaged in remodeling and renovation, experts in lead health effects, and others. If the Administrator determines that any category of contractors engaged in renovation or remodeling does not require certification, the Administrator shall publish an explanation of the basis for that determination. 


                 EPA ICR No. 2502.01; OMB Control No. 2070-NEW
                                       










                                       
                                 ATTACHMENT 2
                                       
Accreditation of training programs:  target housing and child-occupied facilities
                                40 CFR 745.225
                                       
For an electronic copy of 40 CFR 745.225, go to http://www.ecfr.gov/cgi-bin/text-idx?SID=2181334de64d0515a321c606e0ea0b8d&node=40:32.0.1.1.14.6.1.3&rgn=div8. 







                 EPA ICR No. 2502.01; OMB Control No. 2070-NEW











                                 ATTACHMENT 3
                                       
Application and Instructions for Training Providers - Applying for Accreditation of Lead-Based Paint Activity Training Programs - EPA Form 8500-25

An electronic copy of the training provider application form and instructions is available at http://www2.epa.gov/sites/production/files/2013-09/documents/trainapp_9_5_13.pdf
