February 2016

Page 1 of 22 

### 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: Final Rule: Lead

- based Paint Programs; Amendment to Jurisdiction

- Specific Certification and Accreditation Requirements and Renovator Refresher Training Requirements [RIN 2070

- AK02]

EPA ICR No : 2502.0 2 OMB Control No: 2070

- 0192

1(b) Short Characterizatio n

This informa tion collection request ( ICR ) addendum revises an existing, approved ICR (EPA

ICR No. 2507.01 , OMB Control No. 2070

- 01 95 ) which covers the reporting and recordkeeping requirements for individuals or firms conducting lead

- based paint activities or renovation in or on houses, apartments, or child

- occupied facilities built before 1978, under the authority of sections 402 and 404 of the Toxic Substances Control Act (TSCA) (15 U. S. C. 2682, 2684; see Attachment 1 ). This

addendum incorporate s reporting and recordkeeping requirements from a final rule amendment that

eliminate s the hands

- on requirement from the renovator refresher training course. EPA expects training providers that are currently accredited to teach the renovator refresher training to app ly for accreditation

to teach the course via e

- learning ( i.e. , via the internet)

. The Agency is also eliminating jurisdictions requirements under the LBP Activities program , which had require d that training providers, firms and

individuals seek certificati on in each jurisdiction (e.g., a State) where the organization or person wants

to work. Only changes that would result from the rule are included in this addendum. Burden and

activities in the existing ICR that are not affected by the final rule are not i ncluded in this document.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

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, and to require reporting and/or recordkeeping from firms engaged in lead

based paint activities or renovations in target housing and child

- occupied facilities; individuals who perform lead

- based paint activities in target housing and child

- occupied facilities; training providers; and states/territories/tribes/Alaskan native villages. The need/authority is unchanged from that discussed in greater detail in the existing approved ICR.February 2016

Page 2 of 22 

### 2(b) Practic al Utility/Users of the Data

This collection will enable EPA/states to determine compliance with and enforce the requirements for training, certification, accreditation, and work practice standards for renovations and

lead

- based paint activities establish ed pursuant to the statutory mandate. The re

- certification and

re

- accreditation requirements for individuals and training programs are meant to ensure that training programs incorporate new developments and technologies in their courses and provide trainin g to individuals. The Agency believes this will ensure that individuals and firms conduct renovations and

lead

- based paint activities in the safest and most effective manner possible. The practical utility and

users of the data are unchanged from what is discussed in greater detail in the existing approved ICR.

3. NON

- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non

- Duplication

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

collection. There is no other model program for lead

- based paint activities or renovations and there are currently no other federal requirements for the training and certification of individuals engaged in these activities, or lead hazard information distribution requirements for renovations in child

- occupied facilities that involve information collection activities that duplicate those discussed in this ICR addendum. This is unchanged from that discussed in greater detail in the existing approved ICR.

3(b) Public Notice Required P rior to ICR Submission to OMB

The notice of proposed rulemaking (80 FR 1873, January 14, 2015) (FRL

- 9920

- 85) serves as the public notice for this ICR addendum. Interested parties submit ted comments and r esponses were taken into account in developing the final rulemaking.

3(c) Consultations and Public Comments

EPA discussed the proposed amendments and solicited comments on the proposed amendments in the proposed rule. See the proposed rule for further discussion. In addition, in the proposed rule EP A

solicited comment s on the Agency ’ s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden

. Comments received on the ICR are summarized, along with EPA responses, in the Response to Comment document that is

available in the docket for the final rule.

3(d) Effects of Less Frequent Collection

Under the existing regulations, t raining providers must submit p re

- training notifications at least 7 business days pri or to the start of the cour se and must submit p ost

- training notifications no later than 10 business days following course completion. Under the amended regulations, classes that do not have a

hands

- on component do not require pre

- training notification, and post

- training notification s can be submitted once per month. These were determined to be the lowest frequencies possible for achieving statutory and regulatory objectives.February 2016

Page 3 of 22 

### 3(e) General Guidelines

The collection activities are consistent with OMB’s general guidelines. No changes have b een made to the records retention periods discussed in the currently approved ICR ( EPA ICR No. 2507.01,

OMB Control No. 2070

- 01 95 ).

3(f) Confidentiality

The information collection activities in the rule do not include questions of a confidential nature.

3(g) Sen sitive Questions

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

4. THE RESPONDENTS AND INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

The respondents are not changing with the rule amendments. The North American Industrial Classification System (NAICS) codes associated with industries potentially affected by the changes to existing paperwork requirements are described below:

• Buildin g construction (NAICS code 236), e.g., single

- family housing construction, multi

family housing construction, residential remodelers.

• Specialty trade contractors (NAICS code 238), e.g., plumbing, heating, and air

- conditioning contractors, painting and wall covering contractors, electrical contractors, finish carpentry contractors, drywall and insulation contractors, siding contractors, tile and terrazzo contractors, glass and glazing

contractors.

• Real estate (NAICS code 531), e.g., lessors of reside ntial buildings and dwellings, residential

property managers.

• Child day care services (NAICS code 624410).

• Elementary and secondary schools (NAICS code 611110), e.g., elementary schools with kindergarten classrooms.

• Other technical and trade sc hools (NAICS code 611519), e.g., training providers.

• Engineering services (NAICS code 541330) and building inspection services (NAICS code 541350), e.g., dust sampling technicians.

• Lead abatement professionals (NAICS code 562910), e.g., firms and s upervisors engaged in

lead

- based paint activities.February 2016

Page 4 of 2 2 

### 4(b) Information Requested

The rule this addendum addresses would modify the hands

- on requirement from the renova tor refresher training course. EPA expects training providers that are currently accredited to teach the renovator refresher training to develop or license updated courses without the hands

- on component, and apply for accreditation to teach the course via e

- learning ( i.e. , via the inter net)

. This change would result in a reduction in travel time and expenses for renovators that need refresher training to be re

- certified

. Eliminating the multi

- jurisdiction registration fee of $35 results in savings for renovators certified in multiple EPA

- administered states. However, EPA does not anticipate a meaningful change in paperwork burden from the removal of jurisdictions because under the existing regulations, multiple

EPA

- administered jurisdictions can be listed on the same form.

(i) Data Items

T o receive accreditation to provide lead

- based paint activities or renovation training, tra ining providers must submit documents to EPA/ s tate, using the form entitled “Application and Instructions for Training Providers” (see Attachment 3) o r a similar form containing the required information

. Under the

rule amendment that this ICR addendum addresses, EPA expects training providers accredited for the renovator refresher course to apply for accreditation to teach the e

- learning version of the course.

Accredi ted training providers are eligible for an expedited e

- learning course accreditation if they want to teach an already reviewed and accepted e

- learning course. Currently

- accredited training providers seeking accreditation for the e

- learning refresher course must submit the following information to EPA

.

• A cover letter

• A training provider application to amend their accreditation;

• A n e

- learning quality control (QC) plan.

(ii) Respondent Activities

Renovator Refresher Training Course Amendment

Training provid ers will need to apply for accreditation to teach the refresher course without the

hands

- on component, e.g., an e

- learning version of the refresher course, as discussed above in part 4(b) (i) of this supporting statement. In addition to submitting to EPA the information discussed in part 4(b) (i) of this supporting statement, training providers will also have to familiarize themselves with the requirements in the rule that this addendum addresses. The rule will also require training p roviders to include the expiration date of the renovator’s certification in the post

- training notification, but the time

re quired to do this is negligible since this is a new data element

.

Renovators taking the 4

- hour refresher training course will no lo nger be required to perform

hands

- on activities every time they are trained . Renovators will be able to take the refresher course

without the hands

- on component online every other certification , thereby reducing travel time and

expenses

.February 2016

Page 5 of 22 

### Abatement Multi

- jurisdiction Registration Fee Amendment

The elimination of the multi

- state jurisdiction fee of $35 will reduce compliance costs for individuals, firms, and training providers certified in multiple EPA

- administered states. While this is a

reduction i n overall costs, the multi

- jurisdiction registration fee is a regulatory burden, and not a PRA paperwork burden as defined in 5 C.F.R. 1320.3(b), and is therefore not currently accounted for in an existing ICR. Regarding the paperwork burden associated wi th multi

- jurisdiction certification, EPA does not anticipate a meaningful change in paperwork burden from the removal of jurisdictions because under the existing regulations, multiple EPA

- administered jurisdictions can be listed on the same form.

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION

MANAGEMENT

5(a) Agency Activities

To implement the rule amendments, EPA will need to review the e

- learning applications submitted by training providers to attain accreditation.

5(b) Collection Methodology and M anagement

This section includes the data elements for training providers that are expected to be impacted by

the rule amendment

. Under the amended rule, EPA expects training providers accredited for the renovator refresher course to apply for accreditation to teach the e

- learning version of the course. Accredited training providers are eligible for an expedited e

- learning course accreditation if the y want to teach an already reviewed and accepted e

- learning course.

Training providers that intend to offer the online renovator refresher training course must submit

to EPA the following information to seek accreditation for the e

- learning refresher cour se:

• A cover letter

• A training provider application to amend their accreditation (see Attachment 3 ) ;

• A n e

- learning quality control (QC) plan.

For renovators, neither the renovator refresher training course amendment nor the abatement

multi

- jurisdiction registration fee amendment will require the use of any new collection instruments or

methods.

5(c) Small Entity Flexibility

The rule amendments are designed to ensure that regulatory requirements do not unduly burden

small businesses. The rule eliminates multi

- jurisdiction registration fees and revises the hands

- on training requirement for the lead renovation refresher training courses, resulting in c ost savings for entities that no longer will pay the multi

- jurisdiction registration fees and renovators that will have a less expensive refresher training option available to them. Training providers incur costs associated with accrediting e

- learning cour ses. However, it is expected that only training providers that anticipate recovering accreditation costs through tuition charges would opt to apply for the additional accreditationFebruary 2016

Page 6 of 22 

### because there is no requirement mandating training providers offer an e

- lea rning refresher training option. Therefore, there are no direct negative net cost impacts on small entities.

5(d) Collection Schedule

R enovators will need to complete a renovator refresher course every 3 or 5 years , depending on whether or not their pre vious course had a hands

- on component . T he abatement multi

- jurisdiction registration fee a mendment will not affect the collection schedule for individual and firm certifications

and re

- certifications.

6. ESTIMATING THE BURDEN AND COST

This section estimates the incremental reporting burden for training providers and renovators that may result from the revisions to EPA’s renovation, repair, and painting (RRP) program requirement s. This burden is incremental to the burden for EPA’s lead p aint program that has already been accounted for in an existing, approved ICR ( EPA ICR No. 2507.01, OMB Control No. 2070

- 01 95 ). This supporting statement provides burden and cost estimates for three years of the program. All costs are presented in year 2014 dollars.

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

Section 6(c) estimates EPA costs, section 6(d) summarizes the bottom line burden and costs, section 6(e) describes the reasons for changes in burden from the previous ICR, and section 6(f) presents the burden

statement.

The majo rity of RRP training providers are predicted to attain accreditation for an online refresher training course as a result of the rule. Accredited training providers may add an already

- reviewed online course curriculum through an expedited course approval pr ocess. Impacts are estimated for training providers currently offering an accredited refresher training course that are

assumed to seek accreditation for an online course.

As discussed in part 4(b) (ii) of this supporting statement, renovators taking the 4

- hour refresher training course are no longer required to perform hands

- on activities every time they are trained, and thereby save money (e.g., for travel, poten tial reduced tuition, etc.), particularly if they take the class

online.

With respect to the abatement multi

- jurisdiction registration fee amendment, EPA does not anticipate a meaningful change in paperwork burden from the removal of jurisdictions because under the existing regulations, multiple EPA

- administered jurisdictions can be listed on the same form.

6(a) Estimating Respondent Burden

RRP Training Providers

Training providers currently accredited for the renovator refresher training course are expected to apply for an additional accreditation for an online refresher training course as result of the rule. Therefore they would incur an incremental paperwork bu rden associated with becoming familiar with the rule’s requirements and with applying for accreditation to teach an online version of the renovatorFebruary 2016

Page 7 of 22 

### refresher training. All requests to add an already

- reviewed online course curriculum to an already

- accredite d training provider’s record must include a cover letter; a training provider application to amend their accreditation; and an online course quality control (QC) plan. The online course QC plan

must address issues such as how the trainer will ensure that students successfully complete the online course modules and the online course module final assessment. Recordkeeping burdens and reporting burdens associated with notification are not incorporated into the incremental burden because they are

incurred with or without this rule amendment, and are accounted for under the existing a pproved ICR ( EPA ICR No. 2507.01, OMB Control No. 2070

- 01 95 ).

Four hundred training providers are predicted to be accredited for an online refresher training

course based on data from the Federal Lead

- based Paint Program (FLPP) database (see Exhibit 6.1 ). While new training providers that are not currently accredited may apply for accreditation of an e

learning course, EPA expects that the number of new entrants will be offset by the number of currently accredited providers that choose not to become accredited for an e

- learning course.

Exhibit 6

. 1 Number of RR P Training Providers

Entity Type Number of Entities Accredited in Year 1
RPP Training Provider 400



### Exhibit 6.2 presents the number of burden hours per activity and Exhibit 6.3 presents total and

av erage burden hours per year for training providers

. 1 

### Unit burden h our estimates are assumed to be half of the burden hour estimates from the previously a pproved ICR ( EPA ICR No. 2507.01, OMB Control

No. 2070

- 01 95 ) because less information needs to be provi ded, given that the training provider has already been accredited for an in

- person course. As presented in Exhibit 6.3 , the burden for all training providers is estimated to be 6,366 hours in Year 1, and 801 hours in Year 2 and Year 3. The average annual aggregate burden for training providers over the three years covered by this ICR is 2,656 hours.

1 These estimates are based on Scenario I (assuming 50% of the active stock of renovators chooses online refresher training), which yields a conservative estimate of reporting and recordkeeping burden.February 2016

Page 8 of 22 Exhibit 6

. 2 RRP Training Providers: E

- learning Course Accreditation, CDX, and Notification Burden per Activity

Activity Number of Respondents Number of Activities per Training Provider Reporting Hours per Activity

Year 1 Year 2 Year 3 Professional Clerical Total

Accreditation 1,2

Rule Familiarization 400 1.00 0.00 0.00 4.00 0.00 4.00

Accreditation Statement 400 1.00 0.00 0.00 3.80 1.00 4.80

Quality Control Plan 400 1.00 0.00 0.00 4.00 1.00 5.00

CDX Electronic Reporting

CDX Registration 34 1.00 0.10 0.10 0.84 0.00 0.84

Electronic Subscriber Agreements 34 1.00 0.10 0.10 0.25 0.00 0.25
Help Desk 34 1.00 0.10 0.10 0.34 0.00 0.34

Problem Resolution 34 0.03 0.00 0.00 1.00 0.00 1.00

Report Compromised Signature 34 0.00 0.01 0.01 0.40 0.00 0.40

Notification

Pre

- training Notification 400

- 7.40

- 7.40

- 7.40 0.00 0.20 0.20

Pre

- training Renotification 400

- 2.81

- 2.81

- 2.81 0.00 0.20 0.20

Post

- training Notification and Digital Photo 400 6.72 6.72 6.72 0.00 0.60 0.60

1 Number of activities are from the previou sly approved EPA ICR No. 2507.01

.

2 Burden hour per activity are assumed to be half the vales in the previou sly approved EPA ICR No. 2507.01 . The hour estimates were rounded to one decimal place for this ICR.

Exhibit 6

. 3 RRP Training Providers: E

- learning Course Accreditation, CDX, and Notification Total Burden

Activity Number of Respondents Burden per Respondent Total Burden

Year 1 Year 2 Year 3 Year 1 Year 2 Year 3 Average

Accreditation

Rule Familiarization 400 4.000 0.000 0.000 1,600.00 0.00 0.00 533.33

Accreditation Statement 400 4.800 0.000 0.000 1,920.00 0.00 0.00 640.00
Quality Control Plan 400 5.000 0.000 0.000 2,000.00 0.00 0.00 666.67

CDX Electronic Reporting

CDX Registration 34 0.840 0.084 0.084 28.56 2.86 2.86 11.43

Electronic Subscriber Agreements 34 0.250 0.025 0.025 8.50 0.85 0.85 3.40

Help Desk 34 0.340 0.034 0.034 11.56 1.16 1.16 4.63

Problem Resolution 34 0.030 0.000 0.000 1.02 0.00 0.00 0.34

Report Compromised Signature 34 0.000 0.004 0.004 0.00 0.14 0.14 0.09

Notification

Pre

- training Notification 400

- 1.480

- 1.480

- 1.480

- 592.00

- 592.00

- 592.00

- 592.00

Pre

- training Renotification 400

- 0.562

- 0.562

- 0.562

- 224.80

- 224.80

- 224.80

- 224.80

Post

- training Notification and Digital Photo 400 4.032 4.032 4.032 1,612.80 1,612.80 1,612.80 1,612.80

Total Burden 6,365.64 801.01 801.01 2,655.89February 2016

Page 9 of 22 

### Renovators

As a result of the rule, many r enovators are expected to take the r efresher training course without

the hands

- on component entirely online via an e

- learning course

. R enovators taking the refresher training course without the hands

- on component online w ill avoid the time and associated expenses

needed to travel to and from a training facility.

An average of 9,859 additional renovators are predicted to be re

- cert ified per year by taking the refresher training course (see Exhibit 6.4 ) . As a result of renovators taking the refresher training course entirely online via an e

- learning course, the number of renovators traveling to and from a training facility to take the refresher training course with the hands

- on component is predicted to decline by
14,789 (see Exhibit 6.4 )

. Predictions of the number of renovators being re

- cert ified each year are based

on data from the FLPP database

.

Exhibit 6.4 presents burden hours p er activity and Exhibit 6.5 presents respondent burden hours per activity and total burden hours per year. 2 

### The duration of refresher training course i s 4 hours and the duration of a roundtrip to the training facility is 1.8 hours. As presented in Exhibit 6.5 , the annual

incremental burden for all re novators covered by this ICR is estimated to be 12,816 hours.

Exhibit 6

. 4 Renovator: Re

- cert ification Burden per Activity

Activity Number of Respondents Number of Activities per

Renovator Reporting

Hours per

Activity

Re

- cert ification
Refresher Training Course 9,859 1.00 4.00

Travel

- 14,789 1.00 1.80

Exhibit 6

. 5 Renovator: Re

- cert ification Total Burden

Activity Number of Respondents Burden per Respondent Total Burden

Re

- cert ification

Refresher Training Course 9,859 4.00 39,436.00

Travel 14,789

- 1.80

- 26,620.20

Total Burden 12,815.80

2 These estimates are based on Scenario I (assuming 50% of the active stock of renovators chooses online refresher training)

.February 2016

Page 10 of 22 

### 6(b) Estimating Respondent Costs

RRP Training Providers

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

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

either identical to or very similar to those used in previous ICR renewals and related economic analyses.

Exhibit 6.6 presents loaded wage rates for training provider professional and clerical staff, which are $53.66 and $26.79, respectively. Wage and fringe benefit data are taken from the Employer Cost for Employee Compensation data series published by the Bureau of Labor Statistics (BLS)

. 3 

### Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPI for All Urban

Consumers published by the BLS

. 4 

### The overhead estimate is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Progra m

. 5 

### The overhead loading factor is added to the benefits loading factor, and the total is then applied to the base wage rate to derive the fully loaded wage

rate (see Exhibit 6.6 ).

Exhibit 6

. 6 Private Sector Wage Rates for Calculating RRP Training Provider Labor Costs (2014$)

Labor Category BLS Occupation Category 1 Date Wage 1 Fringe

Benefit Fringe (% of Wage) 1 Overhead (% of Wage) 2 Wage Multiplier Loaded Wages 3

(a) (b) (c)
=(b)/(a) (d) (e)
=1+(c)+(d) (f)
=(a)*(e)

Professional Professional

and related 9/12 $33.96 $13.92 41% 17% 1.58 $53.66

Clerical Office and

administrative

support 9/12 $16.64 $7.32 44% 17% 1.61 $26.79

1 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013." Private industry workers, goods

- producing and service

- producing.

2 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. Environmental Protection Agency, Office of Environmental Information, Environmental Analysis Division, Analytical Support Branch.

3 Wage rates are rounded to the closest penny.



### Exhibit 6.7 estimates the cost per activity associated with this information collection for training providers offering renovator courses. As shown in Exhibit 6.8 , total training provider costs are estimated to be $298,677 in Year 1 of the rule, and $21,574 in Year 2 and Year 3 of the rule. The average annual cost over the three year s covered by this ICR is $113,942.

3 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013."
Retrieved Jan. 30, 2014

.

4 Bureau of Labor Statistics (BLS). (2014). "Co nsumer Price Index

- All Urban Consumers, U.S. City Average (2004 to 2014)." CUSR0000SA0

. Retrieved Mar. 21, 2014.

5 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. Environmental Protection Agency, Office of Environmental Information, Environmental Analysis Divis ion, Analytical Support Branch.February 2016

Page 11 of 22 Exhibit 6

. 7 RRP Training Providers: E

- learning Course Accreditation, CDX, and Notification Cost Estimates per Activity (2014$)

Activity Reporting Hours per Activity Reporting Costs per Activity

Professional Clerical Professional Clerical Total

Accreditation 1

Rule Familiarization 4.00 0.00 $214.64 $0.00 $214.64

Accreditation Statement 3.80 1.00 $203.91 $26.79 $230.70

Quality Control Plan 4.00 1.00 $214.64 $26.79 $241.43

CDX Electronic Reporting

CDX Registration 0.84 0.00 $45.07 $0.00 $45.07

Electronic Subscriber Agreements 0.25 0.00 $13.42 $0.00 $13.42

Help Desk 0.34 0.00 $18.24 $0.00 $18.24

Problem Resolution 1.00 0.00 $53.66 $0.00 $53.66

Report Compromised Signature 0.40 0.00 $21.46 $0.00 $21.46

Notifications

Pre

- training Notification 0.00 0.20 $0.00 $5.36 $5.36

Pre

- training Renotification 0.00 0.20 $0.00 $5.36 $5.36

Post

- training Notification and Digital

Photo 0.00 0.60 $0.00 $16.07 $16.07

1 Hour estimates are derived from the previou sly approved EPA ICR No. 1715.14 . The hour estimates were rounded to one decimal place

for this ICR.February 2016

Page 12 of 22 Exhibit 6

. 8 RRP Training Providers: Total E

- learning Course Accreditation, CDX, and Notification Cost Estimates (2014$)

Activity Total Costs

Year 1 Year 2 Year 3 Average

Accreditation

Rule Familiarization $85,856.00 $0.00 $0.00 $28,618.67

Accreditation Statement $92,280.00 $0.00 $0.00 $30,760.00

Quality Control Plan $96,572.00 $0.00 $0.00 $32,190.67

CDX Electronic Reporting

CDX Registration $1,532.38 $153.24 $153.24 $612.95

Electronic Subscriber Agreements $456.28 $45.63 $45.63 $182.51

Help Desk $620.16 $62.02 $62.02 $248.07

Problem Resolution $54.73 $0.00 $0.00 $18.24

Report Compromised Signature $0.00 $7.30 $7.30 $4.87

Notifications

Pre

- training Notification

- $15,865.60

- $15,865.60

- $15,865.60

- $15,865.60

Pre

- training Renotification

- $6,024.64

- $6,024.64

- $6,024.64

- $6,024.64

Post

- training Notification and Digital Photo $43,196.16 $43,196.16 $43,196.16 $43,196.16

Total Costs $298,677.47 $21,574.11 $21,574.11 $113,941.90



### Renovators

The cost estimates addressed in this section are based on the burden estimates discussed in Section 6(a)

. The renovator w age rate is derived with methods and from sources either identical to or v ery similar to those used in previous ICR renewals and related economic analyses. Exhibit 6.9 presents the loaded wage rate for a renovator , which is $ 47 .6 1 . Wage data are taken from Occupational Employment and Wages data series published by Bureau of Labor Statistics (BLS)

. 6 

### Fr inge benefit data are taken from

the Employer Cost for Employee Compensation data series published by the BLS

. 7 

### The wage rate is inflated to 2014 dollars by applying the CPI for All Urban Consumers published by the BLS

. 8 

### The

overhead estimate is taken from Cost of Doing Business Study, 2012 Edition

. 9 

### The overhead loading factor is added to the benefits loading factor, and t he total is then applied to the base wage rate to derive the fully loaded wage rate ( see Exhibit 6.9 ).

6 Bureau of Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics

- Occupational Employment and Wages, May 2012, 47

- 1011 First

- Line Superv isors of Construction Trades and Extraction Workers." Retrieved Jan. 30,

2014

.

7 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013."

Civilian workers. Retrieved Jan. 30, 2014

.

8 Bureau of Labor St atistics (BLS). (2014). "Consumer Price Index

- All Urban Consumers, U.S. City Average (2004 to 2014)." CUSR0000SA0

. Retrieved Mar. 21, 2014.

9 NAHB Business Management & Information Technology (2012). Cost of Doing Business Study, 2012 Edition, NAHB

Buil derBooks.com®.February 2016

Page 13 of 22 Exhibit 6

. 9 Private Sector Wage Rates for Calculating Renovator Labor Costs (2014$)

Labor Category BLS Occupation Category 1 Date Wage 1 Fringe

Benefit Fringe (% of Wage) 2 Overhead (% of Wage) 3 Wage Multiplier Loaded Wages 4

(a) (b) (c)
=(b)/(a) (d) (e)
=1+(c)+(d) (f)
=(a)*(e)

Professional First

- Line Supervisors 3/12 $31.1

2 $13.92 45% 8.3% 1.53 $47.61

1 Bureau of Labor Statistics (BLS). (2012, Mar. 29, 2013). "Occupational Employment Statistics

- Occupational Employment and Wages, May 2012, 47

- 1011 First

- Line Supervisors of Construction Trades and Extraction Workers."

2 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Compensation

- September 2013." Civilian workers

.
3 NAHB Business Management & Information Technology (2012). Cost of Doing Business Study, 2012 Edition, NAHB

BuilderBooks.com®.

4 Wage rates are rounded to the closest penny.



### Exhibit 6.10 estimates the cost per activity associated with this information collection for renovators being re

- cert ified. As show n in Exhibit 6.11 , annual renovator costs covered by this ICR are $610,131.

Exhibit 6

. 10 Renovators: Re

- cert ification Cost Estimates per Activity (2014$)

Activity Reporting Hours per Activity Reporting Costs per Activity

Professional Clerical Professional Clerical Total

Re

- cert ification
Refresher Training Course 4.00 0.00 $190.44 $0.00 $190.44

Travel 1.80 0.00 $85.70 $0.00 $85.70

Exhibit 6

. 11 Renovators: Total Re

- cert ification Cost Estimates

Activity Total Costs per Year

Re

- cert ification

Refresher Training Course $1,877,547.96

Travel

- $1,267,417.30

Total Costs $610,130.66



### 6(c) Estimating Agency Cost

There are also government costs associated with reviewing the expedited online course applications. EPA estimates that it will take 4 hours apiece for an Agency employee to review the 400 training provider online course program accreditation applications. The base wage rate of the federal government employee reviewing applications is taken from the 2014 General Schedule (GS) Locality Pay Table for Washington

- Baltimore

- Northern Virginia, published by the Office of Personnel Manag ement. A loaded wage rate of $78.13 is then derived by applying a multiplier of 1.6 to account for fringe benefits and overhead to the base wage rate of a GS

- 13 Step 5 government employee ($48.83)

. 10

10 The 1.6 fringe benefits and overhead multiplier is taken from the ICR Handbook

- EPA’s Guide to Writing Information Collection Requests , published in 2009.February 2016

Page 14 of 22 

### Exhibit 6.12 presents the costs to EPA for Years 1, 2, and 3, as well as the average annual costs. The costs are calculated by applying the government employee wage rate to the 4 hours of time for each

o f the 400 accreditation applications.

Exhibit 6

. 12 EPA Costs (2014$)

Year 1 Year 2 Year 3 Avg.

$125,008 $0 $0 $41,669February 2016

Page 15 of 22 

### 6(d) Bottom Line Burden Hours and Cost s

Exhibit 6.13 presents a summary of average ann ual respondent burden and costs . The combined

annual burden for RRP training providers and renovators is estimated to be 15,472 hours. The av erage annual respondent cost is estimated to be $ 724,073 . The Agency cost is estimated to average $41,669 per year, as shown in Exhibit 6.14

.

Exhibit 6

. 13 Annual Respondent Burden and Cost Summary

Activity Number of Respondents Number of

Small Respondents 1 Responses

per Respondent Total Annual

Number of Responses Burden

per Response Total

Annual

Burden Total Annual

Costs

Accreditation

Rule

Familiarization 400 376 0.33 133.33 4.00 533.33 $28,618.67

Accreditation

Statement 400 376 0.33 133.33 4.80 640.00 $30,760.00

Quality Control

Plan 400 376 0.33 133.33 5.00 666.67 $32,190.67

CDX Electronic Reporting

CDX Registration 34 32 0.40 13.60 0.84 11.43 $612.95

Electronic

Subscriber Agreements 34 32 0.40 13.60 0.25 3.40 $182.51

Help Desk 34 32 0.40 13.60 0.34 4.63 $248.07

Problem

Resolution 34 32 0.01 0.34 1.00 0.34 $18.24

Report Compromised Signature 34 32 0.01 0.23 0.39 0.09 $4.87

Notification

Pre

- training

Notification 400 376

- 7.40

- 2,960.00 0.20

- 592.00

- $15,865.60

Pre

- training

Renotification 400 376

- 2.81

- 1,124.00 0.20

- 224.80

- $6,024.64

Post

- training

Notification and Digital Photo 400 376 6.72 2,688.00 0.60 1,612.80 $43,196.16

Total RRP Training Providers 2,655.89 $113,941.90

Renovators

Re

- cert ification

Refresher Training Course 9,859 9,267 1.00 9,859 4.00 39,436 $1,877,547.96

Travel 14,789 13,902 1.00

- 14,789

- 1.80

- 26,620

- $1,267,417.30

Total Renovators 12,815.80 $610,130.66

Total 15,471.69 $724,072.56

1 Consistent with the currently approved ICR (EPA ICR No. 2507.01, OMB Control No: 2070

- 0195), 94% of affected entities are

assumed to be small entities.

* Si nce 8.4% of training providers currently do not submit notifications via CDX, 34 of the 400 respondents are assumed to regist er with CDX for the first time.February 2016

Page 16 of 22 Exhibit 6

. 14 EPA Costs

Year 1 Year 2 Year 3 Avg.

EPA $125,008 $0 $0 $41,669



### The total burden in OMB’s inventory for the existing, approved ICR for the lead paint program ( EPA ICR No. 2507.01, OMB Control No. 2070

- 01 95 ) is 6,463,297 hours. With the addition of the 15,472 program change hours related to the rule amendments (program change), the total burden requested is 6,478,769 hours per year.

6(e) Reasons For Changes in Burden

The burden analyzed in this ICR addendum relates to EPA’s program change to modify the renovator refresher training hands

- on requirement and the renovator refresher training notification requirement. This is expected to result in a number of training providers applying for accreditation to

offer online refresher courses, as well as a change in the number of pre

- training notifications,

pre

- training re

- notifications, and post

- training notifications and will provide renovators needing

re

- certification with the option of taking a refresher course online. Renovators are expected to experience an increase in burden because , on average, they will take the refresher training course more frequently. Renovators are expected to experience a reduction in total costs because they will not be required to tra vel to attend refresher training in

- person every renewal cycle . A discussion of potential renovator savings can be found in Chapter 3 of the Economic Analysis for the Lead

- Based Paint Program Minor Amendments Final Rule, available in the public docket for the rulemaking.

With respect to the Abatement Multi

- jurisdiction Registration Fee Amendment, EPA does not anticipate a meaningful change in paperwork burden from the removal of jurisdictions because under the existing regulations, multiple EPA

- administer ed jurisdictions can be listed on the same form.

EPA estimates that 400 RRP training providers would apply for an accreditation for an online refresher training course as a result of the provision to amend the course’s hands

- on training requirement. Trai ning providers are expected to submit 2,958 fewer pre

- training notifications, 1,124 fewer pre

- training re

- notifications and 2,687 additional post

- training notifications. The addition of these new responses is expected to increase the annual accreditation and notification burden by 2,656 hours.

EPA estimates that the number of renovators taking the refresher training course would increase by 9,859 and that the number of renovators traveling to and from a training facility to take the refresher training cou rse would decline by 14,789 as a result of the provision to amend the refresher training

course’s hands

- on training requirement . The change in re

- cert ification responses is expected to increase

the annual renovator re

- cert ification burden by 15,816 hours.

6(f) Burden Statement

The annual incremental public burden associated with RRP training providers for this collection

of information is estimated to be 13.8, 2.82, and 1.00 hour(s) per response for Accreditation, CDX, and Notification activities, respectively

. The annual incremental public burden associated with renovators

for this collection of information is estimated to be 4.00 and 1.80 per response for the refresher training

course and travel associated with r e

- cert ification, respectively. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations ar e listed in 40 CFR part 9 and included on the related collection instrument or form, if applicable.February 2016

Page 17 of 22 

### The Agency has established a docket for this rulemaking, which includes this rule related ICR,

under Docket ID No. EPA

- HQ

- OPPT

- 2014

- 0304, which is availab le for online viewing at http://www.regulations.gov , or in

- person viewing at the EPA Docket Center (EPA/DC), EPA William

Jefferson Clinton West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566

- 0280.

You may submit additional c omments regarding the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Comments, referencing Docket ID No. EPA

- HQ

- OPPT

- 2014

- 0304 and OMB Control No.

2070

- 0192 (EPA ICR No. 2502.02), may be submitted to EPA electronically through http://www.regulations.gov or to OMB, addressed to “OMB Desk Officer for EPA” and referencing

OMB Control No. 2070

- 0192 (EPA ICR No. 2502.02), via email to oira_submission@omb.eop.gov

.

7. ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement are available in the public docket established for this ICR under

docket identification number EPA

- HQ

- OPPT

- 201 4

- 0304.

Attachment 1: 15 U.S.C. 2682

- Toxic Substances Control Act Sections 402

Attachment 2: Accreditation of training programs: target housing and child

- occupied facilities

40 CFR 745.225

Attachment 3: Application and Instructions for Training Providers

- Applying for

Accreditation of Lead

- Based Paint Activity Training Programs

- EPA Form

8500

- 25.February 2016

Page 18 of 22 

### EPA ICR No. 2502.0 2 ; OMB Control No. 2070

- 0192



### ATTACHMENT 1

Toxic Substances Control Act Sections 402

15 U.S.C. 2682February 2016

Page 19 of 22 

### Sec. 2682. Lead

- based paint activities training and certification

(a) Regulations (1) In general Not later than 18 months after October 28, 1992, the Administrator shall, in consultation wi th the Secretary of Labor, the Secretary of Housing and Urban Development, and the Secretary of Health and Human Services (acting through the Director of the National Institute for Occupational Safety and Health), promulgate final regulations governing lea d

- based paint activities to ensure that individuals engaged in such activities are properly trained; that training programs are accredited; and that contractors engaged in such activities are certified. Such regulations shall contain standards for performi ng lead

based paint activities, taking into account reliability, effectiveness, and safety. Such regulations shall require that all risk assessment, inspection, and abatement activities performed in target housing shall be performed by certified contractor s, as such term is defined in section 4851b of title 42. The provisions of this section shall supersede the provisions set forth under the heading ‘’Lead Abatement Training and Certification’‘ and under the heading ‘’Training Grants’‘ in title III of the A ct entitled ‘’An Act making appropriations for the Departments of Veterans Affairs and Housing and Urban Development, and for sundry independent agencies, commissions, corporations, and offices for the fiscal year ending September 30, 1992, and for other p urposes’‘, Public Law 102

- 139 (105 Stat. 765, 42 U.S.C. 4822 note), and upon October 28, 1992, the provisions set forth in such public law under such headings shall cease to have any

force and effect. (2) Accreditation of training programs Final regulat ions promulgated under paragraph (1) shall contain specific requirements for the

accreditation of lead

- based paint activities training programs for workers, supervisors, inspectors and planners, and other individuals involved in lead

- based paint activities , including, but not limited to, each of the following:

(A) Minimum requirements for the accreditation of training providers. (B) Minimum training curriculum requirements. (C) Minimum training hour requiremen ts. (D) Minimum hands

- on training requirements. (E) Minimum trainee competency and proficiency requirements. (F) Minimum requirements for training program quality control. (3) Accreditation and certification fees The Administrator (or the State in the case of an authorized State program) shall impose a fee on

-

(A) persons operating training programs accredited under this subchapter; and (B) lead

- based paint activities contractors certified in accordance with paragraph (1). The fees shall be established at such level as is necessary to cover the costs of administering and enforcing the standards and regulations under this section which are ap plicable to such programs and contractors. The fee shall not be imposed on any State, local government, or nonprofit training program. The Administrator (or the State in the case of an authorized State program) may waive the fee for lead

based paint activi ties contractors under subparagraph (A) for the purpose of training their own employees.

(b) Lead

- based paint activities For purposes of this subchapter, the term ‘’lead

- based paint activities” means

- (1) in the case of target housing, risk asses s ment, inspection, and abatement; and (2) in the case of any public building constructed before 1978, commercial building, bridge, or other structure or superstructure, identification of lead

- based paint and materials containing lead

- based paint, deleading , removal of lead from bridges, and demolition. For purposes of paragraph (2), the term ‘’deleading’‘ means activities conducted by a person who offers to eliminate lead

- based paint or lead

based paint hazards or to plan such activities.

(c) Renovat ion and remodeling (1) GuidelinesFebruary 2016

Page 20 of 22 

### In order to reduce the risk of exposure to lead in connection with renovation and remodeling of target housing, public buildings constructed before 1978, and commercial buildings, the Administrator shall,

within 18 mont hs after October 28, 1992, promulgate guidelines for the conduct of such renovation and remodeling activities which may create a risk of exposure to dangerous levels of lead. The Administrator shall disseminate such guidelines to persons engaged in such re novation and remodeling through hardware and paint stores, employee organizations, trade groups, State and local agencies, and through other appropriate means. (2) Study of certification The Administrator shall conduct a study of the extent to which pers ons engaged in various types of renovation and remodeling activities in target housing, public buildings constructed before 1978, and commercial buildings are exposed to lead in the conduct of such activities or disturb lead and create a

lead

- based paint h azard on a regular or occasional basis. The Administrator shall complete such study and publish the results thereof within 30 months after October 28, 1992. (3) Certification determination Within 4 years after October 28, 1992, the Administrator shall r evise the regulations under subsection (a) of this section to apply the regulations to renovation or remodeling activities in target housing, public buildings constructed before 1978, and commercial buildings that create lead

- based paint hazards. In

determ ining which contractors are engaged in such activities, the Administrator shall utilize the results of the study under paragraph (2) and consult with the representatives of labor organizations, lead

- based paint activities contractors, persons engaged in re modeling and renovation, experts in lead health effects, and others. If the Administrator determines that any category of contractors engaged in renovation or remodeling does not require certification, the Administrator shall publish an explanation of the basis for

that determination.February 2016

Page 21 of 22 

### EPA ICR No. 2502.02; OMB Control No. 2070

- 0192



### ATTACHMENT 2

Accreditation of training programs: target housing and child

- occupied facilities

40 CFR 745.225



### For an electronic copy of 40 CFR 745.225 , go to http://www.ecfr.gov/cgi

- bin/text

idx?SID=2181334de64d0515a321c606e0ea0b8d&node=40:3 2.0.1.1.14.6.1.3&rgn=div8

.February 2016

Page 22 of 22 

### EPA ICR No. 2502.02; OMB Control No. 2070

- 0192



### ATTACHMENT 3

Application and Instructions for Training Providers

- Applying for Accreditation of Lead

- Based Paint Activity Training Programs

- EPA Form 8500

- 25

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

- 09/documents/trainapp_9_5_13.pdf