       Supporting Statement for an Information Collection Request (ICR)
                    Under the Paperwork Reduction Act (PRA)
                                       

1. EXECUTIVE SUMMARY

      1(a). Identification of the Information Collection  -  Title and Numbers
      Title: Lead Training, Certification, Accreditation and Authorization Activities	
      ICR Numbers: EPA ICR No.: 2507.01; OMB Control No.: 2070-New.
	EPA Form Numbers:  EPA Form 8500-25: Application and Instructions for Training Providers Applying for Accreditation of Lead-Based Paint Activity and Renovation Training Programs; EPA Form 8500-27: Application for Firms to Conduct Lead-based Paint Activities or Renovations; EPA Form 747-B-99-002: Application and Instructions for Individuals Applying for Certification to Conduct Lead-Based Paint Activities.
	Docket ID Number: EPA-HQ-OPPT-2014-0486.

      1(b). Docket Information
The information collection request (ICR) that explains the information collection activities and related burden and cost estimates, as well as other supporting documents related to the ICR, are available in the docket established for this ICR. The docket, designated as ID No. EPA-HQ-OPPT-2014-0486, can be viewed online at http://www.regulations.gov or in person at the EPA Docket Center, William Jefferson Clinton West Bldg., Rm. 3334, 1301 Constitution Ave., NW., Washington, DC. The telephone number for the Docket Center is (202) 566-1744. For additional information about EPA's public docket, visit http://www.epa.gov/dockets.

      1(c). ICR Status
Under the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., 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 control number issued by the Office of Management and Budget (OMB). The OMB control numbers are displayed either by publication in the Federal Register or by other appropriate means, such as on the related collection instrument or form, if applicable. The display of OMB control numbers for certain EPA regulations is consolidated in 40 CFR part 9.

Before submitting an ICR to OMB for review and approval under the PRA, an agency must solicit comments pursuant to PRA §3506(c)(2)(A) and 5 CFR 1320.8(d)(1). After considering comments received on the draft ICR, the agency must submit the ICR to OMB for review and approval according to the procedures prescribed in 5 CFR 1320.12. In announcing the submission of the final ICR to OMB for review and approval, the agency must provide another opportunity for public review and comments on the revised ICR pursuant to 5 CFR 1320.12(c).

This is a new ICR that seeks to consolidate the information collection activities that are currently covered by the following three ICRs that are currently approved by OMB under the separate OMB control numbers identified:
   1) OMB Control No. 2070-0155; EPA ICR No. 1715.13; entitled "TSCA Sections 402 and Section 404 Training, Certification, Accreditation and Standards for Lead-Based Paint Activities and Renovation, Repair, and Painting"; approved through December 31, 2015.
   2) OMB Control No. 2070-0158; EPA ICR No. 1669.06; entitled "Lead-Based Paint Pre-Renovation Information Dissemination  -  TSCA Sec. 406(b)"; approved through April 30, 2015.
   3) OMB Control No. 2070-0181; EPA ICR No.2381.02; entitled "ICR for the Final Rule entitled "Lead; Clearance and Clearance Testing Requirements for the Renovation, Repair, and Painting Program; Final Rule" (RIN 2070 - AJ57); approved through April 30, 2015.

Please note that EPA is currently seeking to renew the three ICRs above, unchanged from what is currently approved, in order to ensure that the consolidated ICR can complete the required PRA process.

      3(a). Abstract
      This consolidated ICR will cover the information collection activities associated with the reporting and recordkeeping requirements for individuals, firms and state and local government entities conducting lead-based paint activities or renovations of target housing and child-occupied facilities; training providers; and states/territories/tribes/Alaskan native villages.

	Legal authority: The Toxic Substances Control Act (TSCA), 15 U. S. C. 2601 et seq. In particular, sections 401, 402, 404, and 406; and related implementing regulations in 40 CFR part 745. More details are provided in Unit 2(a) of this Supporting Statement.

	Respondents/affected entities: Entities potentially affected by this ICR are include persons who are engaged in lead-based paint activities and/or perform renovations of target housing or child-occupied facilities for compensation, dust sampling, or dust testing; or who perform lead-based paint inspections, lead hazard screens, risk assessments or abatements in target housing or child-occupied facilities; or who provide training or operate a training program for individuals who perform any of these activities; or state, territorial or Native American agencies that administer lead-based paint activities and/or renovation programs.

	Respondent's obligation to respond: Responses are mandatory under TSCA (see 40 CFR part 745).

      Confidentiality of responses: Respondents may claim all or part of a document submitted to be as confidential. EPA will disclose information that is covered by a claim of confidentiality only to the extent permitted by, and in accordance with, the procedures in TSCA section 14 and 40 CFR part 2.

	Estimated total number of potential respondents: 588,357.

	Frequency of response: On occasion.

	Estimated total annual burden: 5,585,214 hours. Burden is defined at 5 CFR 1320.3(b).

	Estimated total annual costs: $273,556,653, which includes no annualized capital investment or maintenance and operational costs.

      Changes in the estimates: The consolidation of the currently approved ICRs is expected to result in an overall decrease of 444,088 hours in the total estimated combined respondent burden that is currently approved by OMB. This decrease reflects changes in EPA's estimates of the burden including: revisions to the estimated number of respondents based on the number of respondents reporting to EPA for the prior information collection; the fact the housing market and related industries including housing rentals, property management and building renovation have yet to recover from the drop in the housing market; and the 2008 Renovation, Repair and Painting (RRP) rule and the 2010 Opt-Out rule have been in place for several years and the ICR estimates can use actual certification data instead of making broader assumptions about industry behavior. Further details about these changes are included in this ICR supporting statement. This change is an adjustment.


2. NECESSITY OF THE INFORMATION COLLECTION
      2(a). Related Legal and/or Administrative Requirements
The related legal authority is the Toxic Substances Control Act (TSCA), 15 U. S. C. 2601 et seq., with related requirements provided in 40 CFR part 745. The various applicable sections are provided in Attachment 1 and are briefly summarized here along with their implementing regulations, which are provided in Attachment 2.

TSCA section 401 defines target housing as any housing constructed before 1978 except housing for the elderly or disabled or 0-bedroom dwellings.

TSCA section 402(a) and 402(c)(3) 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. (See Attachment 2 for 40 CFR 745, Subparts E, L and Q.) Section 401 of TSCA defines target housing as any housing constructed before 1978 except housing for the elderly or disabled or 0-bedroom dwellings.

TSCA section 406(b) requires EPA to promulgate regulations applicable to all renovations of target housing or child-occupied facilities (COFs) performed for compensation, except as otherwise specified, at 40 CFR part 745, subpart E to provide a lead hazard information pamphlet (attachment 10) to the owner and occupant of such housing no more than 60 days prior to commencing the renovation.
In addition, EPA has developed extensive guidance and other materials that are available at http://www.ep.gov/lead.
The following provides a general overview for requirements covered in this ICR for each entity:

Firms: Firms that wish to engage in renovations 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 renovators and conduct renovations in target housing in accordance with the work practice standards. Firms must re-certify every five years.

The rule also requires firms to develop and retain records of the renovation activities they undertake to demonstrate compliance with standards and provide a written record for future reference.

In addition, for renovations in child-occupied facilities, the rule requires firms to provide the building owner and adult representative of the child-occupied facility with a lead hazard information pamphlet. After providing the pamphlet to the owner and occupant and obtaining written acknowledgment, the firm must keep acknowledgment records on file for three years after completion of work. Renovation firms must also either (i) provide the lead hazard information pamphlet and general information on the renovation to parents or guardians of children under age 6 using the facility, or (ii) erect signs that provide general information on the renovation accompanied by the pamphlet or information on how to obtain a copy of it. The final Clearance rule modified some of the mandatory work practices for firms, but did not impose any additional reporting or recordkeeping requirements on firms.

In addition, under TSCA section 406(b), firms that perform renovations of target housing or child-occupied facilities (COFs) for compensation, except as otherwise specified, at 40 CFR part 745, subpart E, must provide a lead hazard information pamphlet (developed under section 406(a) of TSCA) to the owner and occupant of such housing no more than 60-days prior to commencing the renovation. The firm performing renovations also must prepare, sign, and date a statement describing the steps performed to notify all occupants of the intended renovation activities and to provide the pamphlet (section 745.84(b)(3)). If the scope, locations, or expected starting and ending dates of the planned renovation activities change after the initial notification, the firm performing the renovation must provide further written notification to the owners and occupants providing revised information on the ongoing or planned activities. This subsequent notification must be provided before the firm performing the renovation initiates work beyond that which was described in the original notice (section 745.84(b)(4)). Firm must retain and, if requested, make available to EPA all records necessary to demonstrate compliance with the requirements of 40 CFR part 745, subpart E, for a period of three years following completion of the renovation activities in target housing or COFs.

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) (see Attachment 5). 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 (see Attachment 3). Once accredited, if there are any changes in the information submitted on the application, the training provider must submit an amendment to the EPA or the State, as applicable. Training programs also must maintain certain records related to their students and the qualifications of their training personnel. Training programs also must maintain certain records related to their students and training personnel qualifications. Training programs are required to notify the Agency (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. The final Clearance rule made several minor modifications to the accreditation application package requirements and the notification requirements.

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. The final Clearance rule modified the minimum elements required for State programs in order to demonstrate that they are at least as protective as the Federal program. The final Clearance rule did not impose additional reporting or recordkeeping requirements on States.
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).

      2(b). Necessity of the Information Collection
The information collection activities covered by this ICR are necessary components of the Lead Program established under the TSCA mandates.

Under TSCA section 402(a)(1), 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."

TSCA 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.

TSCA 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.

TSCA section 407 states that regulations shall include such recordkeeping and reporting requirements as may be necessary to ensure effective implementation.
 
 TSCA section 406(b) requires EPA to promulgate regulations requiring certain persons who perform renovations of target housing for compensation to provide a lead hazard information pamphlet to the owner and occupant of such housing prior to commencing the renovation. Regulations promulgated under the authority of section 406(b) of TSCA ensure that owners and occupants of target housing are provided information concerning potential hazards of lead-based paint exposure before certain renovations are begun on that housing. The Agency believes that the distribution of the pamphlet will help to reduce the exposures that cause serious lead poisonings, especially in children under age six, who are particularly susceptible to the hazards of lead.

      1(a). Uses, Users, and Purpose of the Information Collection
Owners/Occupants of target housing and child-occupied facilities, child-occupied facility operators, and parents/guardians. The owner/occupant of target housing or a child-occupied facility must be provided with a lead hazard information pamphlet before any renovation commences. 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/occupants, 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.

The record of compliance could also serve as a crucial piece of information in civil actions to establish liability.
   
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 final Clearance rule made several minor modifications to the training provider accreditation application package requirements and the training provider notification requirements. These modifications were designed to improve the ability of EPA and the States to administer training accreditation programs.
   
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 have to compile and retain are necessary as a reference for building owners/occupants, EPA or authorized entities. These records 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.


1. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
      1(a). Non-Duplication
 The Agency's collection pursuant to the TSCA 402/404/406/407 regulations do not duplicate any other collection. There is no other Federal program for lead-based paint activities and renovations, or associated State program approval process, and there are currently no other Federal requirements for the training and certification of individuals engaged in these activities, for the accreditation of training programs, required standards for the conduct of these activities, or lead hazard information distribution requirements for renovations in target housing or child-occupied facilities.

      2(a). Public Comments and Consultations
 EPA solicited comments on this new ICR pursuant to PRA §3506(c)(2)(A) and 5 CFR 1320.8(d)(1), providing a 60-day public notice and comment period that ended on February 27, 2015 (79 FR 78084, December 29, 2014). EPA received no comments during the comment period.
 
 Additionally, 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 ICR to OMB for review and approval. In accordance with this regulation, EPA submitted questions to nine parties via e-mail. The individuals contacted were:

Kary S. Amin
NOVA Environmental, Inc.
734-930-0995  
kamin@nova-env.com 

Thomas Nunziata
Laborers' International Union of North America
860-974-0800
TNunziata@laborers-AGC.org
Mike Nagel
Men at Work Chicago
312-751-1500
mike@mawchicago.com

Steve Heiteen 
Portland Remodel
503-244-3525 
steve@portlandremodel.com

Kevin Gaul
Pella Corporation
641-621-6615
gaulkj@pella.com

Vince Butler
BBC Builders
703-878-3300
vbutler@bbcbuilders.com

Bob Hanbury
House of Hanbury Builders, Inc.
860-666-1537
bobh@houseofhanbury.com



Andrew J. McLellan 
Environmental Education Associated
888-436-8338
ajm@environmentaleducation.com 

Mark Mikkelson
Andersen Windows
651-264-5150
Mark.Mikkelson@AndersenCorp.com

EPA received no responses to its solicitation for consultations. A copy of EPA's consultation e-mail to the above potential respondents is included in Attachment 11.

      5(a). Effects of Less Frequent Collection
 Due to the nature of the renovation and lead-based paint activities regulations and their related information collection activities, 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.
 
 The 406(b) information distribution requirements at 40 CFR part 745, subpart E, do not include any reporting requirements, only recordkeeping requirements. Therefore, a collection schedule is not applicable.

      8(a). Small Entity Flexibility
 EPA believes that the 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. In addition, as part of the development process for the 2008 RRP rule, the Agency convened a Small Business Advocacy Review Panel under the Regulatory Flexibility Act. More information on the Panel, and the Agency's assessment of the impacts on small businesses, can be found in the preamble to the 2008 RRP rule. The Clearance final rule imposed minimal additional burden on the estimated 159 small business training providers affected.
 
 In promulgating the regulations at 40 CFR part 745, subpart E, EPA attempted to minimize the 406b reporting and recordkeeping burden for both large and small regulated entities. While small businesses constitute the majority of affected entities, hour and cost burden imposed by the regulations is not considered to be of sufficient magnitude to have significant economic impacts on such establishments.

      11(a). General PRA Related Guidelines
 This ICR is consistent with OMB's general guidelines. Firms are required to maintain records for three years and training providers to maintain records for three and one-half years. Authorized States must report once a year for the first three years, and biannually thereafter. The final Clearance rule requires training providers to maintain records of renovation and dust sampling technician training courses for five years, because five years is the length of the refresher training cycle for certified renovators and dust sampling technicians.
 
 The 406(b) information distribution requirements at 40 CFR part 745, subpart E do not exceed any of the Paperwork Reduction Act guidelines at 5 CFR 1320.5.

      14(a). Confidentiality
 The regulations for the TSCA Section 402 and Section 404 Training, Certification, Accreditation and Standards for Lead-Based Paint Activities and Renovation, Repair, and Painting do not address questions of a confidential nature.
 
 Since the 406(b) information distribution requirements at 40 CFR part 745, subpart E involve only recordkeeping and 3rd-party notifications, EPA does not believe that respondents submit any information to the Agency or that, in doing so, would assert a confidentiality claim for information collected under this ICR. However, to the extent information submitted by respondents is business confidential, procedures are in place to protect the information from improper disclosure consistent with section 14 of TSCA; 40 CFR part 2, subpart B; and 40 CFR 745.84.

      17(a). Sensitive Questions
 This information collection does not include questions of a sensitive nature.


1. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
      1(a). Agency Activities
EPA will perform the following activities in response to the submittals related to renovation and lead-based paint activity submissions:

   ::	Receive, review, and act on applications from states
   ::	Receive, review, and file reports from authorized states
   ::	Receive, review, and act on applications and amended 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.

There are no Agency activities associated with the distribution of the 406(b) lead hazard information pamphlets to owners and occupants of target housing and COFs prior to commencing renovations for compensation.

      1(b). Estimated Agency Costs
EPA estimates that it costs the agency approximately $3,590,392 to carry out the activities associated with the information collection activities covered by this ICR. This ICR renewal includes a cost estimate for the administration of the LBP and RRP programs by the Agency. 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 numbers of events are estimated for each respondent type, and following the previously approved ICR (EPA ICR No. 1715.10).
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 EPA's Central Data Exchange (CDX). E-mail notification must be followed by a written notification for the record, but the original e-mail notice would satisfy the applicable notification time requirements. 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.

There are no Agency activities associated with the distribution of the 406b lead hazard information pamphlet to owners and occupants of target housing and COFs prior to commencing renovations for compensation. However, under the provisions of 40 CFR 745.87, EPA may conduct inspections and issue subpoenas pursuant to the provisions of TSCA section 11 (15 U.S.C. 2610) to ensure compliance with 40 CFR part 745, subpart E.

 Collection Schedule
For certification, accreditation, and authorization, collection activities will occur according to the following schedule:
   -	Training programs may apply for accreditation at any time;
   -	Training programs must amend their applications when information changes, and the Clearance final rule establishes requirements for amending applications;
   -	Training programs must seek re-accreditation at four-year intervals following initial accreditation;
   -	Training programs submit notification of training to EPA before each course;
   -	Training programs submit post-training notification to EPA after each course;
   -	Firms may apply for certification at any time;
   -	Firms must amend their applications when information changes;
   -	Firms must seek re-certification at five-year intervals following initial certification;
   -	Renovators and dust sampling technicians may take training at any time;
   -	Renovators and dust sampling technicians must take refresher training at five-year intervals following initial training;
   -	States may apply for authorization at any time;
   -	Authorized States must report once a year for the first three years, and biannually thereafter;
   -	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.

The 406(b) information distribution requirements at 40 CFR part 745, subpart E, do not include any reporting requirements, only recordkeeping requirements. Therefore, a collection schedule is not applicable.

 Use of Technology to Facilitate Collection Activities
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 EPA's Central Data Exchange (CDX). E-mail notification must be followed by a written notification for the record, but the original e-mail notice would satisfy the applicable notification time requirements. 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. EPA is currently modifying CDX to allow individuals and RRP firms to apply through CDX further simplifying these application processes.


1. The RESPONDENTS AND INFORMATION COLLECTION (IC) ACTIVITIES
For each respondent category, this section of the ICR describes the respondents, the information collection activities and related estimates for burden and costs associated with those activities.

      1(a). Methodology for Estimating Respondent Burden and Costs
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. 

The North American Industrial Classification System (NAICS) codes associated with industries most likely affected by the paperwork requirements are described below:
236115	Single Family Housing Construction
236116	Multifamily Housing Construction
236210	Manufacturing and Industrial Building Construction
236220	Commercial and Institutional Building Construction
238220	Plumbing, Heating, and Air-Conditioning Contractors
238320	Painting and Wallpapering
238210	Electrical Contractors
238140	Masonry and Stone Contractors
238310	Drywall, Plastering, Acoustical, and Insulation Contractors
238340	Tile (except resilient) Contractors
238350	Carpentry Contractors
238330	Floor Laying and Other Floor Contractors
238160	Roofing, Siding, and Sheet Metal Contractors
238110	Concrete Contractors
213111	Water Well Drilling Contractors
238120	Structural Steel Erection Contractors
238210	Electrical Contractors and Other Wiring Installation Contractors
238910	Excavation Contractors
238910	Wrecking and Demolition Contractors
238290	Other Building Equipment Contractors
238390	Building fixture and fitting (except mechanical equipment) installation
236118	Residential Remodelers
238150	Glass and Glazing Contractors
238170	Siding Contractors
238210	Electrical Contractors
238220	Plumbing, Heating, and Air-Conditioning Contractors
238290	Other Building Equipment Contractors
238310	Drywall and Insulation Contractors
238340	Tile and Terrazzo Contractors
238350	Finish Carpentry Contractors
238390	Other Building Finishing Contractors
531110	Lessors of Residential Buildings and Dwellings
531190	Lessors of Other Real Estate Property
531210	Offices of Real Estate Agents and Brokers
531311	Residential Property Managers
531320	Offices of Real Estate Appraisers
531390	Other Activities Related to Real Estate
541330	Engineering Services
541350	Building Inspection Services
562910	Remediation 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
923120	Administration of Public Health Programs
924110	Administration of Air and Water Resource and Solid Waste Management Programs
925110	Administration of Housing Programs

      1(b). Information Collections
   IC #1: LBP training provider accreditation applications, training notifications, and recordkeeping
Respondent NAICS Codes

611513	Apprenticeship Training
611519	Other Technical and Trade Schools
611699	All Other Miscellaneous Schools and Instruction

Information Collection Activities
      
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 either the sample EPA Form 8500-25, entitled "Accreditation Application for Training Programs" or a similar form.

Training providers are required to include documentation of training manager and principal instructor qualifications with their accreditation applications. In addition, if training providers wish to use course materials approved by authorized State programs, the providers must submit copies of the course materials along with their applications.

On occasion, training providers may later amend their accreditation application to add or modify information. Accredited training providers must apply for re-accreditation every four years.

Before giving a lead-based paint activity training, training providers must provide notification to the Agency, using either the sample form entitled "Lead-Based Paint Activities and Renovation Training Notification" (see Attachment 6) 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.)

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 training providers must provide notice using either the sample form entitled "Lead-Based Paint Activities and Renovation Post-Training Notification" (see Attachment 7) or a similar form containing the required information. Training providers may submit electronic submissions using the Agency's CDX.
   
Training course providers must maintain records of the qualifications of key staff, current course materials, a quality control plan, results of hands-on assessments and course tests and a record of each student's course completion certificate.

Providers of e-learning courses are required to maintain records on each student's course log-ins, launches, progress, and completion.

IC# 1. LBP training provider accreditation applications, training notifications, and recordkeeping
                        Citation: 40 CFR 745, subpart L

                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
LBP activity training providers / initial accreditation / reporting
8500-25
                                                                            347
                                                                          9,529
                                                                        472,053
LBP activity training providers / renewal accreditation / reporting
N/A
                                                                          1,235
                                                                          6,626
                                                                        314,962
LBP activity training providers / pre-training notification / reporting
Training Notification
                                                                         13,132
                                                                          2,626
                                                                         71,955
LBP activity training providers / pre-training re-notification / reporting
N/A
                                                                          5,628
                                                                          1,126
                                                                         30,838
LBP activity training providers / post-training notification / reporting
Post-Training Notification
                                                                          7,504
                                                                         11,744
                                                                        300,772
LBP training providers / recordkeeping
8500-25
                                                                          1,876
                                                                          1,623
                                                                         41,154
                                                                         Total 
                                                                        29,722 
                                                                               
                                                                        33,274 
                                                                               
                                                                   $ 1,231,734 
            
   IC #2: LBP activity firm certification activities
Respondent NAICS Codes
            
562910	Remediation Services
            
Information Collection Activities

To obtain firm 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 Agency's CDX, the EPA form "Application for Firms to Conduct Lead-based Paint Activities or Renovations" (EPA Form 8500-27; see Attachment 4) or a similar form requiring the same information.

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

Firms seeking certification for lead-based paint activities must perform the following activities:
         *          Read the regulation.
         *          Sign a statement certifying that the firm will only employ appropriately qualified individuals to conduct lead-based paint activities, and that the firm and its employees shall follow the work practice standards in 40 CFR 745.227.
         *          Retain Records of individuals that conduct lead-based paint activities, and that the firm and its employees shall follow the work practice standards in 40 CFR 745.227.

               IC# 2. LBP activity firm certification activities

                        Citation: 40 CFR 745, subpart L
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
LBP activity firms / initial certification / reporting
EPA Form 8500-27
                                                                          4,235
                                                                         31,614
                                                                      1,694,741
LBP activity firms / renewal certification / reporting
EPA Form 8500-27
                                                                          4,882
                                                                          7,152
                                                                        384,186
LBP firms / certification / recordkeeping
EPA Form 8500-27
                                                                          9,117
                                                                             91
                                                                          2,402
                                                                         Total 
                                                                        18,234 
                                                                        38,857 
                                                                               
                                                                   $ 2,081,329 

   IC #3: Individuals performing LBP abatement activities; certification and accreditation / reporting and recordkeeping Respondents
Respondent NAICS Codes
            
562910	Remediation Services
            
Information Collection Activities

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.


  IC# 3. Individuals performing LBP abatement activities; certification and 
                   accreditation/reporting and recordkeeping

                        Citation: 40 CFR 745, subpart L
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
Individuals performing LBP abatement activities; certification and accreditation / reporting and recordkeeping
EPA 747-B-99-002
                                                                         31,168
                                                                        24,906 
                                                                     $ 920,078 

   IC# 4: LBP activity firm pre-abatement reports and occupant protection plans, abatement activity notifications, post-abatement reports and recordkeeping
Respondent NAICS Codes
            
562910	Remediation Services
            
Information Collection Activities

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, a lead hazard screen report, a risk assessment report, an occupant protection plan, and an abatement report.

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" (see Attachment 8) or a similar form containing the required information. Certified firms may also provide electronic submissions using the Agency's CDX. 

IC# 4. LBP activity firm pre-abatement reports and occupant protection plans, abatement activity notifications, post-abatement reports and recordkeeping 

                        Citation: 40 CFR 745, subpart L
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
LBP activity firms / evaluation reports / reporting
EPA Form 8500-27
                                                                        218,816
                                                                        402,402
                                                                     21,626,357
LBP activity firms / post-abatement report / reporting
Sample Renovation Recordkeeping Checklist
                                                                         13,676
                                                                         26,873
                                                                      1,443,974
LBP activity firms / occupant protection plan / reporting
None
                                                                         13,676
                                                                         13,197
                                                                        711,214
LBP activity firms / pre-abatement notifications / reporting
Notification of Lead-Based Paint Abatement Activities
                                                                         13,676
                                                                          6,359
                                                                        347,699
LBP firms / reports / recordkeeping
Notification of Lead-Based Paint Abatement Activities, Sample Renovation Recordkeeping Checklist
                                                                        259,844
                                                                          2,598
                                                                          2,598
LBP activity firms / pre-abatement re-notifications / reporting
Notification of Lead-Based Paint Abatement Activities
                                                                            524
                                                                            112
                                                                          6,248
LBP Firms / re-notifications / recordkeeping
Notification of Lead-Based Paint Abatement Activities
                                                                            524
                                                                              5
                                                                              5
                                     Total
                                    520,736
                                    451,546
                                 $ 24,138,095
     IC# 5: RRP training provider accreditation applications, training notifications, and               recordkeeping
Respondent NAICS Codes
            
611513	Apprenticeship Training
611519	Other Technical and Trade Schools
611699	All Other Miscellaneous Schools and Instruction
            
Information Collection Activities

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 (see Attachment 3). Once accredited, if there are any changes in the information submitted on the application, the training provider must submit an amendment to the EPA or the State, as applicable. Training programs also must maintain certain records related to their students and the qualifications of their training personnel. Training programs also must maintain certain records related to their students and training personnel qualifications. Training programs are required to notify the Agency (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. The final Clearance rule made several minor modifications to the accreditation application package requirements and the notification requirements.



The final Clearance rule made several minor modifications to the training provider accreditation application package requirements and the training provider notification requirements. These modifications were designed to improve the ability of EPA and the States to administer training accreditation programs.

It is the nature of accreditation that an entity seeking such must provide materials to the 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 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.

C# 5. RRP training provider accreditation applications, training notifications, and recordkeeping

                        Citation: 40 CFR 745, subpart E
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
RRP training providers / initial accreditation / reporting
EPA Form 8500-25
                                                                            265
                                                                          7,314
                                                                        361,960
RRP training providers / reaccreditation / reporting
None
                                                                             67
                                                                            630
                                                                         31,097
Accredited Cohort Rule Familiarization Maintenance
None
                                                                            329
                                                                            658
                                                                         35,256
RRP training providers / pre-training notification / reporting
Training Notification
                                                                          9,254
                                                                          1,851
                                                                         50,358
RRP training providers / pre-training re-notification / reporting
Training Notification
                                                                          1,322
                                                                            264
                                                                          7,194
RRP training providers / post-training notification / reporting
Post-Training Notification
                                                                          9,254
                                                                         14,427
                                                                        369,164
RRP training providers / digital photographs / reporting
None
                                                                          9,254
                                                                         11,651
                                                                        298,788
RRP training providers / recordkeeping
EPA Form 8500-25
                                                                            661
                                                                            634
                                                                         15,087
                                                                          Total
                                                                        30,406 
                                                                        37,429 
                                                                               
                                                                   $ 1,168,904 
   IC# 6: Private RRP firm certification activities
Respondent NAICS Codes

236115	Single Family Housing Construction
236116	Multifamily Housing Construction
236210	Manufacturing and Industrial Building Construction
236220	Commercial and Institutional Building Construction
238220	Plumbing, Heating, and Air-Conditioning Contractors
238320	Painting and Wallpapering
238210	Electrical Contractors
238140	Masonry and Stone Contractors
238310	Drywall, Plastering, Acoustical, and Insulation Contractors
238340	Tile (except resilient) Contractors
238350	Carpentry Contractors
238330	Floor Laying and Other Floor Contractors
238160	Roofing, Siding, and Sheet Metal Contractors
238110	Concrete Contractors
213111	Water Well Drilling Contractors
238120	Structural Steel Erection Contractors
238210	Electrical Contractors and Other Wiring Installation Contractors
238910	Excavation Contractors
238910	Wrecking and Demolition Contractors
238290	Other Building Equipment Contractors
238390	Building Fixture and Fitting (except mechanical equipment) Installation
236118	Residential Remodelers
238150	Glass and Glazing Contractors
238170	Siding Contractors
238210	Electrical Contractors
238220	Plumbing, Heating, and Air-Conditioning Contractors
238290	Other Building Equipment Contractors
238310	Drywall and Insulation Contractors
238340	Tile and Terrazzo Contractors
238350	Finish Carpentry Contractors
238390	Other Building Finishing Contractors
531110	Lessors of Residential Buildings and Dwellings
531190	Lessors of Other Real Estate Property
531311	Residential Property Managers
531390	Other Activities Related to Real Estate
541330	Engineering Services
541350	Building Inspection Services
562910	Remediation Services
611110	Elementary and Secondary Schools
611699	All Other Miscellaneous Schools and Instruction
624410	Child Day Care Services

Information Collection Activities

Firms that wish to engage in renovations in target housing or child-occupied facilities must obtain certification from EPA/States. This includes firms consisting only of one self-employed individual, and property management companies, building owners, private schools and daycare centers performing work with their own employees. To receive certification, a firm must submit a letter to EPA/States certifying that it will employ certified renovators and conduct renovations in target housing in accordance with the work practice standards. Firms must re-certify every five years and maintain a record of their certification.

To obtain firm 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 Agency's CDX, the EPA form "Application for Firms to Conduct Lead-based Paint Activities or Renovations" (EPA Form 8500-27; see Attachment 4) or a similar form requiring the same information.

               IC# 6. Private RRP firm certification activities

                        Citation: 40 CFR 745, subpart E
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
Private RRP firms / initial certification / reporting
None
                                                                         27,916
                                                                         97,706
                                                                      4,429,013
Private RRP firms / recertification / reporting
None
                                                                         32,627
                                                                         65,254
                                                                      2,966,773
Certified Cohort Rule Familiarization Maintenance
None
                                                                        184,800
                                                                        184,800
                                                                      8,343,720
Private RRP firms / certification / recordkeeping
None
                                                                         60,543
                                                                            605
                                                                         15,953
                                                                          Total
                                                                       305,886 
                                                                       348,365 
                                                                               
                                                                  $ 15,755,459 

   IC# 7: Distribution of pre-renovation lead hazard information pamphlet and post-renovation and post-renovation checklists documenting lead-safe work practices
Respondents NAICS Codes
      
236115	Single Family Housing Construction
236116	Multifamily Housing Construction
236210	Manufacturing and Industrial Building Construction
236220	Commercial and Institutional Building Construction
238220	Plumbing, Heating, and Air-Conditioning Contractors
238320	Painting and Wallpapering
238210	Electrical Contractors
238140	Masonry and Stone Contractors
238310	Drywall, Plastering, Acoustical, and Insulation Contractors
238340	Tile (except resilient) Contractors
238350	Carpentry Contractors
238330	Floor Laying and Other Floor Contractors
238160	Roofing, Siding, and Sheet Metal Contractors
238110	Concrete Contractors
213111	Water Well Drilling Contractors
238120	Structural Steel Erection Contractors
238210	Electrical Contractors and Other Wiring Installation Contractors
238910	Excavation Contractors
238910	Wrecking and Demolition Contractors
238290	Other Building Equipment Contractors
238390	Building Fixture and Fitting (except mechanical equipment) Installation
236118	Residential Remodelers
238150	Glass and Glazing Contractors
238170	Siding Contractors
238210	Electrical Contractors
238220	Plumbing, Heating, and Air-Conditioning Contractors
238290	Other Building Equipment Contractors
238310	Drywall and Insulation Contractors
238340	Tile and Terrazzo Contractors
238350	Finish Carpentry Contractors
238390	Other Building Finishing Contractors
531110	Lessors of Residential Buildings and Dwellings
531190	Lessors of Other Real Estate Property
531311	Residential Property Managers
531390	Other Activities Related to Real Estate
541330	Engineering Services
541350	Building Inspection Services
562910	Remediation Services
611110	Elementary and Secondary Schools
611699	All Other Miscellaneous Schools and Instruction
624410	Child Day Care Services

Information Collection Activities

 No more than 60 days before beginning renovation activities in any residential dwelling unit of target housing or COF, the firm performing renovations must provide the owner and or occupant(s) of the building with the pre-renovation lead hazard information pamphlet and comply with recordkeeping procedures. If the owner does not occupy the dwelling unit, the firm performing renovations must provide an adult occupant of the unit with the pamphlet. The firm must keep documentation providing proof that the pamphlet was provided to the owner and occupant or that an attempt was made to provide the pamphlet to the owner and occupant of the target housing (e.g., collect signed acknowledgment form, provide self-certification for failed deliveries, and document mailing the information). No more than 60 days before beginning renovation activities in common areas, the firm must provide the owner of the multi-unit housing or COF with a lead hazard information pamphlet, and comply with recordkeeping procedures. In addition, the firm performing renovations must notify in writing, or ensure written notification of, occupant of each affected unit and make the pamphlet available upon request prior to the start of the renovation. Finally, the firm performing renovations must prepare, sign, and date a statement describing the steps performed to notify all occupants of the intended renovation activities and to provide the pamphlet.
 	
 Firms performing renovations must retain and, if requested, make available to EPA all records necessary to demonstrate compliance with the requirements of 40 CFR part 745, subpart E, for a period of three years following completion of the renovation activities in target housing. These requirements include the retention of the acknowledgement of receipt of the lead hazard information pamphlet, certifications of attempted delivery, and certifications of mailing.

In the performance of renovation activities, firms 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.


IC# 7. Distribution of pre-renovation lead hazard information pamphlet and post-renovation and post-renovation checklists documenting lead-safe work practices

                        Citation: 40 CFR 745 Subpart E
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
Pre-Renovation Information Dissemination by Contractors Working in Occupied Target Housing Rental Units
None
                                                                      1,621,277
                                                                        455,579
                                                                     22,677,042
Pre-Renovation Information Dissemination by Contractors Working in Owner-Occupied Target Housing
None
                                                                      4,937,525
                                                                        898,630
                                                                     46,991,905
Pre-Renovation Information Dissemination by Contractors Working in Vacant Target Housing Rental Units and Common Areas
None
                                                                      4,912,960
                                                                      1,301,934
                                                                     65,169,186
Pre-Renovation Information Dissemination by Contractors Working in Owner-Occupied Child-Occupied Facilities and by Landlords Working in Rental Child-Occupied Facilities
None 
                                                                        114,569
                                                                         30,361
                                                                      1,519,729
Pre-Renovation Information Dissemination by Contractors Working in Rental Child-Occupied Facilities
None
                                                                          6,138
                                                                          2,271
                                                                        118,497
Pre-Renovation Information Dissemination by Private Schools and Daycare Centers for In-House Renovation Activities
None
                                                                         25,530
                                                                          5,106
                                                                        263,729
RRP firm checklist / owner-occupied target housing / third party disclosure
Sample Renovation Recordkeeping Checklist
                                                                      6,869,604
                                                                        343,480
                                                                     16,195,091
RRP firm checklist / renter-occupied target housing / third party disclosure
Sample Renovation Recordkeeping Checklist
                                                                      7,360,290
                                                                        368,015
                                                                     18,087,913
RRP firm checklist / in-house or landlord / third party disclosure
Sample Renovation Recordkeeping Checklist
                                                                         29,441
                                                                          1,472
                                                                         69,407
RRP firm checklist / owner-occupied child-occupied facility (COF), contractor / third party disclosure
Sample Renovation Recordkeeping Checklist
                                                                        208,542
                                                                         10,427
                                                                        491,638
RRP firm checklist / renter-occupied child-occupied facility (COF), contractor / third party disclosure
None
                                                                          9,814
                                                                            491
                                                                         25,099
RRP Firms / recordkeeping / recordkeeping
Sample Renovation Recordkeeping Checklist
                                                                        245,343
                                                                      1,177,646
                                                                     53,173,188
                                                                          Total
                                                                    26,341,033 
                                                                     4,595,412 
                                                                               
                                                                 $ 224,782,424 


   IC# 8: Government-employed RRP professional certification activities, distribution of lead hazard information pamphlet prior to renovation activities, post-renovation checklists documenting lead-safe work practices, and recordkeeping
Respondents NAICS Codes

611110	Elementary and Secondary Schools
611699	All Other Miscellaneous Schools and Instruction
923120	Administration of Public Health Programs
924110	Administration of Air and Water Resource and Solid Waste Management Programs
925110	Administration of Housing Programs
   
Information Collection Activities
 
 No more than 60 days before beginning renovation activities in any residential dwelling unit of target housing or COF, the government entity performing renovations must provide the owner and or occupant(s) of the building with the pre-renovation lead hazard information pamphlet and comply with recordkeeping procedures. If the owner does not occupy the dwelling unit, the government entity performing renovations must provide an adult occupant of the unit with the pamphlet. The government entity must keep documentation providing proof that the pamphlet was provided to the owner and occupant or that an attempt was made to provide the pamphlet to the owner and occupant of the target housing (e.g., collect signed acknowledgment form, provide self-certification for failed deliveries, and document mailing the information). No more than 60 days before beginning renovation activities in common areas, the government entity must provide the owner of the multi-unit housing or COF with a lead hazard information pamphlet, and comply with recordkeeping procedures. In addition, the government entity performing renovations must notify in writing, or ensure written notification of, each affected unit and make the pamphlet available upon request prior to the start of the renovation. Finally, the government entity performing renovations must prepare, sign, and date a statement describing the steps performed to notify all occupants of the intended renovation activities and to provide the pamphlet.

 Government entities performing renovations must retain and, if requested, make available to EPA all records necessary to demonstrate compliance with the requirements of 40 CFR part 745, subpart E, for a period of three years following completion of the renovation activities in target housing. These requirements include the retention of the acknowledgement of receipt of the lead hazard information pamphlet, certifications of attempted delivery, and certifications of mailing.

Government entities that wish to engage in renovations in target housing or child-occupied facilities must obtain certification from EPA/States. This includes government entities consisting only of one self-employed individual. To receive certification, a government entity must submit a letter to EPA/States certifying that it will employ certified renovators and conduct renovations in target housing in accordance with the work practice standards. Government entities must re-certify every five years. The rule also requires government entities to develop and retain records of the renovation activities they undertake to demonstrate compliance with standards and provide a written record for future reference.
IC# 8. Government-employed RRP professional certification activities, distribution of lead hazard information pamphlet prior to renovation activities, post-renovation checklists documenting lead-safe work practices, and recordkeeping

                        Citation: 40 CFR 745 subpart E
                         Data Element (w/ hyperlinks)
                                     Form
                                   Responses
                                    Burden
                                     Cost
Government entities / initial certification / reporting
 
                                                                          1,389
                                                                          4,862
                                                                        261,354
Government entities / renewal certification / reporting
 
                                                                          1,597
                                                                          8,624
                                                                        463,069
Government entities / recordkeeping
None
                                                                          6,670
                                                                         32,016
                                                                      2,106,012
Government entities / in-house or landlord / third party disclosure
None
                                                                         53,360
                                                                          2,668
                                                                        212,319
Pre-renovation information dissemination by schools for in-house renovation activities
None
                                                                         36,275
                                                                          7,255
                                                                        435,876
                                                                          Total
                                                                        99,291 
                                                                        55,425 
                                                                    $3,478,630 


   5(c).	Total Estimated Respondent Burden and Costs
                               IC Summary Table
                                  IC Category
                                   Responses
                                    Burden
                                     Cost
IC 1: LBP Training Providers
                                                                         29,722
                                                                         33,274
                                                                      1,231,734
IC 2: LBP firm activities
                                                                         18,234
                                                                         38,857
                                                                      2,081,329
IC 3: LBP individual activities
                                                                         31,168
                                                                         24,906
                                                                        920,078
IC 4: LBP Reports, Plans, Notifications and Recordkeeping
                                                                        520,736
                                                                        451,546
                                                                     24,138,095
IC 5: RRP Training Providers
                                                                         30,406
                                                                         37,429
                                                                      1,168,904
IC 6: RRP Firm Activities
                                                                        305,886
                                                                        348,365
                                                                     15,755,459
IC 7: RRP Pamphlet and Checklists
                                                                     26,341,033
                                                                      4,595,412
                                                                    224,782,424
IC 8: RRP Government Entities
                                                                         99,291
                                                                         55,425
                                                                      3,478,630
Total
                                                                    27,376,476 
                                                                     5,585,214 
                                                                   273,556,653 


1. Changes in Burden and Cost Estimates
This information collection combines the burden from three previously approved ICRs, EPA ICR No. 2381.02, EPA ICR No. 1669.06, and EPA ICR No. 1715.13. The total combined burden from these three previously approved ICRs was 6,029,302 hours. The total burden requested for this ICR is 5,585,214 hours, or a decrease of 444,088 hours from the previous total burden. 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;
   * The housing market and related industries including housing rentals, property managers and the building renovation industry have yet to recover from the drop in the housing market; and
   * The 2008 RRP Rule and the 2010 Opt-Rule have been in place for a few years and the ICR estimates can use actual certification data instead of having to make broader assumptions about industry behavior and compliance rates.
      
The total combined cost from these three previously approved ICRs was $291,575,709. The total cost requested for this ICR is $273,556,653. The difference between the current cost 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 2013 dollars for this information collection request. In certain disciplines, wage rates have actually decreased, likely due to the depressed housing market and overall economy. This combined with reduced burden caused the lower cost of this combined ICR.


2. PRA BURDEN STATEMENT
Under the PRA, burden is defined at 5 CFR 1320.3(b).

The response burden for this ICR is estimated to range between 1.2 and 10.2 hours per response, depending on the particulars associated with the individual DCI. The total annualized burden for this ICR is estimated to be 5,585,214 hours per year. The response cost is estimated to range between $14 and $657 per response, depending on the particulars associated with the individual DCI. The total annualized cost for this ICR is estimated to be $273,556,653 per year. This estimated total annualized cost includes $55,616,019 for non-burden costs related to mailing and special deliveries for the submissions. Delivery of paper submissions will be eliminated with the full implementation of the electronic system that is under development.


3. 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-2014-0486. These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in the following listing.

Attachment 1:	Toxic Substances Control Act (TSCA), 15 U.S.C. 2601 et seq.

Attachment 2:	40 CFR 745, Subparts E, L and Q

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

Attachment 4:	EPA Form 8500-27: Application and Instructions for Firms Applying for 
			Certification to Conduct Lead-Based Paint Activities and/or Renovations

Attachment 5:	EPA Form 747-B-99-002: Application and Instructions for Individuals 
			Applying for Certification to Conduct Lead-Based Paint Activities

Attachment 6:	Lead-Based Paint Activities and Renovation Pre-Training Notification

Attachment 7:	Lead-Based Paint Activities and Renovation Post-Training Notification

Attachment 8:	Notification of Lead-Based Paint Abatement Activities

Attachment 9:	Sample Renovation Recordkeeping Checklist

Attachment 10:	The Lead-Safe Certified Guide to Renovate Right

Attachment 11:	Copy of Consultations Message Sent by EPA to Potential Respondents

