PART B OF THE SUPPORTING STATEMENT

1. QUESTIONNAIRE OBJECTIVES, KEY VARIABLES, AND OTHER 

PRELIMINARIES

1(a) Questionnaire Objectives 

As part of its investigation into lead exposure resulting from RRP activities in P&CBs, 

EPA seeks to obtain a better understanding of the incidence of different types of RRP activities 

that disturb lead-based paint in P&CBs, the methods that are used to conduct these activities, the 

work practices that are used to contain and clean the resulting dust, and the characteristics of the 

buildings. EPA will use this information to estimate the resulting exposures to lead dust. If EPA 

determines that a regulation is needed, the Agency will use this data to assess the incremental 

benefits and costs of potential options to reduce such exposures. 

EPA’s primary objectives are to use the survey data to: 

1. Gather information on building and activity patterns that may affect exposures to lead 

dust from RRP activities in P&CBs; 

2. Determine the number of firms that perform RRP activities in P&CBs; 

3. Determine the types and numbers of RRP activities that are performed; 

4. Determine the extent to which various work practices that disturb painted surfaces are 

currently being used in RRP jobs in P&CBs; and 

5. Determining the extent to which various work practices that help with the containment 

and cleanup of lead dust are currently being used in RRP jobs performed in P&CBs. 

Secondary objectives of the survey include: 

1. Collecting information on how the proportion of jobs that use particular practices differs 

between different types of firms; and 

2. Collecting information on the percentage of contractors who already have training and 

certification under EPA’s residential RRP Program.

1(b) Key Variables 

The key information to be collected includes the following:

1. Respondent Identification

 These questions will be used to identify the individual at the firm with the knowledge 

required to complete the survey.

2. Screening and Scope

 These questions will be used to determine whether a respondent performs potentially 

regulated RRP activities in P&CBs. Only those who perform RRP activities in 

P&CBs will be asked to complete the full survey. Responses from the screening and 

scope questions will be used to estimate the universe of firms conducting RRP 

activities in P&CBs.
3. Firm Type and Size

 Responses from these questions will be used to assign the appropriate sampling 

weights.

4. Total Number of Activities

 The survey includes 11 categories of RRP activities that disturb painted surfaces. For 

each of these 11 activity categories, the survey asks two questions: (1) the total 

number of jobs and (2) the total number where more than a small areas of paint 

(equivalent to the minor maintenance exception in the RRP rule) is disturbed by the 

respondent firm’s employees. 

 In addition, contractor respondents who report painting activities will be asked about 

the numbers of jobs in the past year where they use one of the following paint 

removal techniques: (1) open flame or torch, (2) high temperature heat gun, (3) 

abrasive blasting (exterior only), and (4) needle gun/scaler. In general, the survey 

only asks detailed questions about activity types (including paint removal techniques) 

and work practices for the most recent job a respondent has completed. Responding 

about the most recent job may be easier and less burdensome for respondents than if 

they were asked about all of the jobs they have conducted in the past year, given the 

difficulty of recalling the details of all of those jobs. And given the variation in jobs 

a firm may conduct (including job type, job size, and building type), it might be 

difficult for a respondent to characterize their “typical” work practices. However, the 

four paint removal techniques described above are the exception to asking about the 

most recent job because these techniques potentially generate high levels of lead dust 

and are believed to be uncommon enough that information about them may not be 

captured if the survey only asks about them in the context of the respondent’s most 

recent job.

5. Recent Job: Job Size, Job Duration, LBP Testing, Access to Work Area

 Each respondent will be randomly selected for a more detailed series of questions 

about a single RRP activity type that they perform (such as removing or replacing 

painted building components, cutting or making holes in painted surfaces, or surface 

preparation for painting). Once the activity type is selected, the respondent will be 

prompted to recall the most recent job of that type performed in a building where a 

test indicated the presence of LBP or surfaces that might contain paint that was 

applied before 1978 were disturbed. If there were no recent jobs meeting these 

criteria they will be asked about the most recent job. 

 Respondents will be asked to characterize the size and type of building the work was 

performed in. This information will allow EPA to estimate how much paint might be 

disturbed and the number of people potentially exposed to lead dust generated by the 

RRP activity.
 For respondents being asked about a recent painting job, they will be asked how long 

the paint preparation took and how many workers were doing this work, the percent 

of the painted surface disturbed, and the average number of layers of paint removed 

during the paint preparation. This information will be used to estimate how much 

paint was removed. 

 For respondents being asked about a recent window or exterior door job, they will be 

asked how many windows or doors were replaced. This will be used to estimate how 

much paint was disturbed. 

 All respondents will be asked about: (1) the total duration of the job, (2) the times of 

day the work was done, and (3) access to the work area by building occupants. 

Responses to these questions will be used in estimating the exposure to lead dust that 

building occupants might experience.

6. Job Combinations

 For the most recent RRP activity a respondent is asked about, he or she will be asked 

to report what other RRP activities were performed at the same time (such as 

replacing windows and performing surface preparation before repainting walls as part 

of the same job). The responses to these questions will be used to ensure that the 

estimates of the number of activities are not based on double counting, and to 

estimate the total lead dust generated from jobs composed of multiple RRP activities.

7. Containment

 There are seven questions related to dust containment practices. Responses to these 

questions will be used to estimate the extent to which firms are already using 

practices to contain dust from RRP activities.

8. Cleanup

 Responses to these questions will be used to estimate the extent to which firms are 

already using practices to clean up dust following RRP activities.

9. Paint Preparation and Removal Techniques

 Respondents being asked about a recent job involving paint preparation or removal 

will be asked about the specific techniques they used.

10. Routine Cleaning

 Respondents will be asked how often most areas of the building receive routine 

janitorial cleaning. This information will be used to estimate changes in exposures to 

lead dust over time following an RRP activity.
11. Motivation for lead-safe work practices

 Respondents will be asked what one or two factors usually influence the level of dust 

containment and cleaning for a given job in P&CBs.

12. Baseline RRP Certification

 Respondents will be asked whether they are already certified under the residential 

RRP rule. This is asked because being certified for residential work may affect 

firms’ baseline work practices in P&CBs, and to estimate the potential costs if 

uncertified firms are required to become certified in order to perform RRP work in 

P&CBs.

13. Open Ended

 Respondents will be given the option to provide additional comments or information. 

1(c) Statistical Approach

This ICR will allow the Agency to produce statistically valid estimates for the population 

of RRP firms and jobs that disturb paint in P&CBs. Without the proposed information collection, 

these estimates will have to be derived from assumptions, anecdotal information, or convenience 

samples rather than parameters estimated from a survey designed to use a probability sample to 

calculate nationally representative parameter estimates. Therefore, the Agency has chosen a 

statistical approach for this ICR. 

The Agency will be assisted in this survey effort by Abt Associates, an independent 

contractor, who will be responsible for developing the survey response database; identifying the 

survey sample; overseeing the conduct of the survey and creating a cleaned survey data file of the 

survey results; weighting, tabulating and analyzing data; and reporting results. Abt Associates

has extensive experience with sample design, survey methods, internet surveys, telephone data 

collection using CATI, data editing and cleaning, and calculation of sampling weights. 

1(d) Feasibility 

A knowledgeable person at the respondent firm should be able to complete the survey. 

To make respondent recall easier the more detailed questions about the use of work practices are 

asked only about a recent job – reviewing or consulting company records is not necessary. EPA 

conducted a pretest of the contractor survey with 6 respondents and has made some revisions to 

the questionnaire based on the insights gained from the pretest. EPA has planned for and 

allocated resources for the efficient and effective management of the information collection. 

2. QUESTIONNAIRE DESIGN FOR THE STATISTICAL APPROACH 

2(a) Target Population and Coverage 
The target population consists of three groups of establishments described in Table 

B2.1.

Table B2.1: Target Population

Group 1 Group 2 Group 3

Substantive 

description Contractors

Nonresidential 

Lessors, Property 

Managers and Facility 

Support Services

Building Occupants

[NAICS codes] [NAICS 2361, 2362, 

2381, 2382, 2383, 

2389]

[NAICS 53112, 53131, 

5612]

[All other NAICS 

codes]

1-4 employees 1,328,230

(83.2%)

150,725

(89.9%)

12,561,214

(75.6%)

5-9 employees 142,486

 (8.9%)

8,969

 (5.4%)

1,577,814

(9.50%)

10-49 employees 106,645

 (6.7%)

5,814

 (3.5%)

1,390,439

 (8.4%)

50+ employees 13,432

 (0.8%)

1,327

 (0.8%)

371,500

 (2.2%)

Unknown size 4,802

 (0.3%)

866

 (0.5%)

711,991

 (4.3%)

Total 1,595,595 

(100%)

167,701 

(100%)

16,612,958 

(100%)

Note: frame counts provided by sample vendor (SSI) using a Dun & Bradstreet database.

The incidence of RRP work disturbing lead-based paint is expected to differ markedly 

between the three groups, hence the rationale for stratification. Also, the larger companies, while 

representing fewer establishment in the universe, take a disproportionately larger share of 

employment, and hence the number of jobs performed and the total amount of lead-based paint 

they are likely to disturb (all other things being equal). Thus, the larger firms need to be 

oversampled relative to mid- and small-size firms. Also, the larger establishments from Group 3 

are more likely to have their own maintenance departments that could be conducting RRP jobs 

disturbing lead-based paint, while the smaller firms may be more likely to subcontract such jobs 

to establishments in Groups 1 and 2. While over 99% of the entities in the U.S. are small, small 

entities are expected to represent roughly 97% of the survey respondents. 

From this population of establishments, EPA will select a representative sample large 

enough to support nationally representative estimates of the number of affected firms, number of 

affected employees, and the number of RRP jobs in which lead-based paint is disturbed.

2(b) Sample Design 

At this stage, little information is available except for the frame counts to guide the 

sample design. The information that EPA needs to continue analyzing RRP activities in P&CBs 

refers to three different populations:

1. The population of establishments, to estimate the total number of affected establishments, 

necessary to estimate the potential certification costs.

2. The population of contractor, property management and building maintenance workers to 
estimate the total number of workers affected, necessary to estimate potential training 

costs.

3. The population of RRP jobs, to estimate the total number of jobs disturbing lead-based 

paint, necessary to estimate potential work practice costs and public exposure to lead dust 

generated by disturbing lead-based paint.

For the first of the above population tasks, a simple random sample (SRS) of 

establishments is the optimal design to estimate the incidence of RRP work. This can be used to 

construct a ratio estimator of the total number of firms across the nation conducting such jobs. 

An SRS solution is conceptually easily to execute and does not require any additional 

information. 

For population task 2 above, the optimal design is a sample proportional to the number of 

workers employed in RRP jobs. However, this particular sample is not feasible to obtain because 

the number of RRP workers cannot be identified on the DMI frame. It can only be assumed that a 

sizeable proportion of the workers in Group 1 establishments (contractors) are likely participants 

in RRP projects. For Group 2 and especially Group 3, maintenance workers will constitute a 

small to zero fraction of the total employment of establishments. 

Finally, for population task 3, the optimal design would be one that is proportional to the 

number of jobs performed by a given establishment. Again, such a sample is not feasible because 

the number of RRP jobs is also not available on the DMI frame. 

In order to proceed with the development of a possible sample design that provides some 

level of utility, assumptions have to be made regarding: 

1. the incidence of RRP jobs in the population or its segments; and

2. the relation between the frame information (number of employees) and the target 

information (number of RRP workers; number of jobs performed by an establishment).

To devise an efficient sampling scheme, it is assumed that the establishment size (number 

of workers) and the number of jobs are jointly distributed. The design assumptions made 

regarding the population parameters are shown in the top half of Table B2.2. The parameters of 

these distributions are obtained from U.S. Census data.

All of these assumptions regarding cooperation and completion will need to be verified in 

the field. After the first 120 cases are completed, the design assumptions parameters will be 

evaluated and adjustments will be made as needed.

The bottom half of Table B2.2 shows the proposed design to generate the estimates for

the three Groups listed above. Given the total sample size, the sample sizes per employee size 

category are driven by attempting to obtain the maximum precision within each size category. 
Table B2.2: Design Assumptions and Proposed Allocations

Group 1

Contractors

Group 2

Lessors and 

Property managers

Group 3

Building 

Occupants

Design assumptions *

Incidence of RRP in P&CBs 20% 10% 5%

Fraction of employees in RRP jobs 90% 40% 5%

Avg. number of jobs/year 100 50 10

Proposed design assumptions and estimates

Allocation proportions for screeners (Total = 

100%) 19.4% 24.0% 56.6%

Total no. of screeners (Total = 8,485) 1,645 2,040 4,800

Screeners in 0-4 employees 745 935 1,513

Screeners in 5-9 employees 369 374 860

Screeners in 10-49 employees 317 565 1,686

Screeners in 50+ employees 214 166 742

Completes (Total = 402) 254 68 80

Margin of error (0.5 base) ± 6.1% ± 11.9% ± 11.0%

*Based on professional judgment

Unlike in many other surveys with eligibility at or close to 100%, most of the firms that 

will be contacted are not expected to be eligible to participate in the survey. Numerous 

contractors only work in residences and do not work in P&CBs. Similarly, many lessors and 

property managers as well as building occupants hire contractors to perform RRP activities, 

instead of using their own staff. However, information on whether an establishment performs 

RRP activities in P&CBs is not available in the Dun & Bradstreet database, or through any other 

readily accessible source. Therefore, it is not feasible to design a random sampling method for 

the survey without contacting a large number of establishments and screening them through the 

questionnaire. However, the questionnaire has been designed to quickly screen out respondents 

who do not perform RRP activities in P&CBs, in order to reduce the burden of locating eligible 

respondents.

Adaptive sample design

It is a realistic possibility that the assumptions that were made to obtain allocations in 

Table B2.2 will be far from the data that could be observed in practice. For these reasons, there 

will be an initial smaller sample for the purpose of providing more informed parameter estimates 

for the rest of the study sample. Once a sample size of 10 full completes is achieved in each of the 

NAICS group by establishment size cell, the assumed parameters in Table B2.2 will be reestimated. Thus, this initial sample size would be a total of 120 establishments (10 completes × 

12 strata = 120) out of the total study sample size of 402 establishments. For Group 1 alone, it 

would be 40 establishments (10 completes x 4 strata = 40). Based on these initial findings, EPA 

can re-design the balance of the sample and adaptively optimize the sample allocations to assure 

the best possible approximation of study estimates. (If deemed necessary, the establishment size 

categories can be redefined if substantial efficiency gains can be expected from a different size 

stratification scheme.) 
Adaptive sample design is and has been a standard practice in many survey organizations 

and federal statistical agencies. Groves and Heeringa (2006) provided a review of the current 

approaches in using process paradata to make interventions into ongoing data collection with the 

aim of improving coverage or response rates in specific subgroups. The idea of “adaptive” or 

“responsive” sample design is actually much older, since using the incoming information on the 

population parameters for which little was known at the design stage has often been a practical, 

corrective necessity in well-managed and monitored data collection operations over past decades.

(i) Sampling Frame 

The Dun & Bradstreet “Dun’s Market Identifiers” DMI file will serve as the sampling 

frame for this establishment survey. The DMI is considered to be the most comprehensive 

commercially available list of U.S. businesses. What is essentially critical is that the DMI 

includes industry and establishment size information necessary for stratifying the sample. 

Additionally, the sample provider, Survey Sampling, Inc. (SSI), can provide additional 

information, such as the name, the email address, and the phone number of a named executive for 

a specified managerial job title. 

An establishment will be defined as the business located at a particular address or 

location. Eligibility for the screener will be determined by verifying that they are still in business. 

Data will be collected with respect to this location, even if the firm has other locations. The unit 

of analysis is the worksite, defined as a “single physical location where business is conducted or 

where services or industrial operations are performed.” The headquarters and other purely 

administrative sites of the larger contractors, nonresidential lessors, property managers and 

facility support services firms will be removed at the sampling stage using SSI corporate linkage 

information.

(ii) Sample Size

It is anticipated that 8,485 establishments will be screened in order to achieve a desired 

total number of 402 full completes. For Group 1, 1,645 establishments would be screened to 

identify and complete 254 interviews. This sample size was selected in order to achieve the 

precision targets shown in the bottom row of Table B2.2 (6.1% for Group 1 and between 11.0% 

and 11.9% for the other two Groups).

(iii) Stratification Variables 

A key requirement of a successful establishment sample is that it produces reliable 

estimates by establishment size and industry grouping. The most efficient way to accomplish this 

goal is to stratify the DMI sampling frame by the cross-classification of establishment size and 

industry. The initial proposed stratification by industry, to the extent the companies in these 

NAICS groups are expected to be involved in RRP jobs disturbing lead-based paint, and to the 

extent that incidence and the number of jobs is expected to vary with sample size, is the one given 

in Table B2.2. 

Establishments will be selected with equal probabilities within each of the 12 strata 

defined by the establishment size and industry classification groups. Larger establishments will 

be sampled at a higher rate to ensure that enough large establishments are available for the 

analysis. It is expected that these larger establishments will account for a disproportionately high 

fraction of the total RRP jobs. The employer survey weight will correct for the oversampling of 

large establishments by weighting by the inverse of the probability of selection. The weights will 

also correct for the expected non-response by using the standard non-response adjustment 

techniques (non-response cell adjustments or propensity score modeling). Finally, the weights 

will be normalized to agree with the distribution of the size of establishments as indicated by the 
Census distribution via the appropriate weight calibration (raking) procedures. This will yield 

approximately unbiased estimates of establishments in the DMI frame and, assuming it provides 

adequate coverage, in the United States. 

(iv) Sampling Method 

Establishments will be selected using the method of stratified random sampling without 

replacement.

2(c) Precision Requirements 

(i) Precision Targets 

EPA’s survey has been designed to obtain estimates that have margins of error of 6.1% 

for Group 1 and between 11.0% and 11.9% for the other two Groups. EPA feels that these 

precision rates will be adequate to characterize the number of regulated activities and the extent 

to which renovators currently use certain containment and cleaning practices.

(ii) Nonsampling Errors 

An expected source of non-sampling error for this study will be non-response bias – i.e., 

that the non-respondents may differ from respondents. Non-response is best handled at the 

design stage of a survey, rather than after the data have been collected. Therefore, the strategy to 

minimize non-response for this survey is to use a survey design that will minimize the incidence 

of non-response. Finally, the data collected in the survey and the follow-up data will be analyzed 

to determine the extent to which non-response may bias the results. This non-response plan 

summarizes the approach to dealing with two forms of non-response: unit non-response (i.e., 

when a survey questionnaire is not completed by a sampled establishment) and item non-response 

(i.e., when a survey questionnaire is finished, but some data elements are missing). 

There are a number of reasons why selected respondents may not respond to the survey. 

The four major reasons for potential non-response are likely to be:

1. Mistrust of regulatory agencies – Some individuals contacted may not have responded 

because they have an inherent mistrust of regulatory agencies and a concern about the 

actions that they think EPA may take based on the data they provide in the survey. 

2. Sensitivity to disclosing technical data – Some individuals contacted may be concerned 

about disclosing their work practices and data, which may result in their failing to 

respond. 

3. Burden – Individuals contacted for the survey have limited time to respond. The 

respondent will need to make time to respond to the survey. Thus, some non-response 

may occur because the contact person does not have the time to respond or will not make

the time to respond. 

4. Questions unclear – If the questions in the survey are unclear, then the individual 

receiving the survey may decline to respond. 

The survey instruments have been designed to reduce the number of non-respondents 

while still gathering the information needed for the Agency’s analysis and decision making. 

Respondents have the option to either complete the survey online or over the phone. The 

requested information should be readily available to a knowledgeable individual at the firm, not 

requiring any additional research on their part. The survey asks detailed technical questions only 

about the respondent’s most recent job to make recall easier. 
A multi-staged respondent contact process will be used to reduce the number of initial 

non-respondents, and to follow up with initial non-respondents in order to convert them to 

respondents.

Stage 1 – Notification Letter. EPA will send a letter on EPA letterhead notifying firms in the 

sample that the survey is taking place and telling them that EPA’s contractor will contact them by 

telephone to conduct the survey. The letter will be short and will describe the type of data that 

EPA is collecting, explain why EPA is collecting the data, note that the identity of the firms will 

be kept anonymous and state EPA’s appreciation for their participation in the survey. The letter 

will also include an address for the optional online survey.

Stage 2 – Technical Contact Identification Call. EPA’s contractor will call all businesses in the 

sample to determine the identity and contact information for a knowledgeable person who can 

complete the survey. During the call, the interviewer will reiterate the purpose of the survey. 

Stage 3 – EPA contractor conducts interview on phone. This can be the same call as in Stage 2 or 

a subsequent appointment time. If the interview cannot be completed by telephone, an email will 

be sent to the key informant of the eligible businesses with a link to the online survey.

Stage 4 – Reminder Notices. EPA’s contractor will send up to two reminder emails (as needed) 

to recipients who have provided an email address but have not completed their online survey after 

the Stage 3 call. If needed, EPA’s contractor will also make a reminder phone call. If the 

reminder call reaches the contact person, an offer to complete the survey with a telephone 

interview will again be made. 

All interviewers will be trained to identify and avert potential refusals and attempt to 

convert non-respondents who refused. Interviewers will record information about refusals, which 

may facilitate subsequent interview attempts if refusal conversion is deemed possible. The 

combination of a well-designed and well-executed survey with a highly capable staff of 

interviewers should minimize the magnitude of non-response and ensure the reliability of the 

survey results.

Despite efforts to design effective survey instruments, however, some level of nonresponse is expected. As a final stage in the non-response plan, the data will be analyzed for 

potential non-response biases. To assess the possibility of non-response bias, the characteristics 

of respondents and non-respondents will be examined in terms of size, geography, type of firm, 

etc., to determine whether there could be any significant differences in responses between the two 

groups. A common procedure in surveys to reduce the bias because of non-response is to adjust 

the sampling weights of respondents to account for non-respondents after forming weighting 

classes. The assumption is that respondents and non-respondents within a weighting class are 

similar. This is a more reasonable assumption than assuming that the total sample of respondents 

is similar to non-respondents.

For example, if the response rates differ by size of firm and the percentages of interest 

(i.e., how they answered a question) also differs by size of firm, then size groups can be formed 

as weighting classes. Within each size group, the weights of respondents can be adjusted to 

account for non-respondents. There will be a reduction in the bias in the estimate if there is 

reason to believe that the respondents and non-respondents are similar within a size group. It is 

worth noting however, that the weighting approach may be only partially successful, since some 

of the responses may not be closely correlated with firm size or other available characteristics. 

A second potential source of non-sampling error is measurement error. If respondents 

have difficulty interpreting a question, they may provide inconsistent answers, leading to 
inaccurate responses. Information provided from memory may also be inaccurate. The survey 

includes instructions for phone interviewers to help them clarify any concepts that are challenging 

and the online version of the survey instrument will include text boxes that include these 

clarifications. In addition, the more technical survey questions are focused only on the 

respondents’ most recent job to aid in recall.

2(d) Questionnaire Design 

Respondents will receive an initial notification letter encouraging them to follow the 

instructions provided for completing the survey using the online instrument. Those respondents 

who do not complete the survey online will be contacted by telephone using trained interviewers 

calling from a survey telephone center. 

The telephone survey instrument will use a CATI screener questionnaire and detailed 

interview questionnaire. Respondents will also have the option to complete the survey online. 

Skip and branching logic will be programmed into the CATI system and the online survey 

instrument. This allows irrelevant questions to be skipped automatically (e.g., if a respondent 

reports that she only does exterior painting, she will not be asked about interior painting) and also 

allows questions asked later in the survey to be based on earlier questions (e.g., if a respondent 

indicates that 40 percent of his jobs are interior painting and 60 percent are exterior painting, the 

survey instrument will be programmed so that there is a 40 percent chance that the most recent 

job he will be asked about is an interior painting job, and a 60 percent chance that he will be 

asked about an exterior painting job). While this type of questionnaire design is well suited to a 

telephone or online survey, it is not feasible for a mail survey.

The survey instrument includes questions that are multiple choice, numeric (generally 

asking for counts), and text (open-ended). The open-ended question simply provides respondents 

with the option to provide any additional information to EPA that they think might be useful.

3. PRETESTS AND PILOT TESTS

3(a) Pretest

The Agency conducted a pretest of the contractor survey instrument with 6 respondents. 

The respondents were asked to comment on the ease of answering the questions and about how 

they interpreted the questions. Several changes to the survey were made based on insights gained 

by conducting the pretest, including the following:

• Respondents reported that EPA is likely to have a difficult time convincing respondents 

to participate in the study. In response to this feedback EPA has added an incentive of 

$50 for eligible contractor respondents that complete the entire survey.

• Some respondents had difficulty recalling the numbers of projects where specific work 

practices were used (e.g., projects that involved paint preparation for interior painting). 

Pretest respondents told the interviewers that it would be easier to respond to these 

questions by reporting the number of jobs as a percentage of the total jobs that they 

performed. The questionnaire was revised so that respondents have the option to report 

the number of jobs as a count or as a percentage. 

• The questionnaire was initially worded so that respondents would be asked about a recent 

job in a pre-1978 building. The objective of limiting response to pre-1978 buildings was 

to limit responses to instances where LBP might have been disturbed. However, more 

than one case arose where the respondents knew that LBP was not present in the painted 
surfaces they disturbed even though it was an older building. The questionnaire has been 

revised to ask about recent jobs where LBP might have been disturbed either because the 

paint was tested for LBP or the respondent reported that the surfaces they disturbed might 

contain paint that was applied before 1978. Two pretest respondents completed the 

revised version of these questions and did not have any difficulty with them.

• Respondents were asked whether they would be able to report the average number of 

layers of paint that were removed during paint preparation. They said that they could 

provide an estimate of this, so the question was added to the survey.

3(b) Pilot Survey

Given time and budget constraints, EPA does not plan to conduct a pilot test.

4. COLLECTION METHODS

EPA has chosen to conduct its survey by telephone and online interview for three 

reasons:

 Skip and branching logic will be programmed into the online instrument and the CATI 

system. This interactive survey format is not feasible for a mail survey.

 Having both an online and telephone option should maximize cooperation. Some 

respondents may prefer to respond via an online survey, which will allow them to 

respond to the survey whenever it is most convenient for them. Also, telephone surveys 

can maximize cooperation through direct contact with the respondents and provide an 

opportunity to clarify terms and aid recollection through probes. 

 Telephone surveys provide a rapid turnaround time.

For those respondents that decide not to complete the survey online, initial contacts and 

follow-ups will be made using the CATI system. Interviewers will receive training on the intent 

of the survey, the range of potential responses, and definitions of key terms used or addressed by 

the survey.

4(a) Collection Methods

The process to conduct this information collection is illustrated in Exhibit B4.1.

Exhibit B4.1: Survey process flow chart.

Purchase sample of contractors, 

manager/lessors and building occupants

Send notification letters
Non-response bias analysis

EPA will send a notification letter to all sampled addresses to inform them about their 

selection in the sample. The objective of this letter will be to inform them about the study and 

invite their participation. A link to the online address where the surveys can be completed will be 

included with this letter. The online survey will allow respondents to complete the screening as 

well as the main questionnaire. One week after the mailing of this letter, the first phase of 

telephone interviews will begin. Businesses in the sample will be called to screen for eligibility 

and to identify the key informant. Once contacted, interviewers will attempt to complete the 

screening as well as the main interview. EPA’s contractor will attempt to initially complete 120 

interviews across the three study groups and analyze the data collection process to determine if 

sample allocation needs to be modified for the rest of the study. 

Telephone data collection will be conducted by interviewers employed by EPA’s 

contractor who are experienced in conducting large-scale national surveys of business 

populations. Prior to telephone data collection, interviewers will receive training about the study. 

Program and test CATI instrument
The objective of the training will be to cover background information about the study, discuss any 

special characteristics or interviewing protocols, and thoroughly discuss the instrument. Given 

this is an establishment survey of firms of varying sizes and structures, EPA’s contractor will 

need to develop special calling protocols to increase cooperation and ensure quality. Telephone 

calls will be conducted on a schedule designed to facilitate successful contact with targeted 

businesses, which may require making calls during morning and evening hours when respondents 

are more likely to be available to participate in a phone interview. 

When calling each establishment, the interviewer will use a systematic procedure to 

determine if the intended business has been reached, and whether the business is eligible for the 

study. The interviewer will also attempt to identify an appropriate key informant for the study and 

will then ask to speak to that person. If the contact person is not available to talk, the interviewer 

will probe for an appropriate callback time or set up an appointment to talk. The interviewer will 

also ask for the email address of the contact person so that they can email them a link to the 

online version of the survey. If the contact person still refuses to participate, the interviewer will 

record that information and the reasons given. When the contact person agrees to participate, the 

interviewer will conduct the interview over the phone. 

4(b) Survey Response and Follow-up

Identifying and classifying non-responders

To gain some insight into non-responding sample units, the first step is to screen the 

sample being fielded. Non-responders will fall into two segments, those that were successfully 

screened and found eligible but chose either not to participate or for some reason an interview 

could never be conducted. This group is referred to as Screened Eligible Non-Responders. The 

other category consists of sample units that could not be successfully screened and thus their 

eligibility status is unknown. These are Unscreened Unknown Eligibility Non-Responders. 

In the Exhibit B4.2 schematic, the Screened Eligible non-responders are in segment A 

and the Unscreened Unknown Eligibility non-responders are in segment B, which is likely to be 

this study’s largest segment due primarily to non-cooperation and inability to make contact. 

Regarding segment B, some frame information on these cases will be known, but because of the 

unknown eligibility status, it is impossible to determine which cases may be eligible. Thus, it is 

not possible to asses if their exclusion contributes to any bias in the study findings. The nonresponse bias analysis will report, using frame information, any differences that may exist 

between the screened vs. unscreened entities. However, it would be unknown if any differences 

are a contributor of bias in the study estimates. Segment A offers some opportunity to examine 

non-response based entirely on information provided in the frame. If it is assumed that nonparticipation is uncorrelated with work practices, then the nonresponse analysis could consider 

whether these non-responders are different from or similar to cooperative responders based 

exclusively on the frame information. 

Response Propensity Models

Analytically, propensity models can be developed to examine whether there are statistical 

differences between the screened eligible responders and screened eligible non-responders on 

their likelihood to complete the survey. Likewise, the analysis can examine the propensity to 

cooperate between all those who were screened (regardless of eligibility status) and those 

establishments who were not screened. The models would be developed for each of the three 

study groups for a total of six propensity models.
The Dun and Bradstreet frame offers a few variables that can be used in these analyses. 

These establishments, within study groups, can be defined by their location (four Census regions), 

the size based on number of employees (e.g., categorized: 0-4, 5-9, 10-19 .... 100+) and the 

possibility of NAICS subgroups within study groups, although these NAICS subgroups will have 

to be evaluated for feasibility and practicality.

Exhibit B4.2. Responder, Non-responder schematic

Screened 

Eligible

NonResponders

Unscreened 

Unknown 

Eligibility

Non-responders

Screened 

Eligible

Responders

Screened 

as 

Ineligible A

B
5. ANALYSIS AND REPORTING QUESTIONNAIRE RESULTS

5(a) Data Preparation 

The interview data will be extracted into a database with all identifying respondent 

information removed. 

A weight will be computed for each completed screener and long survey that adjusts for 

the differential probabilities of selection as well as nonresponse. Specifically, the weight will be 

computed with the following adjustments:

a) a base weight reflecting the probability of selection of the establishment; 

b) an adjustment for nonresponse to the screener and extended interview; and 

c) a post-stratification adjustment to Census population controls for the number of 

establishment in each of the twelve strata defined by size and industry.

The sample design of the employer survey necessitates that appropriate statistical 

software be used to estimate the precision of the survey estimates. Abt SRBI (the contractor 

conducting the survey for EPA) shall compute the main weight, as well as the replicate weights 

for variance estimation that will ensure that the standard errors based on the RRP survey correctly 

reflect the sample design. 

5(b) Analysis 

The data will be analyzed using a statistical software package. Data analysis will include 

both descriptive statistics (e.g., frequencies of survey variables) and relationship analyses (e.g., 

regression analysis).

5(c) Reporting Results 

EPA will use the survey data in preparing exposure and economic analyses. Results of 

EPA’s analyses are usually reported publicly in three ways: (1) within Federal Register notices; 

(2) within development and supporting documents; and (2) within materials placed in the 

rulemaking record. All of these classes of documents would be made available by EPA on the 

Internet.

Note that neither EPA nor any other person or entity other than the contractor hired to 

perform the survey will have access to personal identifiers in the raw survey data. (These 

personal identifiers include the respondent’s name, the respondent’s phone number, and the name 

of the organization the respondent works for.) All personal identifiers will be stripped from the 

database before it is conveyed to EPA. The original survey database will remain under the 

control of the contractor hired to perform the survey. 
References

Groves, R.M. and Heeringa, S.G. (2006). Responsive Design for Household Surveys: Tools for 

Actively Controlling Survey Errors and Costs, Journal of the Royal Statistical Society, 

Series A, 169, 3, 439-459.
ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachment 1 - Toxic Substances Control Act Section 402; 15 U.S.C. 2681 et. seq.

Attachment 2 - Public Consultations

Attachment 3 - Public Comments on Proposed ICR and EPA Responses to Public Comments

Attachment 4 - EPA Public and Commercial Building Contractor Survey Questionnaire

Attachment 5 - EPA Public and Commercial Building Manager/Lessor Survey Questionnaire

Attachment 6 - EPA Public and Commercial Building Occupant Survey