Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: TSCA Sections 402 and Section 404 Training, Certification, Accreditation and 

Standards for Lead-Based Paint Activities and Renovation, Repair, and Painting

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

1(b) Short Characterization

This information collection request (ICR) combines existing ICRs 1715.09 (ICR for leadbased paint activities), 1715.10 (ICR addendum for the 2008 RRP final rule), and 1715.12 (ICR 

for the 2010 RRP opt-out and recordkeeping final rule)1covering the reporting and 

recordkeeping requirements for individuals or firms conducting lead-based paint activities or 

renovation in or on houses, apartments, or child-occupied facilities built before 1978, under the 

authority of sections 402 and 404 of the Toxic Substances Control Act (TSCA) (15 U. S. C. 

2682, 2684; see Attachment 1). 

Sections 402(a) and 402(c)(3) of TSCA require EPA to develop and administer a training 

and certification program as well as work practice standards for persons who perform lead-based 

paint activities and/or renovations. The current regulations in 40 CFR part 745, subpart E, cover 

work practice standards, recordkeeping and reporting requirements, individual and firm 

certification, and enforcement for renovations done in target housing or child-occupied 

facilities. The current regulations in 40 CFR part 745, subpart L, cover inspections, lead hazard 

screens, risk assessments, and abatement activities (referred to as “lead-based paint activities”) 

done in target housing and child-occupied facilities. Section 401 of TSCA defines target housing 

as any housing constructed before 1978 except housing for the elderly or disabled or 0-bedroom 

dwellings. 

Sections 402(a) and 402(c)(3) of TSCA require reporting and/or recordkeeping from four 

entities: firms engaged in lead-based paint activities or renovations in target housing and childoccupied facilities; individuals who perform lead-based paint activities in target housing and 

child-occupied facilities; training providers; and states/territories/tribes/Alaskan native villages 

(hereafter, the term “states” includes territories/tribes/villages). The following sections provide a 

general overview for each entity:

Firms: Firms that wish to engage in renovations or lead-based paint activities in target 

housing or child-occupied facilities must obtain certification from EPA/states. This includes 

firms consisting only of one self-employed individual. To receive certification, a firm must 

 

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

superseded by the ICR addendum for the final rule.
submit a letter to EPA/states certifying that it will employ certified individuals and conduct work 

in target housing and child-occupied facilities in accordance with the applicable work practice 

standards. Renovation, repair, and painting firms must apply for re-certification every five years, 

while firms performing lead-based paint activities must apply for re-certification every three 

years. The rule also requires firms to develop and retain records of the lead-based paint activities 

and renovations they undertake to demonstrate compliance with standards and provide a written 

record for future reference. Firms must notify the Agency prior to commencement of lead-based 

paint abatement activities. In addition, for work in child-occupied facilities located in public or 

commercial buildings, the rule requires firms to provide the building owner and adult 

representative of the child-occupied facility with a lead hazard information pamphlet. (Existing 

regulations require the distribution of a lead hazard pamphlet, and the associated recordkeeping, 

before renovations in all target housing. This burden is reflected in EPA ICR No. 1669.05 LeadBased Paint Pre-Renovation Information Dissemination- TSCA Sec. 406(b), and is approved 

under OMB Control No. 2070-0158.) These notification, reporting, and recordkeeping 

requirements are necessary to provide EPA compliance monitoring and enforcement personnel 

with information necessary to track compliance activity and to prioritize inspections.

Individuals: Individuals who wish to perform lead-based paint activities in target 

housing or child-occupied facilities must also receive certification from EPA/states. To obtain 

certification, an individual must complete an accredited training course and receive a course 

completion certificate, pass a third-party certification exam, meet specific education/experience 

requirements, and demonstrate this to EPA/states.

Individuals certified to perform lead-based paint activities must take a refresher course 

and apply for re-certification every three years (five for individuals who have passed a 

proficiency test as part of their training). The rule also requires individuals to develop records of 

the lead-based paint activities and renovations they undertake to demonstrate compliance with 

standards and provide a written record for future reference. These notification and 

recordkeeping requirements are necessary to provide EPA compliance monitoring and 

enforcement personnel with information necessary to track compliance activity and to prioritize 

inspections. 

Training providers: Training programs seeking to offer training for inspectors, risk 

assessors, project designers, abatement supervisors, abatement workers, renovators or dust 

sampling technicians must obtain EPA/state accreditation. In order for EPA/states to have the 

information necessary to evaluate and accredit the training programs, training providers must 

prepare and submit application packages. Training programs also must certain records related to 

their students and training personnel qualifications. Training programs are required to notify the 

Agency prior to (i) prior to providing training courses, and (ii) following completion of training 

courses. Training programs must apply for re-accreditation every four years. These notification 

requirements are necessary to provide EPA compliance monitoring and enforcement personnel 

with information necessary to track compliance activity and to prioritize inspections.

States: Under TSCA section 404, EPA must review and assess state submissions to 

determine whether to grant authorization to administer a program addressing training, 

certification, accreditation and standards for lead-based paint activities or renovation, repair, and 
painting. A state seeking authorization will need to provide information to EPA so the Agency

may determine whether its program is at least as protective of human health and the environment 

as the federal program and whether it provides adequate enforcement. Authorized states need to 

provide a report to EPA on their activities.

2. NEED FOR AND USE OF THE COLLECTION

 2(a) Need/Authority for the Collection

Under section 402(a)(1) of TSCA, the Agency must “...promulgate final regulations 

governing lead-based paint activities to ensure that individuals engaged in such activities are 

properly trained; that training programs are accredited; and that contractors engaged in such 

activities are certified. Such regulations shall contain standards for performing lead-based paint 

activities, taking into account reliability, effectiveness and safety.” 

Section 402(a)(2) states that “Final regulations promulgated under [section 402(a)] 

paragraph (1) shall contain specific requirements for the accreditation of ... training programs ... 

including, but not limited to:

- Minimum requirements for the accreditation of training providers;

- Minimum training curricula requirements;

- Minimum training hour requirements;

- Minimum hands-on training requirements;

- Minimum training competency and proficiency requirements;

- Minimum requirements for training program quality.

Section 402(c)(3) directs EPA to revise its regulations under TSCA section 402(a) to 

apply to renovation and remodeling activities that create lead-based paint hazards. 

Section 404(a) of TSCA states that “[a]ny State which seeks to administer and enforce 

the standards, regulations, or other requirements established under Section 402 may...develop 

and submit to the Administrator an application, in such form as the Administrator shall require, 

for authorization of such a State program.” The Agency shall approve such an application, if it 

finds that “...the State program is at least as protective of human health and the environment as 

the Federal program under section 402...and such State program provides adequate 

enforcement.” The statute also requires the Agency to implement the program in states that do 

not receive authorization.

Section 407 of TSCA states that regulations shall include such recordkeeping and 

reporting requirements as may be necessary to ensure effective implementation.

2(b) Practical Utility/Users of the Data

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

parents/guardians
The owner of a public or commercial building containing a child-occupied facility must 

be provided with a lead hazard information pamphlet before any renovation in the child-occupied 

facility commences. In addition, if the child-occupied facility is not operated by the owner of the 

building, an adult representative of the child-occupied facility must also be provided with a lead 

hazard information pamphlet. Parents and guardians of children using child-occupied facilities 

must be provided with general information on the renovation as well as the pamphlet, or 

information on how to obtain a copy of the pamphlet. Information contained in this pamphlet 

may be used by homeowners, public or commercial building owners, child-occupied facility

operators, and parents or guardians to take appropriate precautions to minimize the exposure of 

children to lead-based paint hazards created by renovations. Parents and guardians may also use

general information about the renovation for the purpose of minimizing the exposure of their 

children to lead-based paint hazards created by renovations.

EPA

This information collection will provide EPA with materials necessary to authorize state 

renovation and training rule programs and to serve as the accrediting and certifying body in 

states without authorized programs (discussed further below).

EPA/States

This collection will enable EPA/states to determine compliance with and enforce the 

requirements for training, certification, accreditation, and work practice standards for 

renovations and lead-based paint activities. Without this collection, there would be no 

meaningful way of ensuring the implementation of the statutory objective: to ensure that trained 

individuals conduct renovations and lead-based paint activities in such a way as to minimize 

potential harm to occupants. The rule provides flexibility for individuals conducting renovations 

and lead-based paint activities, by relying on guidance and training to help individuals determine 

the best approaches for renovations and lead-based paint activities. The Agency believes this is 

the best method for accommodating a variety of projects and site-specific conditions. 

It is the nature of certification and accreditation that an entity seeking such must provide 

materials to the certifying or accrediting body. The materials the Agency/state requires for these 

activities are central to the activity. In addition, EPA will be relying on training provider 

notifications to keep track of which individuals have received accredited renovator training. This 

information will be a critical part of EPA’s compliance monitoring and enforcement activities. 

The re-certification and re-accreditation requirements for individuals and training 

programs are meant to ensure that training programs incorporate new developments and 

technologies in their courses and provide training to individuals. The Agency believes this will 

ensure that individuals and firms conduct renovations and lead-based paint activities in the safest 

and most effective manner possible. 

The records individuals and firms would have to compile and retain are necessary as a 

reference for building owners/occupants, EPA or authorized entities. The records would 

demonstrate that the activities are done in a safe and effective manner, according to the minimum 
work practice standards established by the rules. These recordkeeping requirements are also 

necessary to permit the Agency to target its enforcement activities and to ensure compliance 

within the contracting and training community.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

The Agency’s collection pursuant to the TSCA 402/404 regulations does not duplicate 

any other collection. There is no other model program for lead-based paint activities or 

renovations and there are currently no other federal requirements for the training and 

certification of individuals engaged in these activities, or lead hazard information distribution 

requirements for renovations in child-occupied facilities. 

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

Prior to submission to OMB, this ICR will be made available to the public for comment 

through a Federal Register notice. The public will have 60 days to provide comments. Any

comments received will be given consideration when completing the supporting statement that is 

submitted to OMB.

3(c) Consultations and Public Comments

Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original or 

renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will 

pursue additional consultations with interested parties during the development of the renewal of 

this collection.

3(d) Effects of Less Frequent Collection

Due to the nature of this regulation and its collection, less frequent collection is not 

feasible. In particular, each individual and firm must obtain certification and re-certification, 

each training program must obtain accreditation and re-accreditation as well as specific 

notification and documentation prior to commencement and upon completion of each lead-based 

paint activity and renovation course, and each lead-based paint activity is a separate and unique 

event requiring specific notification and documentation. Program approval for states is a onetime activity, although there is ongoing reporting.
3(e) General Guidelines

This ICR is consistent with OMB’s general guidelines. The Agency requires that 

individuals and firms maintain records for three years. Authorized states report once a year for 

the first three years and biannually thereafter.

The training providers should maintain student records as long as the individual is 

certified following training for a period of three and a half years. This is due to the interim 

certification period of six months following an individual completing lead-based paint activities 

training, which allows the individual time to apply to EPA/states to receive official certification. 

At such time, the individual remains certified for three years before he or she must obtain 

refresher training and re-certification. EPA wishes training providers to maintain records on a 

particular lead-based paint activities trainee for as long as the individual is certified following 

training, so three and one-half years is an appropriate period for the retention of such records. It 

is likely that most training providers that seek accreditation to offer renovator or dust sampling 

technician courses will already be accredited to offer lead-based paint activities courses. The 

Agency believes that a single recordkeeping period for these providers is simpler and easier to 

administer. 

3(f) Confidentiality

This information collection does not include questions of a confidential nature. 

3(g) Sensitive Questions

This information collection does not include questions of a sensitive nature.

4. THE RESPONDENTS AND INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

Respondents to the lead-based paint activities rule include:

1) firms and individuals engaged in lead-based paint activities 

2) training programs providing training services in lead-based paint activities 

3) state programs

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

1) firms and individuals engaged in residential renovations or renovations in childoccupied facilities

2) training programs providing training services in renovations

3) state programs

The North American Industrial Classification System (NAICS) codes associated with 

industries most likely affected by the paperwork requirements are described below: 
23321 Single Family Housing Construction

23331 Manufacturing and Industrial Building Construction

23332 Commercial and Institutional Building Construction

23521 Painting and Wall Covering Contractors

23542 Drywall, Plastering, Acoustical, and Insulation Contractors

23551 Carpentry Contractors

23561 Roofing, Siding, and Sheet Metal Contractors

23594 Wrecking and Demolition Contractors

23599 All Other Special Trade Contractors

236118 Residential Remodelers

238210 Electrical Contractors

238220 Plumbing, Heating, and Air-Conditioning Contractors

238320 Painting and Wall Covering Contractors

238350 Finish Carpentry Contractors

238310 Drywall and Insulation Contractors

238170 Siding Contractors

238340 Tile and Terrazzo Contractors

238150 Glass and Glazing Contractors

238390 Other Building Finishing Contractors

238290 Other Building Equipment Contractors

531110 Lessors of Residential Buildings and Dwellings

531311 Residential Property Managers

541330 Engineering Services

541350 Building Inspection Services

611110 Elementary and Secondary Schools

611513 Apprenticeship Training

611519 Other Technical and Trade Schools

611699 All Other Miscellaneous Schools and Instruction

624410 Child Day Care Services

92312 Administration of Public Health Programs

92411 Administration of Air and Water Resource and Solid Waste Management 

Programs

92511 Administration of Housing Programs

4(b) Information Requested

The lead-based paint activities and renovation, repair, and painting regulations specify

reporting and recordkeeping for training providers and individuals/firms undertaking lead-based 

paint activities and/or renovations in target housing and child-occupied facilities. 
(i) Data Items

States

In order to obtain authorization from EPA to administer and enforce a program under 

section 404, states must prepare:

 A notice of intent to seek authorization

 An application for authorization identifying the agencies responsible for 

implementation, administration, and enforcement of the program, and a 

description of the authority and responsibilities vested in such agencies. 

States that receive authorization for lead-based paint activities and/or renovation 

programs must submit to EPA a report summarizing implementation and enforcement activities, 

including a list of enforcement actions taken and any changes in content, administration, or 

enforcement of the state program.

Training Providers

To receive accreditation to provide lead-based paint activities or renovation training, 

training providers must submit the following documents to EPA/state, using the form entitled 

“Application and Instructions for Training Providers” or a similar form containing the required 

information:

 An accreditation statement that clearly indicates how the training program meets 

the minimum requirements for accreditation

 A quality control plan which outlines procedures for periodic revision of training 

material and exams, annual review of instructors, and adequacy of the training 

facilities

 A copy of the course agenda

 A copy of the student and instructor manuals if the training provider does not use 

the EPA model training materials

 A copy of the course test blueprint

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

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

training

Before giving a lead-based paint activity or renovation/dust sampling technician course, 

training providers must provide notification to the Agency, using either the sample form entitled 

“Lead-Based Paint Activities and Renovation Training Notification” or a similar form containing 

the required information. Training providers may provide electronic submissions using the 

Agency’s secure, Internet-based Central Data Exchange (CDX). (The paperwork activities, 

related burden and costs with CDX user registration are described in an ICR approved under

OMB Control No. 2025-0003.) The initial notice must include the following: 

 Notification type (original, updated, cancellation)
 Training program name, EPA accreditation number, address, and phone number 

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

 Date(s) and time(s) of training 

 Training location’s phone number and street address

 Principal instructor’s name

 Training manager’s name and signature

Training providers must update the Agency regarding any changes to training dates, 

course locations, course cancellations, or other changes to the original notice.

Following completion of lead-based paint activities, renovator, or dust-sampling 

technician courses, training providers must provide notice using either the sample form entitled 

“Lead-Based Paint Activities and Renovation Post-Training Notification” or a similar form 

containing the required information. Training providers may submit electronic submissions 

using the Agency’s CDX. The notice must include the following information:

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

 Course discipline and type (initial, refresher)

 Date(s) of training

 The following information for each student who took the course:

 Name

 Address

 Date of birth

 Course completion certificate number

 Student test score

 Training manager’s name and signature

In addition, for renovator and dust-sampling technician courses, the training provider 

must take a digital photograph of each student and submit it to the EPA along with the training 

course follow-up material.

Training course providers must maintain the following records:

 Records regarding qualifications of training manager and principal instructor

 Current curriculum and course materials

 Course test blueprints

 Information regarding how hands-on assessments are conducted

 Quality control plan

 Results of students’ hands-on assessments and course tests

 Record of each student’s course completion certificate
Individuals/Firms

To obtain certification to perform lead-based paint activities or renovations in target 

housing or child-occupied facilities, firms must submit specific materials to EPA/state, using the 

sample EPA form “Application for Firms to Conduct Lead-based Paint Activities or 

Renovations” or a similar form requiring the same information:

 List of current permits, licenses, certifications, or registrations in the lead-based 

paint field held by the firm

 Explanation of any violations of lead-based paint

 Certification statement that the firm will employ only properly certified or trained 

individuals and that its employees will follow the specified work practice 

standards

Firms may later amend their applications to add or modify information. Lead-based paint 

activities firms must be recertified every three years, while renovation firms must be recertified 

every five years.

Firms conducting renovations are required to maintain records demonstrating compliance 

with the final rule requirements for using certified renovators and properly trained workers, 

posting signs, containing and cleaning the renovation work area, and performing a postrenovation cleaning verification or dust clearance testing after renovation activity is finished. 

To obtain certification, individuals engaged in lead-based paint activities are required to 

submit specific materials to EPA/state:

 Inspectors, risk assessors, supervisors: accredited training course completion 

certificate, statement certifying the individual meets the education/experience 

prerequisites, proof of passage of the third-party exam

 Project designers: statement certifying individual meets the education/experience 

prerequisites, accredited training course completion certificate

 Workers: accredited training course completion certificate

In the performance of lead-based paint activities, firms/individuals must complete and 

retain a number of reports (contingent on the activity conducted), including:

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

sampling results

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

sampling results

 A risk assessment report, which includes an accounting of paint, dust, or soil 

sampling results and existing hazards

 An occupant protection plan identifying the measures that will be taken to protect 

building occupants from lead-based paint hazards

 An abatement report detailing the activities undertaken to eliminate the hazard
Certified firms must notify EPA prior to beginning lead-based paint abatement activities 

(except in emergency situations) and provide an updated notice if needed, using either the 

sample form entitled “Notification of Lead-Based Paint Abatement Activities” or a similar form 

containing the required information. Certified firms may provide electronic submissions using 

the Agency’s CDX. Notices should include the following information:

 Notification type (original, updated, cancellation)

 Date when lead-based paint abatement activities will start and end (approximation 

using best professional judgment)

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

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

 Property name 

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

work

 Documentation showing evidence of an EBL determination or a copy of the 

federal/state/tribal/local emergency abatement order (if applicable)

 Name and EPA certification number of the project supervisor

 Approximate square footage/acreage to be abated

 Brief description of abatement activities to be performed

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

the notification

(ii) Respondent Activities

The rule specifies reporting and recordkeeping for authorized states, training providers, 

and individuals/firms undertaking lead-based paint activities and renovations. The rule does not 

require specific forms or applications for submissions.

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

the following activities:

 Read the regulation

 Compare any existing state program requirements to the minimum requirements 

of the federal regulation

 Develop and adopt new legislation as necessary

 Develop and promulgate new regulations as necessary

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

public hearing

 Prepare and submit to EPA an application for program approval

 Maintain program application availability for public inspection for up to one year 

after submission

 Submit an annual report to EPA

Training providers must perform the following activities: 
 Read the regulation

 Prepare and submit an accreditation application to accrediting entity

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

 Provide notice of completion of all courses offered and retain records

 Provide accrediting entity access to records as requested

Firms must perform the following activities:

 Read the regulation

 Submit applications for certification which includes proof of passage of thirdparty exam and/or course completion certificate, and 

 Statement certifying individual meets education/experience requirements 

(applicable to risk assessors, supervisors, and project designers)

 Submit notification of abatement work (does not apply to firms applying for 

renovation only)

 Prepare and retain records 

Individuals seeking certification perform the following activities:

 Read the regulation

 Submit a proof of passage of third-party exam and/or course completion 

certificate, and statement certifying individual meets education/experience 

requirements

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

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND 

INFORMATION MANAGEMENT

5(a) Agency Activities

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

rule:

 Receive, review, and act on applications from states

 Receive, review, and file reports from authorized states

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

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

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

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

 Receive, review, and file notices of abatement activities from certified abatement 

firms.
5(b) Collection Methodology and Management

This section details the data elements for each type of respondent and for each reporting 

or recordkeeping activity. Note that EPA is cited as the accrediting and certifying body, as state 

programs may not necessarily adopt a program requiring the submission or retention of exactly 

the same materials as in the federal program. For the purposes of estimating burden in section 6 

of this ICR, however, the Agency assumes that states adopt the federal program requirements for 

reporting and recordkeeping. In states without authorized programs, EPA is the accrediting and 

certifying body.

The rule provides general instructions to states seeking EPA authorization under this 

regulation. A state may submit an application to EPA any time. The elements necessary for 

application are as follows:

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

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

approval

 An Attorney General or tribal equivalent statement certifying the adequacy of the 

state’s program authority

 Copies of all applicable state statutes and regulations

 The name of the primary agency that is or will be responsible for administering and 

enforcing the program and functions of any other agencies involved in administering the 

program

 A description of the program elements and an analysis of how these elements relate to 

the federal program elements under section 402

 A description of the resources the state intends to devote to the administration and 

enforcement of the program

States authorized for this rule will need to provide a report (or separate reports) to EPA 

describing any significant changes in the programs and enforcement activities.

The rule instructs training programs seeking accreditation for initial training programs to 

submit a one-time application to EPA covering the following elements:

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

 A list of courses for which it is applying for accreditation

 A statement, signed by the training program manager, that certifies that the training 

program meets the minimum requirements (e.g., training hours) established in the rule

 A copy of the test blueprint, which describes the proportion of test questions devoted 

to each major course topic

 A detailed description of the facilities and equipment available for lecture and handson training

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

skills

 A copy of the program’s quality control plan
 For programs that do not adopt the EPA model curriculum, the program must submit, 

in addition to the above materials, a copy of the student manuals and instructor notebooks 

to be used for each course, and a copy of the course agenda, which includes the time 

allocated for each course topic

Training programs must submit the following information to seek accreditation for 

refresher training courses (note that applications for refresher training may be simultaneously

submitted with applications for full-length training programs):

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

 A list of refresher courses for which it is seeking accreditation

 A copy of student manuals and instructor notebooks

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

provisions

Training programs must also seek re-accreditation from EPA every four years. In order 

to receive re-accreditation, the training program must submit:

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

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

 A description of any changes or updates to the training facility or equipment that 

would adversely affect a student’s ability to learn, since its last application was approved

 A statement from the training program manager that the training program complies at 

all times with all rule requirements

The rule specifies that training programs must retain the following records for three years 

and six months and make them available upon EPA request:

 Qualifications of training managers and work practice instructors

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

these materials

 The course test blueprint

 Information on how the hands-on assessment is conducted

 The quality control plan

 Results of the students’ hands-on skills assessments and course tests, and a copy of 

each student’s course completion certificate

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

application

The rule provides general instructions to individuals seeking certification to perform 

lead-based paint activities. Individuals must submit an application to EPA, including the 

following elements:

 Proof of training (for all individuals)
 Evidence that the individual meets the education or experience prerequisites 

(applicable to all but workers and inspectors)

 Proof of completing the standardized certification exam (applicable to all but workers 

and project designers).

Under the rule’s provisions, individuals must seek re-certification every three years (five

years for individuals who have passed a proficiency test as part of their training), submitting to 

EPA an application and a copy of the refresher course completion certificate.

The rule provides specific requirements for firms seeking certification. A firm must 

submit to EPA a letter indicating that the firm will employ only certified individuals to conduct 

lead-based paint activities and follow the work practice standards.

The rule requires that individuals/firms prepare reports during the conduct of lead-based 

paint activities and maintain the reports for no fewer than three years. The requirements are 

specific to the disciplines.

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

the following:

 Date of inspection

 Address of building and units

 Date of construction of building and units

 Unit numbers (if applicable)

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

 Name, signature, and certification number of each certified inspector and/or risk 

assessor conducting testing

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

applicable)

 Each testing method and device and/or sampling procedure employed, including 

quality control data, and, if used, the serial number of the XRF device

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

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

For a risk assessment:

 Date of risk assessment

 Address of residences and buildings

 Date of construction of residences and buildings

 Unit numbers (if applicable)

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

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

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

applicable)

 Results of visual inspection
 Name, address, and telephone of each recognized laboratory conducting analyses of 

samples

 Testing methods and sampling procedures for paint analysis employed

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

 All data collected from on-site testing

 All results of laboratory analyses on samples

 Any other sampling results

 Any background information collected prior to the activity

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

applicable

 Description of the location and type of identified LBP hazards

 Description of options for addressing any LBP hazards.

For a lead hazard screen:

 First 15 items on the risk assessment list above

 Recommendations concerning desirability of follow-up risk assessment.

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

abatement activities.

Before an abatement, the individual/firm must prepare an occupant protection plan 

describing the measures that the individual/firm will take during the abatement to protect 

building occupants from exposure to lead-contaminated dust and debris.

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

following:

 Start and completion dates

 Name and address of each individual or firm conducting the abatement(s) and each 

supervisor assigned to the project

 The occupant protection plan

 Name, address, and signature of each certified risk assessor or inspector conducting 

sampling and the date of clearance testing

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

them

 A detailed description of the abatement, including method employed, locations of 

rooms and/or components, reasons for selecting abatement methods for particular 

components

The Agency will make use of existing technology to simplify the application and 

notification processes where available. In addition to the more traditional methods (mail, 

commercial delivery service, or hand delivery), the Agency will accept faxed course notifications 

from training providers as well as notifications through the Central Data Exchange (CDX). In 
addition, lead abatement and evaluation firms may use CDX to apply for certification and recertification, but individuals, renovation, repair, and painting firms must apply by mail.

5(c) Small Entity Flexibility

EPA has attempted to ensure that regulatory requirements do not unduly burden small 

businesses. The certification process for firms and individuals is very simple. EPA allows 

flexibility in the way that information is prepared and presented, in that there are no mandatory

forms to complete, CDX can be used in many instances, and faxed notifications are also 

permitted. 

5(d) Collection Schedule

For authorization, certification and accreditation, collection activities will occur 

according to the following schedule:

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

 Training providers may apply for accreditation at any time

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

initial accreditation

 Firms/individuals may apply for certification at any time

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

renovations

 Firms/individuals must apply for re-certification every three years (five for 

individuals who have passed a proficiency test as part of their training) after 

initial certification for lead-based paint activities

The Agency believes that receipt of notification of five and seven business days 

respectively prior to conducting lead-based paint abatement activities or training courses is 

necessary to facilitate the inspection of abatement and training locations. The regulation also 

includes provisions for updating the original notification. The Agency determined that the time 

periods for initial notification will also apply to a change in course location, or if the course is to 

be presented earlier than described in the original notification. Other changes, including 

cancellation of courses or abatement projects, need only be received by the Agency at least two 

business days before a training course is scheduled to begin, or by the start date of an abatement 

activity. Such notification periods are appropriate to allow proper allocation of EPA compliance 

monitoring and enforcement resources, and to prevent the arrival of Agency personnel at the 

wrong location or time.

6. ESTIMATING THE BURDEN AND COST

This section estimates the burden of reporting and recordkeeping for the lead-based paint 

(LBP) activity requirements under sections 402 (a) and 404 of TSCA and the renovation, repair, 

and painting (RRP) requirements under TSCA section 402(c)(3). This burden combines the 

burdens approved under three previously approved ICRs: (1) EPA ICR No. 1715.09 (the ICR 
renewal for the lead-based paint activities/abatement program), (2) EPA ICR No. 1715.10 (the 

ICR addendum for the 2008 RRP final rule), and (3) EPA ICR No. 1715.12 (the ICR addendum 

for the 2010 RRP opt-out and recordkeeping final rule)2. This supporting statement provides 

average annual burden and cost estimates for the next three years of the program. All costs are 

presented in year 2009 dollars.

Sections 6(a) and 6(b) estimate the respondents’ paperwork burdens and costs, 

respectively. Section 6(c) estimates agency costs, section 6(d) summarizes the bottom line 

burden and costs, section 6(e) describes the reasons for changes in burden from the previous 

ICRs, and section 6(f) presents the burden statement.

6(a) Estimating Respondent Burden

This section presents the estimated hour burden associated with this information 

collection. Five types of respondents will be affected by this information collection activity:

1) LBP training providers: training providers who are accredited to offer LBP evaluation 

and abatement training courses; 

2) RRP training providers: training providers who are accredited to offer Renovator 

training courses;

3) LBP firms: firms who are certified to perform lead-based paint evaluation and abatement 

activities;

4) RRP firms: firms who are certified to perform renovation, repair, or painting (RRP) 

activities; and

5) LBP professionals: individuals who are certified to perform lead-based paint evaluation 

and abatement activities. 

The burdens and costs fall into the following categories: 1) applying for initial 

accreditation or certification, 2) applying for renewal of accreditation or certification, 3) annual 

reporting (or reporting during the course of the year), and 4) annual recordkeeping (or 

recordkeeping during the course of the year). The reporting burden estimates include the time 

associated with completing and sending the reports to the appropriate authority, as well as the 

time required for collecting information needed to complete the report. The recordkeeping 

burden estimates include the time associated with copying, filing and maintaining the records. In 

addition, states, tribes, other governmental entities administering authorized programs, and the 

federal government will be affected in their role as administrators of the programs.

Training Provider Burden: Number of Training Providers and Accreditation 

Applications

EPA estimated the numbers of two different types of training providers: (1) training 

providers offering lead-based paint evaluation and abatement activity courses (LBP training 

providers), and (2) training providers offering renovator courses (RRP training providers). The 

number of LBP training providers was estimated from the number of accredited training provider 

 

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

superseded by the ICR addendum for the final rule.
applications in EPA administered regions in 2007-2009 according to the Federal Lead-Based 

Paint Program (FLPP) database. Since these data only pertain to LBP training providers who 

operate in areas administered by EPA, the number of LBP training providers operating 

nationwide was estimated assuming that the number of entities and activities in EPA 

administered areas represents 17 percent of the national number of entities and activities. This 

value is derived in EPA’s 1999 Economic Analysis of the Final TSCA Section 402(a)(3) LeadBased Paint Accreditation And Certification Fee Rule, which estimated that 17 percent of the 

lead-based paint hazards nationwide are in EPA administered states compared to states 

administering their own programs.

There were 325 training providers accredited to offer lead-based paint activities courses 

in EPA administered areas during the period 2007-2009. As described above, the number of 

training providers accredited nationally is estimated as 325 divided by 17 percent, or 1,912 LBP 

training providers. Based on the number of initial accreditation and renewal accreditation 

applications received by EPA, it appears that most training providers file one of these 

applications each year. There are 10 different lead-based paint activities courses, an initial and a 

refresher course for five different disciplines, and while one application can be used to apply for 

multiple accreditations, it appears that rather than renewing all accreditations once every four 

years, training providers stagger their renewal accreditation applications, renewing accreditation 

for a few courses each year. Based on the average number of applications received between 

2007 and 2009, it was estimated that about 150 training providers file an initial accreditation 

application and 130 file a renewal accreditation application with EPA in a given year.3 Thus, by

dividing these numbers by 17 percent the national number of applications is estimated to be 882 

initial accreditation applications and 765 renewal accreditation applications for LBP training 

providers. 

EPA expects there will be approximately 600 training providers accredited for Renovator 

training. Since renewal accreditation is required every 4 years, it was estimated that one quarter 

of training providers will seek accreditation in a given year. Based on the number of LBP 

training provider applications recorded in the FLPP database between 2007 and 2009, 54 percent 

of accreditations are initial accreditations, implying that either there is a high rate of turnover for 

training providers, or that training providers may let their accreditation lapse if they offer these 

courses infrequently. Since 54 percent of LBP training provider accreditation applications are 

initial applications, this implies a turnover rate of about 14% per year (14%=54% divided by 4 

years). Based on this, it is estimated that EPA will receive 81 initial accreditation applications 

and 69 refresher accreditation applications each year over the next three years for RRP training 

providers. 

 

3 The FLPP database indicates that there were about 300 initial accreditation applications for the worker discipline 

course, which is the most frequently offered course. Since there are two types of worker courses (initial and 

refresher), 300 was divided by two to estimate that 150 training providers apply for initial accreditation annually. 

Thus, it is assumed that training providers applying for accreditation in other disciplines are applying for worker 

course accreditation at the same time. The number of training providers applying for renewal accreditation is 

estimated using the same method and assumptions (there were about 259 renewal accreditation applications for the 

worker discipline course).
Exhibit 6.1: Annual Number of Training Providers

Entity Type Number of Entities a

LBP Activity Training Providers

 Initial Accreditation 883

 Renewal Accreditation 765

 Cohort not applying for accreditation 265

 Total 1,912

Renovator Training Providers

 Initial Accreditation 81

 Renewal Accreditation 69

 Cohort not applying for accreditation 450

 Total 600

a Number of entities estimated based on data in EPA’s FLPP database. 

See text above table for detailed description.

Training Provider Burden: Accreditation and Notification Burden

Exhibit 6.2 presents the hour burden for training providers offering LBP evaluation and

abatement courses as a result of this information collection. Training providers applying for 

their initial accreditation incur a burden associated with becoming familiar with the rule’s 

requirements and completing an accreditation statement and quality control plan. Those 

applying for renewal accreditation incur a burden associated with the renewal accreditation 

statement. All training providers incur recordkeeping and reporting burdens associated with 

notifying EPA about upcoming course offerings and providing EPA with notifications that list 

the individuals who have completed their courses. The estimates of burden hours per response 

are adopted from previous ICR renewals, and the numbers of notifications are estimated based 

on the number of notifications received between 2007 and 2009.
Exhibit 6.2: Annual LBP Training Provider Hour Burden

Activities Professional

Hours a

Clerical 

Hours a

Burden 

Hours Per

Activity a

Number of 

Training 

Providers b

Number 

of Events 

Per 

Provider c

Total 

Burden 

Hours

Initial accreditation cohort

 Rule Familiarization 8.00 - 8.00 882 1 7,056

 Accreditation Statement 7.60 2.00 9.60 882 1 8,467

 Quality Control Plan 8.00 2.00 10.00 882 1 8,820

Re-accreditation cohort

 Accreditation Statement 3.80 1.00 4.80 765 1 3,672

 Audit 0.20 0.40 0.60 765 1 459

All Firms

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

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

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

 Recordkeeping - 0.80 0.80 1,912 1 1,530

 Total Reporting 44,535

 Total Recordkeeping 1,530

 Total Reporting and

 Recordkeeping 46,065

a Hour estimates are from the previously approved ICR for LBP activity training providers (EPA ICR No. 

1715.09). The hour estimates were rounded to one significant digit for this ICR.

b

See Exhibit 6.1.

c Number of notifications are estimated based on the average number of notifications received by EPA 

between 2007 and 2009.

Exhibit 6.3 presents the hour burden for RRP training providers offering Renovator 

courses as a result of this information collection. Training providers applying for their initial 

accreditation incur a burden associated with becoming familiar with the rule’s requirements and 

completing an accreditation application. Those applying for renewal accreditation incur a 

burden associated with completing the application. All training providers incur recordkeeping 

and reporting burdens associated with notifying EPA about upcoming course offerings and 

providing EPA with notifications and digital photos of the individuals who have completed their 

courses. 

The estimates for burden hours per response for training providers were slightly higher in 

the previously approved ICR for LBP activity training providers (EPA ICR No. 1715.09) 

compared to the previously approved ICR for RRP activity training providers (EPA ICR No. 

1715.10). For consistency the estimates for burden hours per response from the previously

approved ICR for LBP activity training providers are adopted here for both types of training 

providers. The estimated numbers of notifications per provider are taken from previously

approved ICRs for RRP training providers (EPA ICR No. 1715.10 and 1715.12).
Exhibit 6.3: Annual RRP Training Provider Hour Burden

Activity Professional

Hours a

Clerical 

Hours a

Burden 

Hours Per

Activity a

Number of 

Training 

Providers b

Number 

of Events 

Per 

Provider c

Total 

Burden 

Hours

Initial accreditation cohort

 Rule Familiarization 8.00 0.00 8.00 81 1 648

 Accreditation Statement 7.60 2.00 9.60 81 1 778

 Quality Control Plan 8.00 2.00 10.00 81 1 810

Re-accreditation cohort

 Accreditation Statement 3.80 1.00 4.80 69 1 331

 Audit 0.20 0.40 0.60 69 1 41

All Firms

 Pre-Notification 0.00 0.20 0.20 600 14 1,680

 Re-Notification 0.00 0.20 0.20 600 2 240

 Post-Notification 0.00 1.60 1.60 600 14 13,440

 Digital Photo 0.00 1.30 1.30 600 14 10,920

 Recordkeeping 0.00 0.80 0.80 600 1 480

 Total Reporting 28,888

 Total Recordkeeping 480

 Total Reporting and

 Recordkeeping 29,368

a Hour estimates are from the previously approved ICR for LBP activity training providers (EPA ICR No. 

1715.09). The hour estimates were rounded to one significant digit for this ICR.

b

See Exhibit 6.1.

c Number of notifications are from the previously approved ICRs for RRP activity training providers (EPA 

ICR No. 1715.10 and 1715.12). They were rounded to the nearest digit for this ICR.

Firm Burden: Number of Firms and Certification Applications

Exhibit 6.4 presents EPA’s estimates of the annual number of firms and certification 

applications. During the 2007-2009 period, LBP firms submitted an average of 754 and 791 

initial and renewal certification applications per year, respectively, to EPA. Since renewal 

certification is required every three years, it was estimated that one third of firms will seek 

certification in each year. As described above, the number of national LBP firm certifications 

(4,435 initial and 4,653 renewal) is estimated by dividing the EPA administered estimates (754 

initial and 791 renewal) by 17 percent. The number of LBP firms in the 2nd year cohort is 

assumed to be equal to half the number applying for either initial or renewal certification. 

The number of RRP firms (312,785 private firms and 7,718 government firms) affected 

by this information collection request was taken from EPA’s (2008) Economic Analysis for the 

TSCA Lead Renovation, Repair, and Painting Program Final Rule for Target Housing and 

Child-Occupied Facilities and EPA’s (2010) Economic Analysis for the TSCA Lead Renovation, 

Repair, and Painting Program Opt-out and Recordkeeping Final Rule for Target Housing and 

Child-Occupied Facilities. These economic analyses estimated a turnover rate of about 18 

percent per year, implying that 18 percent of the stock of certified firms will be applying for 

initial certification annually. Based on this, it is estimated that EPA will receive 56,301 private 

firm and 1,389 government firm initial certification applications each year over the next three 
years. Since this is a recent rule no renewal certifications are expected during this reporting 

period.

Exhibit 6.4: Annual Number of Firms and Certification Applications

Entity Type Number of Entities a

LBP Activity Firms

 Initial Certification 4,435

 Renewal Certification 4,653

 2nd year cohort b4,544

 Total 13,632

RRP Private Firms

 Initial Certification 56,301

 Renewal Certification -

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

 Total 312,785

RRP Government Firms

 Initial Certification 1,389

 Renewal Certification -

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

 Total 7,718

a Number of LBP firms estimated based on data in EPA’s FLPP database. 

Number of RRP firms estimated based on related RRP economic 

analyses in 2008 and 2010. See text above table for detailed description.

b The number of LBP activity firms in the 2nd year cohort is estimated as 

the average of those in the initial and renewal certification cohorts.

Firm Burden: Certification, Reporting and Recordkeeping Burden

Exhibit 6.5 presents the hour burden for LBP activity firms as a result of this information 

collection. Firms applying for their initial certification incur a burden associated with becoming 

familiar with the rule’s requirements and completing the certification application. Those 

applying for renewal certification incur a burden associated with the renewal certification 

application. All LBP firms incur recordkeeping and reporting burdens associated with lead 

hazard evaluation reports, notifying EPA about upcoming abatements, preparing occupant 

protection plans, and preparing post-abatement reports.

Assumptions developed for previous LBP activity ICR renewals are the basis for the 

estimated burden hours per response and the number of evaluation reports per LBP firm. The 

number of initial certifications, renewal certifications, notifications, and abatements per firm are 

estimated from the average number of applications and notifications received by EPA between 

2007 and 2009. As described above, the number of activities in EPA administered areas is 

divided by 17 percent to extrapolate to national estimates. 
Exhibit 6.5: Annual LBP Firm Certification, Reporting, and Recordkeeping Burden Hours

Activity Professional

Hours a

Clerical 

Hours a

Burden 

Hours Per 

Activity a

Number of 

Firms b

Number 

of Events 

Per Firm c

Total 

Burden 

Hours

Initial certification cohort

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

 Certification recordkeeping - 0.01 0.01 4,435 1 44

Renewal certification cohort

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

 Certification recordkeeping - 0.01 0.01 4,653 1 47

All Firms

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

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

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

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

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

 Recordkeeping for reports

 and notifications

- 0.01 0.01 13,632 22 2,999

 Recordkeeping for re-

 notifications

- 0.01 0.01 2,616 1 26

 Total Reporting 541,930

 Total Recordkeeping 3,116

 Total Burden 545,046

a Hour estimates are from the previously approved ICR for LBP activities (EPA ICR No. 1715.09). The hour 

estimates were rounded to two significant digits for this ICR. Certifications and notifications are prepared by 

Supervisors, evaluation reports are prepared by Inspectors and Risk Assessors, and occupant protection plans are 

prepared by Project Designers.

b See Exhibit 6.4.

c Number of certifications, notifications, protection plans, and post abatement reports are estimated based on 

data in EPA’s FLPP database between 2007 and 2009. The number of evaluations is estimated based on the 

previously approved ICR (EPA ICR No. 1715.09). The number of recordkeeping events is estimated as the sum 

of the reports and notifications. Numbers were rounded to the nearest two digits for this ICR.

The burden for RRP firms differs from that for LBP firms because of different regulatory

requirements. Exhibit 6.6 estimates the burden hours for privately owned RRP firms as a result 

of this information collection. Exhibit 6.7 presents the hour burden for public schools that will 

be certified RRP firms as a result of this information collection. Firms applying for their initial 

certification incur a burden associated with becoming familiar with the rule’s requirements and 

completing the certification application. Those applying for renewal certification incur a burden 

associated with the renewal certification application. All firms incur recordkeeping and 

reporting burdens associated with providing owners and occupants with checklists that document 

the measures taken to ensure the work was performed in a lead-safe manner. The estimates of 

the numbers of activities and the burden hours per response are adopted from EPA’s (2008) 

Economic Analysis for the TSCA Lead Renovation, Repair, and Painting Program Final Rule for 

Target Housing and Child-Occupied Facilities and EPA’s (2010) Economic Analysis for the 

TSCA Lead Renovation, Repair, and Painting Program Opt-out and Recordkeeping Final Rule 

for Target Housing and Child-Occupied Facilities.
Exhibit 6.6: Private RRP Firm Certification, Reporting, and Recordkeeping Burden Hours

Activity Professional

Hours a

Number 

of Firms

a

Number of 

Events Per 

Firm a

Total Burden 

Hours

Initial Certification 3.50 56,301 1 197,054

Checklist Provision

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

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

 Owner-performed COFb0.05 37,534 1 1,877

 Contractor, owner-occ. COFb

0.05 265,867 1 13,293

 Contractor, renter-occ. COFb

0.05 12,511 1 626

Recordkeeping 4.80 312,785 1 1,501,368

Total 2,621,294

a The estimates of the numbers of firms, activities and the burden hours per response 

are adopted from EPA’s (2008) Economic Analysis for the TSCA Lead Renovation, 

Repair, and Painting Program Final Rule for Target Housing and Child-Occupied 

Facilities and EPA’s (2010) Economic Analysis for the TSCA Lead Renovation, 

Repair, and Painting Program Opt-out and Recordkeeping Final Rule for Target 

Housing and Child-Occupied Facilities.

b Child Occupied Facility (COF)

Exhibit 6.7: Government (Public Schools) RRP Firm Certification, Reporting, 

and Recordkeeping Burden Hours

Burden Element Professional

Hours a

Number 

of Firms

a

Number of 

Events Per 

Firm a

Total Burden 

Hours

Initial Certification 3.50 1,389 1 4,862

Checklist Provision

 Owner-performed COF b0.05 7,718 8 3,087

Recordkeeping 4.80 7,718 1 37,046

Total 44,995

a The estimates of the numbers of firms, activities and the burden hours per response 

are adopted from EPA’s (2008) Economic Analysis for the TSCA Lead Renovation, 

Repair, and Painting Program Final Rule for Target Housing and Child-Occupied 

Facilities and EPA’s (2010) Economic Analysis for the TSCA Lead Renovation, 

Repair, and Painting Program Opt-out and Recordkeeping Final Rule for Target 

Housing and Child-Occupied Facilities.

b Child Occupied Facility (COF)

Individual Reporting Burden

Exhibit 6.8 presents the hour burden for individuals engaged in LBP activities as a result 

of this information collection. Note that there is no burden for individuals under the RRP 

program associated with this ICR because Renovators are not required to send an application to 

EPA. Individuals incur burdens associated with completing the applications for initial and 

renewal certification. The burden per individual is the same as estimated under previous ICR 

renewals and the numbers of affected individuals are estimated from the average numbers of 

applications received by EPA between 2007 and 2009. As described above, the number of 
individuals in EPA administered areas is divided by 17 percent to extrapolate to national 

estimates.

Exhibit 6.8: LBP Individual Certification Burden Hours

Burden Element Professional 

Hours

Number of 

Individuals a

Total Burden 

Hours

Initial Inspector Certification 1.00 1,696 1,696

Renewal Inspector Certification 1.00 1,167 1,167

Initial Risk Assessor Certification 1.00 5,294 5,294

Renewal Risk Assessor Certification 1.00 6,312 6,312

Initial Supervisor Certification 1.00 3,410 3,410

Renewal Supervisor Certification 1.00 3,212 3,212

Initial Worker Certification 0.50 6,704 3,352

Renewal Worker Certification 0.50 2,792 1,396

Initial Project Designer Certification 0.50 265 133

Renewal Project Designer Certification 0.50 316 158

Total Individual Burden 26,130

a The numbers of affected individuals are estimated from the average numbers of applications 

received by EPA between 2007 and 2009. As described above, the number of individuals in 

EPA administered areas is divided by 17 percent to extrapolate to national estimates.

6(b) Estimating Respondent Costs

The cost estimates addressed in this section are based on the burden estimates discussed 

in section 6(a). Wage rates for each category of personnel are derived with methods and from 

sources either identical to or very similar to those used in previous ICR renewals and related 

economic analyses. However, to simplify the calculations a uniform loading factor of 60 percent 

for fringe benefits and overhead was applied to all categories of labor for this ICR, whereas 

earlier related economic analyses utilized occupation-specific loading rates in some cases. 

Non-governmental wages are drawn from the 2009 full-time mean hourly earnings 

annual data in the Bureau of Labor Statistics (BLS) National Compensation Survey: 

Occupational Wages in the United States, June 2010, Table 2-2 (Private industry, selected 

occupations, mean hourly earnings). The BLS occupational categories have been revised since 

the most previous ICR renewals, and therefore the wages for the occupations that best match the 

ICR labor categories were selected as shown in Exhibit 6.9.
Exhibit 6.9: Private Sector Wage Rates for Calculating Labor Costs (2009$)

ICR Labor Category BLS Occupation Category June 2009 

Wage Rate

Wage with Fringe 

and Overhead

Training Provider Professional Professional and related $32.16 $51.46

Training Provider and LBP 

Firm Clerical

Office and administrative 

support occupations

$16.28 $26.05

Inspector or Risk Assessor Environmental engineering 

technicians $22.48 $35.97

Project Designer Environmental Engineer $39.74 $63.58

Supervisor/Renovator Supervisors/managers of 

construction trades and 

extraction workers

$29.94 $47.90

Abatement Worker Construction and extraction 

occupations $17.50 $28.00

Training Provider Cost: Accreditation and Notification Cost

Exhibit 6.10 and Exhibit 6.11 present the costs associated with this information collection 

for training providers offering LBP activity courses and Renovator courses, respectively. The 

estimates of the material costs per response are based on the assumptions from ICR renewals, 

updated to 2009 dollars. These costs are calculated using the burden estimates presented in 

Exhibit 6.2 and Exhibit 6.3, the wage rates presented above in Exhibit 6.9, and a notification 

material cost of $0.10 for a photocopy, $0.03 for an envelope, and $0.44 for a stamp. 

Exhibit 6.10: LBP Training Provider Cost (2009$)

Cost Element Number 

of 

Training 

Providers

Events 

per 

Training 

Provider

Material 

Cost Per 

Event 

Total 

Material 

Cost a

Total 

Labor 

Cost b

Total Cost

Initial accreditation cohort

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

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

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

Re-accreditation cohort

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

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

All Firms

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

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

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

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

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

 Total Recordkeeping - $39,846 $39,846

 Total Reporting and

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

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

stamp.
b Wage rates of $51.46 and $26.05 are applied to the professional and clerical hour burdens, respectively, 

presented in Exhibit 6.2. See Exhibit 6.9 for a summary of wage rate definitions and sources.

Exhibit 6.11: RRP Training Provider Cost (2009$)

Cost Element Number 

of 

Training 

Providers

Events 

per 

Training 

Provider

Material 

Cost Per 

Event 

Total 

Material 

Cost a

Total 

Labor 

Cost b

Total Cost

Initial accreditation

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

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

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

Re-accreditation cohort

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

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

All firms

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

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

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

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

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

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

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

 Total Reporting and

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

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

stamp.

b Wage rates of $51.46 and $26.05 are applied to the professional and clerical hour burdens, respectively, 

presented in Exhibit 6.3. See Exhibit 6.9 for a summary of wage rate definitions and sources.

Firm Certification, Reporting and Recordkeeping Costs

Exhibit 6.12, Exhibit 6.13, and Exhibit 6.14 present the costs associated with this 

information collection for LBP activity firms, private RRP firms, and government RRP firms, 

respectively. The estimates of the material costs per response are based on assumptions 

developed for previous ICR renewals, updated to 2009 dollars. These costs are calculated using 

the burden estimates presented in Exhibit 6.5, Exhibit 6.6, and Exhibit 6.7; the wage rates used 

are presented in Exhibit 6.9 and the material costs used are $0.10 per photocopy, $0.03 for an 

envelope, and $0.44 for a stamp. 
Exhibit 6.12: LBP Firm Cost (2009$)

Cost Element Number 

of Firms

Events 

per 

Firm

Material 

Cost Per 

Event 

Total 

Material 

Cost a

Total Labor 

Cost b

Total Cost

Initial certification cohort

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

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

Renewal certification cohort

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

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

All Firms

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

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

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

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

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

 Recordkeeping for reports

 and notifications

13,632 22

$0.00

$0 $78,125 $78,125

 Recordkeeping for re-

 notifications

2,616 1

$0.00

$0 $681 $681

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

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

 Total Reporting and

 Recordkeeping

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

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

envelope and $0.44 for a stamp.

b Wage rates of $47.90 (Supervisor) are applied to the professional hour burdens presented in Exhibit 6.5 for 

certifications and notifications. The Inspector/Risk Assessor wage rate ($35.97) is applied to the evaluation 

report burden presented in Exhibit 6.5. The Project Designer wage rate ($63.58) is applied to the occupant 

protection plan burden presented in Exhibit 6.5. See Exhibit 6.9 for a summary of wage rate definitions and 

sources.

Exhibit 6.13: Private RRP Firm Cost (2009$)

Cost Element Number 

of Firms

Events 

per Firm

Material Cost 

Per Event 

Total 

Material 

Cost a

Total Labor 

Cost b

Total Cost

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

Checklist Provision

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

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

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

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

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

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

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

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

a Material costs include $0.10 per copy for photocopies. For initial certification, material costs include $0.03 for 

an envelope and $0.44 for a stamp.

b Wage rates of $47.90 (Renovator) are applied to the professional hour burdens presented in Exhibit 6.6. See 

Exhibit 6.9 for a summary of wage rate definitions and sources.
Exhibit 6.14: Government RRP Firm Cost (2009$)

Cost Element Number 

of Firms

Events 

per Firm

Material 

Cost Per 

Event 

Total 

Material 

Cost a

Total Labor 

Cost b

Total Cost

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

Checklist Provision

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

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

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

a Material costs include $0.10 per copy for photocopies. For initial certification, material costs include $0.03 for 

an envelope and $0.44 for a stamp.

b Wage rates of $47.90 (Renovator) are applied to the professional hour burdens presented in Exhibit 6.7. See 

Exhibit 6.9 for a summary of wage rate definitions and sources.

Individual Certification, Reporting and Recordkeeping Costs

Exhibit 6.15 presents the costs associated with this information collection for individuals 

performing LBP activities. These costs are calculated using the burden estimates presented in 

Exhibit 6.8 and the wage rates presented in Exhibit 6.9.

Exhibit 6.15: Individual Costs (2009$)

Cost Element Number 

Respondents

Wage Rate Total Cost

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

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

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

Renewal Risk Assessor 

Certification 6,312 $35.97

$227,043

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

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

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

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

Initial Project Designer 

Certification 265 $63.58

$8,424

Renewal Project Designer 

Certification 316 $63.58

$10,046

Total Individual Costs $989,058

See Exhibit 6.9 for a summary of wage rate definitions and sources. These wage rates 

are applied to the professional burden hours presented in Exhibit 6.8

6(c) Estimating Agency Cost

Government Wage Rates 

The wage rates for state and federal government employees are taken from the federal 

government’s GS Salary Table for hourly wages, effective January 2009 (See Exhibit 6.16). The 

wages for EPA headquarters workers are taken from the table including locality pay for the 

Washington-Baltimore area. 
Exhibit 6.16: Government Wage Rates

ICR Labor Category Government Occupation 

Category

2009 Wage 

Rate

Wage With 

Fringe And 

Overhead

State and EPA Region 

Professional

GS 11, step 1

$27.03 $43.25

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

State and EPA Region 

Managerial

GS 13, step 1

$38.53 $61.65

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

Authorized Program Costs 

This ICR renewal includes an estimate for the entities authorized to administer the LBP 

and RRP programs. As discussed in section 6(a) of this ICR, 39 states and three tribal areas, as 

well as Puerto Rico and the District of Columbia, have sought and been granted authorization to 

administer their own LBP activity programs under TSCA section 402. The labor hours incurred 

by authorized programs includes the following activities:

 Application processing and recordkeeping 

 Certification exam processing and recordkeeping

 Training course audits

 Fee transactions and waivers

 Issuance of certification documents

 Public assistance/outreach

 Reporting (to overseeing agencies)

 Other management

Exhibit 6.17 presents the labor hours incurred by states, tribes, and other government 

entities authorized to administer LBP activity programs. The estimated hours per activity

incurred by authorized programs were derived in EPA’s (2009) Economic Analysis for the TSCA 

Section 402 Lead-Based Paint Program Accreditation and Certification Fee Rule. The numbers 

of events are estimated as described above for each respondent type. Following the previously 

approved ICR, 83 percent of LBP activity events nationwide are estimated to occur in areas 

administered by authorized programs. EPA expects there will be 20 states total in the next 3 

years with the authorization to administer the RRP program (about 40% of the states). For 

example, since there are 44 authorized programs, 765 renewal LBP activity training provider 

accreditations and 69 renewal RRP training provider applications, it is estimated that there are 15 

renewal training provider accreditation applications on average for authorized programs: 

15=(83%*765)/44+(40%*69)/44.
Exhibit 6.17: Authorized Program Labor Hours 

Authorized

Programs a

Number 

Events 

Per 

Program b

Labor Hours Per-Event c Total 

Labor 

Prof. Cler. Mgmt. Hours

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

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

Initial Firm Certification 44 608 0.05 0.59 0.00 17,121

Renewal Firm Certification 44 88 0.04 0.74 0.00 3,020

Initial Individual Certification 44 328 0.07 0.69 0.01 11,113

Renewal Individual Certification 44 260 0.05 0.81 0.01 9,953

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

 Total 59,440

a

39 states and three tribal areas, as well as Puerto Rico and the District of Columbia, have sought and been 

granted authorization to administer their own LBP activity programs under TSCA section 402. About half of the 

states authorized to administer the LBP activity program are projected to obtain authorization to administer the 

RRP program over the next three years.

b The numbers of events are estimated as described above for each respondent type, and following the previously 

approved ICR (EPA ICR No. 1715.09), 83 percent of LBP activity events nationwide are estimated to occur in 

areas administered by authorized programs. 

c The estimated labor hours incurred by authorized programs were derived in EPA’s (2009) Economic Analysis 

for the TSCA Section 402 Lead-Based Paint Program Accreditation and Certification Fee Rule. Time estimates 

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

This ICR renewal includes a cost estimate for the administration of the LBP and RRP 

programs by authorized programs. As discussed in section 6(a) of this ICR, 39 states and three 

tribal areas, as well as Puerto Rico and the District of Columbia, have sought and been granted 

authorization to administer their own programs under TSCA section 402. Exhibit 6.18 presents 

the average annual total costs to authorized programs from this information collection. 

Exhibit 6.18: Authorized Program Costs (2009$)

Cost Element Total Cost

Initial Training Provider Accreditation $370,650

Renewal Training Provider Accreditation $73,988

Initial Firm Certification $472,962

Renewal Firm Certification $82,055

Initial Individual Certification $314,488

Renewal Individual Certification $275,498

Other State Program Administration 

Activities

$76,028

Total $1,665,669

Total costs are calculated by applying the wage rates of $43.25, 

$26.30, and $61.65 to the hour burdens presented in Exhibit 6.17 for 

professional, clerical and managerial, respectively. See Exhibit 6.9

for a summary of wage rate definitions and sources. 
EPA Costs 

This ICR renewal includes a cost estimate for the administration of the LBP and RRP 

programs by the Agency. Exhibit 6.19 presents the average annual total costs to EPA from this 

information collection. The per-activity burdens are taken from those derived in EPA’s (2009) 

Economic Analysis for the TSCA Section 402 Lead-Based Paint Program Accreditation and 

Certification Fee Rule.

4

 The labor costs are estimated by applying the labor burdens shown in 

Exhibit 6.19 by $43.25, $26.30, $61.65, and $46.75 for EPA Region professional, EPA Region 

clerical, and EPA Region managerial, and EPA Headquarters professional labor, respectively 

(See Exhibit 6.9 for a summary of wage rate definitions and sources). 

The numbers of events are estimated for each respondent type, and following the 

previously approved ICR (EPA ICR No. 1715.09), 17 percent of LBP activity events nationwide 

are estimated to occur in areas administered by EPA. Since about 20 states are projected to 

obtain authorization to administer the RRP program over the next few years, it is estimated that 

60 percent of RRP activity events nationwide will occur in areas administered by EPA Regions 

during the three year period covered by this ICR renewal. For example, since there are 765 

renewal LBP activity training provider accreditations, 69 renewal RRP training provider 

applications, and 660 occur in areas with authorized programs, 174 (174 = 765 + 69 - 660) are 

estimated to occur in areas administered by EPA Regions.

Exhibit 6.19: EPA Labor Hours and Cost

Activity

Number 

of

Events a

Labor Hours Per Event 

Total 

Labor 

Hours 

Total 

Labor 

Cost

Contrac

t Cost 

Per 

Event

Total Cost Prof. Cler. Mgmt.

EPA Region Labor

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

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

Initial Firm Certification 35,373 0.05 0.59 0.00

22,639 $625,37

7

$625,377

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

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

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

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

Total EPA Region Labor 32,500 $917,105

EPA Headquarters Labor

Headquarters Support

1 4,160 0 0

4,160 $194,48

0

$194,480

Contractor application 

processing 83,590 $5.48

$458,073

Contractor database 

maintenance 1 $197,397

$197,397

Total EPA HQ Labor 4,160 $849,950

Total EPA Labor 36,660 $1,767,05

5

a The numbers of events are estimated as described above for each respondent type, and following the previously 

 

4 Burdens were rounded to the nearest significant two digits and burdens less than 0.01 were rounded up to 0.01.
approved ICR (EPA ICR No. 1715.09), 17 percent of LBP activity events nationwide are estimated to occur in 

areas administered by EPA. 

6(d) Bottom Line Burden Hours and Cost

The number of respondents, responses, average per-respondent burden, total burden, and 

total costs are shown in Exhibit 6.20, Exhibit 6.21, Exhibit 6.22, and Exhibit 6.23. The estimates 

of the numbers of small firms and governments are estimated from the previous ICR renewals 

and related economic analyses. The average annual paperwork burden is estimated be 3,312,524 

hours. The total annual respondent cost for the collection of notification information is estimated 

to be $155,901,692. The Agency cost is estimated to average $3,432,724 per year, as shown in 

Exhibit 6.24. 

Exhibit 6.20: Total Respondent Burden and Cost for Individuals

Respondent Type Number 

Respondents

Responses 

Per 

Respondent

Number 

Responses

Average 

Burden Hours 

Per Response

Total 

Burden 

Hours

Total Cost

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

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

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

Renewal Risk 

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

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

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

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

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

Initial Project 

Designer 265 1 265 0.50 132.50 $8,424.35 

Renewal Project 

Designer 316 1 316 0.50 158.00 $10,045.64 

Total 31,168 1 31,168 0.8383438142 26,130 $989,058 
Exhibit 6.21: Total Respondent Burden and Cost for Private Firms

Respondent Type

Number 

of Small 

Respondents

Number of 

Respondents

Responses 

Per 

Respondent

Number of 

Responses

Average 

Burden Per 

Response

Total 

Burden 

Hours

Total Cost

Reporting Burden

LBP Training Providers

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

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

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

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

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

RRP Training Providers

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

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

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

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

RRP Training Provider 

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

LBP Activity Firms

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

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

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

Pre-abatement 

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

Abatement renotifications 2,589 2,616 1 2,616 0.22 575.52 $29,320.13 

Occupant protection 

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

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

Private RRP Firms

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

Recordkeeping

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

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

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

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

LBP Firm Renotifications 2,589 2,616 1 2,616 0.01 26.16 $681.47 

RRP Firm

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

Third Party Disclosure: RRP Firm Checklists

RRP Firm Checklist 

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

RRP Firm Checklist 

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

RRP Firm Checklist In 

house/Landlord 37,152 37,534 1 37,534 0.05 1,876.70 $93,647.33

RRP Firm Checklist 

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

RRP Firm Checklist 

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

Overall Private Firm Bottom Line
Reporting subtotal 325,453 328,929 1.285399 422,805 1.9205874 812,034 $33,709,177 

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

Third party disclosure 

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

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

Exhibit 6.22: Total Respondent Burden and Cost for Government Firms

Respondent Type

Number 

of Small 

Respondents

Number of 

Respondents

Responses Per 

Respondent

Number of 

Responses

Average 

Burden Per 

Response

Total 

Burden 

Hours

Total Cost

Reporting Burden

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

Recordkeeping

RRP Firm 

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

Third Party Disclosure: RRP Firm Checklists

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

Overall Government Firm Bottom Line

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

Exhibit 6.23: Overall Respondent Bottom Line Burden and Cost

Respondent Type

Number 

of Small 

Respondents

Number of 

Respondents

Responses Per 

Respondent

Number of 

Responses

Average 

Burden Per 

Response

Total 

Burden 

Hours

Total Cost

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

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

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

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

Exhibit 6.24: EPA Labor Hours and Cost

Type Total Cost

Authorized Programs $1,665,669 

EPA Regions $917,105 

EPA HQ $849,950 

Total EPA $3,432,724 
6(e) Reasons For Changes in Burden

This information collection combines the burdens from three previously approved ICRs, 

EPA ICR No. 1715.09, EPA ICR No. 1715.10, and EPA ICR No. 1715.12. The total combined 

burden from these three previously approved ICRs was 3,804,495 hours. The total burden 

requested for this ICR is 3,312,524 hours. Note that the pre-renovation education burden for 

Child Occupied Facilities is no longer accounted for in this ICR, but was included in EPA ICR 

No. 1715.10. This pre-renovation education burden has been moved from this ICR to the 

renewal request for the pre-renovation education ICR, EPA ICR No. 1669. The difference 

between the current burden request and the previously approved requests are due to adjustments 

in EPA’s estimates of the burden. Several adjustments to the estimates were made, including:

 Revisions to the estimated number of respondents based on the number of respondents 

reporting to EPA for the prior information collection;

 Revisions to the per-activity burden estimates to simplify some assumptions (e.g., rounding a 

per-activity burden to 0.01 from 0.0083) and to make estimation methods consistent across 

the three different ICRs (e.g., include envelope costs for all notifications, where not all 

previously approved ICRs included envelope costs); and

 Burden hours and costs to authorized programs are accounted for as Agency burden rather 

than respondent burden for this ICR.

The total combined cost burden from these three previously approved ICRs was 

$127,139,355. The total cost burden requested for this ICR will be $155,901,692. The 

difference between the current cost burden request and the previously approved requests are due 

only to adjustments in EPA’s estimates of the burden. In addition to the adjustments listed 

above, the wage rates and material costs were revised to reflect 2009 dollars for this information 

collection request. Exhibit 6.25 presents a comparison of the current and previously approved 

information collection requests. The primary reasons for the differences are as follows:

 The overall burden for individuals performing LBP activities is higher since more individuals 

are estimated to apply for certification in the current ICR. This higher estimate is due to an 

increase in the number of individual applications received by EPA between 2007 and 2009.

 The overall burden for LBP activity training providers is higher for this ICR despite a 

decrease in the number of training providers. Based on the number of accreditation 

applications received by EPA between 2007 and 2009, each training provider submits more 

accreditation applications than previously estimated. This appears to be because training 

providers are submitting separate applications for separate courses rather than applying for 

accreditation in multiple courses at one time. The decrease in the number of training 

providers is due to a decrease in the number of EPA accredited providers over the 2007 to 

2009 period.

 The overall burden for RRP training providers is higher for this ICR despite a lower burden 

estimate per provider. The burden per RRP training provider is lower because all training 

providers needed to apply for initial accreditation during the previous reporting period which 

covered the initial implementation of the rule. Most RRP training providers will not need to 

renew their accreditation during this reporting period. This ICR estimates an increase in the 

estimated number of accredited RRP training providers. 
 The overall burden for LBP firms is lower for this ICR as the effect of a lower burden per 

firm dominates the effect of the increase in the estimated number of firms. The lower 

estimated burden per firm is because EPA received substantially fewer notifications per firm 

between 2007 and 2009 than was estimated for the previous information collection request. 

Specifically, the average firm during 2007-2009 performed one abatement instead of the 14 

abatements estimated in the previously approved ICR.

 The overall burden for private and government RRP firms is lower for this ICR primarily due 

to a lower burden per firm. The burden per firm is lower because most firms applied for 

certification at the end of the previous reporting period and will not need to renew it during 

this reporting period. The number of firms is estimated to be slightly smaller for this 

reporting period following the related economic analyses, which assumed that the number of 

firms would decline slightly over time with the size of the pre-1978 housing stock.

 The burden for authorized programs is accounted for along with agency costs in the current 

ICR, rather than as respondent burden.

Exhibit 6.25: Comparison of Current and Previous Information Collection Request

Respondent Type Number of Respondents Burden Per Respondent Respondent Burden 

Hours

Previously Approved Information Collection

LBP Individuals 11,336 0.83 9,420

LBP Training Providers 2,483 1.74 4,322

RRP Training Providers 167 127.88 21,356

LBP Firms 8,466 80.13 678,384

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

Government RRP Firms 7,750 6.92 53,629

Authorized Programs 44 1,877.59 82,614

Total 344,320 11.06 3,809,753

Current Information Collection Request

LBP Individuals 31,168 0.84 26,130

LBP Training Providers 1,912 24.09 46,065

RRP Training Providers 600 48.95 29,368

LBP Firms 13,632 39.98 545,046

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

Government RRP Firms 7,718 5.83 44,995

Authorized Programs 0 0.00 0

Total 367,815 9.01 3,312,524

Difference In Estimates

LBP Individuals 19,832 0.01 16,710

LBP Training Providers -571 22.35 41,743

RRP Training Providers 433 -78.93 8,012

LBP Firms 5,166 -40.15 -133,338

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

Government RRP Firms -32 -1.09 -8,634

Authorized Programs -44 -1877.59 -82,614

Total 23,495 -2.05 -497,229
6(f) Burden Statement

The annual public burden for this collection of information, which is approved under 

OMB Control No. 2070-0155, is estimated to average 0.8 hours for individuals, 9.9 hours for 

firms, and 5.8 hours for governments (calculated from the number of respondents and total hour 

burden presented in Exhibit 6.23). According to the Paperwork Reduction Act, “burden” means 

the total time, effort, or financial resources expended by persons to generate, maintain, retain, or 

disclose or provide information to or for a federal agency. For this collection it includes the time 

needed to review instructions; develop, acquire, install, and utilize technology and systems for 

the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with 

any previously applicable instructions and requirements; train personnel to be able to respond to 

a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. An agency may not conduct or 

sponsor, and a person is not required to respond to, a collection of information unless it displays 

a currently valid OMB control number. The OMB control numbers for EPA’s regulations in title 

40 of the CFR, after appearing in the Federal Register, are listed in 40 CFR part 9 and included 

on the related collection instrument or form, if applicable.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQOPPT-2010-1007, which is available for online viewing at www.regulations.gov, or in person 

viewing at the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., 

NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the 

Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention and 

Toxics Docket is (202) 566-0280. You may submit comments regarding the Agency's need for 

this information, the accuracy of the provided burden estimates and any suggested methods for 

minimizing respondent burden, including the use of automated collection techniques.

Submit your comments, referencing Docket ID No. EPA-HQ-OPPT-2010-1007 and 

OMB Control No. 2070-0155, to (1) EPA online using www.regulations.gov (our preferred 

method), or by mail to: Document Control Office (DCO), Office of Pollution Prevention and 

Toxics (OPPT), Environmental Protection Agency, Mail Code: 7407T, 1200 Pennsylvania Ave., 

NW, Washington, D.C. 20460, and (2) OMB by mail to: Office of Information and Regulatory

Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th 

Street, NW, Washington, DC 20503.