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 Trai ning, 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 exist ing I CRs 1715.09 (I CR for lead
based paint activities), 1715.10 (I CR addendum for the 2008 RRP final rule), and 1715.12 (ICR for the 2010 RRP opt
- out and recordkeeping final rule) 1 covering the reporting and recordkeeping requirements for individuals or fi rms 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 4 0 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 a s an y housing constructed before 1978 except housing for the elderl y 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 re novations in target housing and child
occupied facilities; individuals who perform lead
- based paint activities in target housing and child
- occupied facilities; training providers; and s tates/t erritories/tribes/Alaskan n ative v illages (hereafter, the term “ s tates” includes t erritories/tribes/v illages). 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 ce rtification from EPA/s tates. 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 r ecordkeeping proposed rule, and was superseded by the ICR addendum for the final rule.submit a letter to EPA/s tates 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
- certific ation every three ye ars. 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 n otify 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 o f 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 I CR No. 1669.05 Lead
Based 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: In dividuals who wish to perform lead
- based paint activities in target housing or child
- occupied facilities must also receive cer tification from EPA/ s tates. 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 demons trate this to EPA/s tates. Individuals certified to perform lead
- based paint activities must take a refresher course and appl y for re
- certification every three years (five for individuals who have passed a proficiency

test as part of their training). The r ule 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 requirement s 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, ris k assessors, project designers, abatement supervisors, abatement workers, renovators or dust sampli ng technicians must obtain EPA/s tate ac creditation. In order for EPA/s tates 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 prov iding 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 wi th information necessary to track compliance activity and to prioritize inspections. States: Under TSCA section 404, EPA must review and assess s tate submissions to determine whether to grant authorization to administer a program addressing training, cert ification, accreditation and standards for lead
- based paint activities or renovation, repair, andpainting. A s tate 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 f ederal program and whether it provides adequate enforcement. Authorized s tates need to provide a report to EPA on their activities. 2. NEED FOR AND USE OF THE COLLECTION 2(a) Need/Authority for the C o llection 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 properl y trained; that training programs are accredited; and that c ontractors 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 promul gated 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 curri cula 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 s ection 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 s tat es 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 D ata Public or commercial building owners, child
- occupied facility operators, and parents/guardiansThe 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 cop y 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 s tate renov ation and training rule programs and to serve as the accrediting and certifying body in s tates without authorized programs (discussed further below). EPA/States This collection will enable EPA/ s tates to determine compliance with and enforce the requirem ents 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 th at 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 rel yi ng on guidan ce 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 c ertification and accreditation that an entity seeking such must provide materials to the certifying or accrediting body . The materials the Agency / s tate requires for these activities are central to the activity . In addition, EPA will be relying on trainin g 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 requi rements 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 co nduct 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 entitie s. The records would demonstrate that the activities are done in a safe and effective manner, according to the minimumwork practice standards established by the rules. These recordkeeping requirements are also necessary to permit the Agency

to target it s 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 currentl y 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 I CR will be made available to the public for comment through a Fed eral Register notice. The public will have 60 day s 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 I CR respondents and data users about specific aspects of I CRs before submitting an original or renewal I CR to OMB for review and approval. In accordance with this regulation, EPA will pursue additional con sultations 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, ea ch 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 s tates is a one
time activity , although there is ongoing reporting.3(e) General Guidelines

This I CR is consistent with OMB’s general guidelines. The Agency requires that individuals and firms maintain record s for three years. Authorized s tates report once a year for the first three ye ars and biannually thereafter. The training pro viders should maintain student records as long as the individual is certified following training for a period of three and a half ye ars. This is due to the interim certification period of six months following an individual completing lead
- based paint acti vities training, which allows the i ndividual time to apply to EPA/s tates to receive official certification. At such time, the individual remains certified for three ye ars 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 ye ars is an appropriate period for the retention of such records. It is likely th at 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 i s 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. T HE 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) s tate programs Respondents to the renovation, repair, and painting rule include: 1) firms and individuals engaged in residential renovations or renovations in child
occupied facilities 2) training programs providing training services in renovations 3) s tate 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 an d Industrial Building Construction 23332 Commercial and Institutional Building Construction 23521 Painting and Wall Covering Contractors 23542 Dry

wall, Plastering, Acoustical, and Insulation Contractors 23551 Carpentry

Contractors 23561 Roof

ing, 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 Dry

wall and Insulation Contractors 238170 Siding Contractors 238340 Tile and Terrazzo Contractors 238150 Glass and Glazing Contractors 238390 Other Building Finishing Contra ctors 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 s ection 404, s t ates 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 s tate program. Training Providers To receive accreditation to provide lead
- based paint activities or renovation training, training providers must submit the following documents to EPA/ s tate, using the form entitled “Application and Instructions for Training Providers” or a similar form containing the required information:

 An accreditation statement that clearl y 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 cop y of the course agenda  A cop y of the student and instructor manuals if the train ing provider does not use the EPA model training materials  A cop y 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 I CR approved under OMB Control No. 2025
- 0003.) The initial notice must include the following:

 Notification ty

pe (original, updated, cancellation) Training program name, EPA accreditation number, address, and phone number  Course discipline, ty

pe (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 an y 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 ty pe (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  In formation 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 certificateIndividuals/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/ s tate, using the sample EPA form “Application for Firms to Conduct Lead
- based Paint Activities o r 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 properl y 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 ye ars, while renovation f irms 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 prop erly trained workers, posting signs, containing and cleaning the renovation work area, and performing a post
renovation cleaning verification or dust clearance testing after renovation activity is finished. To obtain certification, individuals engaged in lead
- based paint activities are required to submit specific materials to EPA/ s tate:

 Inspectors, risk assessors, supervisors: accredited training course completion certificate, statement certifying the individual meets the education/experience prerequis ites, proof of passage of the third
- party exam  Project d esigners: 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 hazardCertified firms must notify EPA prior to beginning lead
- based paint abatement a ctivities (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 ty

pe (original, updated, cancellation)  Date when lead
- based paint abatement activities will start and end (approximation using best profes sional judgment)  Firm’s name, EPA certification number, address, phone number  Ty pe of building (e.g. single family dwelling, multi
- family

dwelling, child
occupied 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 cop y of the federal/s tate/tribal/ l ocal emergency abatement order (if applicable)  Name and EPA certification number of the project sup ervisor  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 spe cifies reporting and recordkeeping for authorized s tates, 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 authori zation for the training rule and/or renovation program will perform the following activities:

 Read the regulation  Compare an y existing s tate program requirements to the minimum requirements of the f ederal regulation  Develop and adopt new legislation as ne cessary  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 availabili ty 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 ini tial 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 third
party exam and/or course completion certificate, and  Statement certifying individual meets education/experience requirements (applicable to risk assessors, supervisors, an d project designers)  Submit notification of abatement work (does not apply to firms appl yi ng for renovation only)  Prepare and retain records Individuals seeking certification perform the following activities:

 Read the regulation  S ubmit a proof of passag e of third
- party exam and/or course completion certificate, and statement certifying individual meets education/experience re quirements  R etain records, if individual is incorporated or acting as a firm. 5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND I NFORMATION 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 fro m s tates  Receive, review, and file reports from authorized s tates  Rec eive, 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 typ e of respondent and for each reporting or recordkeeping activity. Note that EPA is cited as the accrediting and certifying body , as s tate programs may

not necessarily

adopt a program requiring the submission or retention of exactl y the same materials as in the federal progr am. For the purposes of estimating burden in s ection 6 of this I CR, however, the Agency assumes that s tates adopt the f ederal program requirements for reporting and recordkeeping. In s tates without authorized programs, EPA is the accrediting and certifyi ng body
. The rule provides general instructions to s tates seeking EPA authorization under this regulation. A s tate may

submit an application to EPA any time. The elements necessary for application are as follows:

 A public notice of intent to seek auth orization, 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 s tate’s program authority  Copies of all applicable s tate statutes and regulations  The name of the primary agency that is or will be responsible for administering and enforcing the program and functions of an y other agencies involved in administering the program  A description of the program e lements and an analy sis of ho w these elements relate to the f ederal program elements under section 402  A description of the resources the s tate intends to devote to the administration and enforcement of the program States authorized for this rule will nee d to provide a report (or separate reports) to EPA describing an y 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 b y the training program manager, that certifies that the training program mee ts the minimum requirements (e.g., training hours) established in the rule  A cop y 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 f or lecture and hands
on training  A detailed description of the procedures for conducting the assessment of hands
- on skills  A cop y 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 cop y of the student manuals and instructor notebooks to be used for each course, and a cop y of the course agenda, which includes the time allocated for each course topic Training programs must submit the following informati on 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 cop y of student manuals and instructor notebooks  A statement signed b y 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 an y changes or updates to the training facility or equipment that would adversel y 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 ye ars 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  In formation 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 eac h 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. Indivi duals 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 complet ing 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 ye ars 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 emplo y onl y 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 ye ars. 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 c ertified firm employing the individual (if applicable)  Each testing method and device and/or sampling procedure emplo yed, 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 app licable)  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 analy ses of samples  Testing methods and sampling procedures for paint analy sis employed  Specific locations of each painted component tested for the presence of LBP  All data collected from on
- site testing  All results of laboratory anal ys es on samples  Any other sampling results  Any background information collected prior to the activity  An evaluation of an y previous inspections, analyses, or assessments of LBP, if applicable  Description of the location and ty pe of identified LBP hazards  Description of options for addressing an y LBP hazards. For a lead hazard screen:

 First 15 items on the risk assessment list above  Recommendations concerning desirabi lity 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 th at 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 comple tion 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 th e date of clearance testing  Results of clearance testing and all soil analy ses, 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). Inaddition, lead abatement and evaluation firms may use CDX to apply for certification and re
certification, but individuals, renovation, repair, and painting firms must apply by mail. 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 i s 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 man y 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 ye ars after initial certification for renovat ions  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 n otification of five and seven business day s respectivel y 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 f

or 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 cha nges, including cancellation of courses or abatement projects, need only be received by

the Agency

at least two business day s 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 prev iously approved I CRs: (1) EPA ICR No. 1715.09 (the ICRrenewal for the lead
- based paint activities/abatement program), (2) EPA I CR No. 1715.10 (the

ICR addendum for the 2008 RRP final rule), and (3) EPA I CR No. 1715.12 (the I CR addendum for the 2010 RRP o pt - 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 ye ar 2009 dollars. Sections 6(a) and 6(b) estimate the respondents’ pa perwork burdens and costs, respectivel y. 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 s tatement. 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: trai ning 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 b urdens and costs fall into the following categories: 1) appl yi ng for initial accreditation or certification, 2) applying for renewal of accreditation or certification, 3) annual reporting (or reporting during the course of the ye ar), and 4) annual recordke eping (or recordkeeping during the course of the ye ar). 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 comp lete the report. The recordkeeping burden estimates include the time associated with copying, filing and maintaining the records. In addition, states, tribes, other government al 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 lea d
- 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 pro vider
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 b y EPA, the number of LBP training pro viders 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 F inal TSCA Section 402(a)(3) Lead
Based 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 wer e 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 b y 17 percent, o r 1,912 LBP training providers. Based on the number of initial accreditation and renewal accreditation applications received b y EPA, it appears that most training providers file one of these applications each ye ar. 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 appl y for multiple accreditations, it appears that rather than renewing all accreditations once every four ye ars, training provi ders stagger their renewal accreditation applications, renewing accreditation for a few courses each ye ar. Based on the average number of applications received between 2007 and 2009, it was estimated that about 150 training providers file an initial accre ditation 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 ac creditation 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 infrequentl y. Since 54 percent of LBP training provider accreditation applications are initial applications, this implies a turnover rate of about 14% per ye ar (14%=54% divided by 4 ye ars). 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 ye ars for RRP training providers.

3 The FLPP databas e 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 ty pes 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 provid ers 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 fo r 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 FL PP 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 appl yi ng 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 I CR renewals, and the numbers of notifications are estimated based on the number of notificat ions 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 Provi der 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 appr oved 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 ave rage 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 appl yi ng 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 completi ng 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 I CR 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 ty pes of training providers. The estimated numbers of notifications per prov ider 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 Ac tivity 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 C ontrol 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 -Notifi cation 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: Numb er 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, respectivel y, to EPA. Since renewal certification is required every three years, it was estimated that one third of firms will seek certification in each ye ar. As described above, the number o f 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 2 nd ye ar 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 Renovati on, 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
- Occ upied Facilities . These economic anal ys es estimated a turnover rate of about 18 percent per ye ar, 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 re ceive 56,301 private firm and 1,389 government firm initial certification applications each ye ar over the next threeye ars. 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 Firm s Initial Certification 4,435 Renewal Certification 4,653 2nd year cohort b 4,544 Total 13,632 RRP Private F irm s 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 L BP 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 appl yi ng 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 I CR 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 EP A 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 Burde n

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 notific ations 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 approv ed ICR (EPA ICR No. 1715.09). The num ber 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 privatel y 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 i nitial 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 th e 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 Renovati on, 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 Profess io nal Hours a Number

of Firm s 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 COF b 0.05 37,534 1 1,877 Contractor, owner - occ. COF b 0.05 265,867 1 13,293 Contractor, renter - occ. COF b 0.05 12,511 1 626 Recordkeeping 4.80 312,785 1 1,501,368 Total 2,621,294 a The estimates of the number s 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 Analys is 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 Ele ment Profess ional Hours a Number

of Firm s a Number of

Events Per Firm a Total Burden

Hours Initial Certification 3.50 1,389 1 4,862 Checklist Provision Owner - performed COF b 0.05 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 Facili ties. 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 I CR 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 b y EPA between 2007 and 2009. As described above, the number ofindividuals in EPA administered areas is divided by 17 percent to extrapolate to national estimates. Exhibit 6. 8 : LBP Individual Certification Burden Hours

Burden Ele ment 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 Renew al 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 fro m sources either identical to or very similar to those used in previous ICR renewals and related economic analy ses. 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 I CR, whereas earlier related economic anal ys es utilized occupation
- specific loading rates in some cases. Non - governmental wages are drawn from the 2009 full
- time mean hourl y 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 I CR renewals, and therefo re 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 (200 9$) 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 Abat ement 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, respectivel y. The estimates of the material costs per response are based on the assumptions from I CR renewals, updated to 2009 d ollars. 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 photocop y, $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 Event s

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 $390,89 9 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 To tal 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 sour ces.

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 accreditatio n 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 $350,1 12 $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 Recor dkeeping $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, respectiv ely, 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 fir ms, and government RRP firms, respectivel y. 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 , Ex hibit 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 Firm s 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 notificatio ns 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 Recordkeepi ng $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 W age 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 evaluat ion 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 Firm s Events

per Firm Material Cost

Per Event Total

Mater ial 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 Firm s Events

per Firm Material

Cost P er 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 - - $1,774,52 3 $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 $47.90 (Renovator) are applie d to the professional hour burdens presented in Exhibit 6. 7 . See Exhibit 6. 9 for a summary of wage rate definitions and sources. Individual Certification, Reporting and Recordkeeping Costs Exhibit 6. 15 presents the costs associated with this information collection for individuals performing LBP activities. These costs are calculated using the burden estimates presented in Exhibit 6. 8 and the wage rates presented in Exhibit 6. 9 . Exhibit 6. 15 : Individual Costs (2009$) 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 Certificat ion 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 Proje ct 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 s tate and f ederal government employees are taken from the f ederal g overnment’s GS Salary

Table for hourly

wages, e ffective 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 : Gover nment 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 M anagerial GS 13, step 1 $38.53 $61.65 Headquarters Professional GS 11, step 1; DC area $29.22 $46.75 Authorized Program Costs This I CR renewal includes an estimate for the entities authorized to administer the LBP and RRP programs. As discussed in s ection 6(a) of this I CR, 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 s ection 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/outrea ch  Reporting (to overseeing agencies)  Other management Exhibit 6. 17 presents the labor hours incurred b y s tates, tribes, and other government entities authorized to administer LBP activity programs. The estimat ed hours per activity incurred b y 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 eac h respondent type. Following the previously approved ICR, 83 percent of LBP activity events nationwide are estimated to occur in areas administered b y authorized programs. EPA expects there will be 20 states total in the next 3 ye ars with the authorizatio n 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 r enewal training provider accreditation applications on average for authorized programs: 15=(83%*765)/44+(40%*69)/44.Exhibit 6. 17 : Authorized Program Labor Hours Auth orized Programs a Number

Events Per Program b Labor Hours Per - Event c Total Labor Hours Prof. Cler. M gmt . 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 Renew al 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 Admin istrative 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 s ection 402. About half of the states authorized to admini ster 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 I CR 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 Sec tion 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 I CR renewal includes a cost estimate for the administration of the LBP and RRP programs b y authorized programs. As discussed i n section 6(a) of this ICR, 39 s tates 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 s ection 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 I CR renewal includes a cost estimate for the administration of the LBP and RRP programs b y 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 b y appl yi ng 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, respectivel y (See Exhibit 6. 9 for a summary of wage rate definiti ons and sources). The numbers of events are estimated for each respondent ty pe, and following the previously

approved IC R (EPA I CR No. 1715.09), 17 percent of LBP activity events nationwide are estimated to occur in areas administered b y EP A. Since about 20 states are projected to obtain authorization to administer the RRP program over the next few ye ars, it is estimated that 60 percent of RRP activity events nationwide will occur in areas administered by EPA Regions during the three ye ar period covered b y 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. EP A 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 1,2 54 $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.ap proved 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 burde n, 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 I CR renewals and related economic analy ses. The average annual paperwork burden is estimated be 3,312,524 hours. The total annual respondent cost for the col lection 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 Respon dent 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 $989,058Exhibit 6. 21 : Total Respondent Burden and Cost for Private Firms

Respondent Type Number

of Sm all Respon dents Number of Respondents Responses

Per Respondent Numbe r 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 1.3 0 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 re
notifications 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 Pr ovider 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 Re
notifications 2,589 2,616 1 2,616 0.01 26.16 $681.47 RRP Fi rm 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 LineReporting 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 a nd Cost for Government Firms Respondent Type Number

of Sm all Respon dents 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 In
house/Landlord 7,639 7,718 8 61,744 0.05 3,087.20 $154,051.28 Overall Go vernment 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 Sm all Respon dents 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 $91 7,105 EPA HQ $849,950 Total EPA $3,432,7246(e) Reasons For Changes in Burden

This information collection combines the burdens from three previously approved ICRs, EPA I CR No. 1715.09, EPA I CR No. 1 715.10, and EPA I CR No. 1715.12. The total co mbined burden from these three previously approved IC Rs was 3,804,495 hours. The total burden requested for this I CR is 3,312,524 hours. Note that the pre
- renovation education burden for Child Occupied Facilities is no longer accounted for in this I CR, but was included in EPA I CR No. 1715.10. This pre
- renovation education burden has been moved from this I CR to the renewal request for the pre
- renovation education ICR, EPA I CR No. 1669. The difference between the current burden request and the previously ap proved 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 I CRs (e.g., include envelope costs for all notifications, where not all previously

approved IC Rs included envelope costs); and  Burden hours and costs to authorized programs are accounted for as Agency burden rather than respondent burden for this I CR. The total combined cost burden from th ese three previously approved IC Rs was $127,139,355. The total cost burden requested for this I CR will be $155,901,692. The difference between the current cost burden request and the previousl y approved requests are due only to adjustments in EPA’s estim ates 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 certi fication in the current I CR. This higher estimate is due to an increase in the number of individual applications received b y 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 b y 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 appl yi ng 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 durin g 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 I CR estimates an increase in the estimated number of accredited RRP training providers. The overall burden for LBP firms is lower for this I CR 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 s ubstantially fewer notifications per firm between 2007 and 2009 than was estimated for the previous information collection request. Specificall y, the average firm during 2007
- 2009 performed one abatement instead of the 14 abatements estimated in the previo usl y approved ICR.  The overall burden for private and government RRP firms is lower for this I CR primaril y 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 slightl y smaller for this reporting period following the related economic analy ses, 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 Inf ormation 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 Individua ls 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 Firm s - 32 - 1.09 - 8,634 Authorized Programs
- 44 - 1877.59 - 82,614 Total 23,495 - 2.05 - 497,2296(f) Burden Statement

The annual public burden for this collection of information, which is approved under OMB Control No. 2070
- 0155, is estimated to averag e 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; devel op, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any pr eviousl y 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 Feder al 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 I CR under Docket ID No. EPA
- HQ OPPT - 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 holiday s. 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 b y 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. 2 0460, and (2) OMB b y 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.