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6 Economic Analysis for the Lead-Based Paint Program 

7 Minor Amendments Proposed Rule 

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10 RIN 2070-AK02 

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14 EO 12866 REVIEW DRAFT 

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19 July 23December 10, 2014

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34 Economic and Policy Analysis Branch 

35 Economics, Exposure and Technology Division 

36 Office of Pollution, Prevention, and Toxics 

37 U.S. Environmental Protection Agency 

38 1200 Pennsylvania Avenue 

39 Washington, DC 20460 
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This Page Intentionally Left Blank 
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ii 

Acknowledgement

Analytical and draft preparation support was provided by Abt Associates Inc. under EPA Contract No. 

EP-W-08-0100. 

 
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iii 

Table of Contents

Executive Summary ................................................................................................................................. ES-1

1. Introduction ...................................................................................................................................... 1-1

1.1 Regulatory and Programmatic Background ............................................................................. 1-1

1.2 Summary of Analytic Approach .............................................................................................. 1-2

1.3 Organization of This Report..................................................................................................... 1-2

2. Affected Entities ................................................................................................................................ 2-1

2.1 Regulated Community ............................................................................................................. 2-1

3. Industry Cost Savings ...................................................................................................................... 3-1

3.1 Introduction .............................................................................................................................. 3-1

3.2 Abatement Multi-jurisdiction Registration Fee Amendment ................................................... 3-1

3.3 Renovator Refresher Training Course Amendment ................................................................. 3-2

3.4 Total Industry Cost Savings ..................................................................................................... 3-9

3.5 Other Industry Costs ................................................................................................................ 3-9

4. Agency Costs ..................................................................................................................................... 4-1

5. Social Cost Savings ........................................................................................................................... 5-1

6. Small Entity Impact Analysis .......................................................................................................... 6-1

7. Other Impact Analyses ..................................................................................................................... 7-1

7.1 Paperwork Reduction Act ........................................................................................................ 7-1

7.2 Unfunded Mandates Reform Act ............................................................................................. 7-3

7.3 Executive Order 13132 – Federalism ....................................................................................... 7-4

7.4 Executive Order 13175 – Consultation and Coordination with Indian Tribal Governments ... 7-4

7.5 Executive Order 13045 - Children’s Health ............................................................................. 7-4

7.6 Executive Order 13211 – Energy Supply, Distribution, or Use ............................................... 7-4

7.7 National Technology Transfer and Advancement Act ............................................................. 7-4

7.8 Executive Order 12898 – Environmental Justice ..................................................................... 7-5

8. References ......................................................................................................................................... 8-1

Appendix A. Training Courses Tuition Data .......................................................................................... A-1
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iv 

List of Exhibits

Exhibit ES-1: Total and Annualized Social Cost Savings of the Proposed Amendments Over 50 Years 

(millions 2014$) ......................................................................................................................................... ES-2

Exhibit 2-1: Lead-based Paint Activities Individuals and Firms Applying for (Re)certification and Training 

Providers Applying for (Re)accreditation from 2011-2013 .......................................................................... 2-1

Exhibit 2-2: Renovator Initial Certifications under the Renovation, Repair, and Painting Program Rule from 

2010 through 2013. ....................................................................................................................................... 2-1

Exhibit 3-1: Annual Multi-jurisdiction Registration Fees for Individuals and Firms Applying for 

(Re)certification, and Training Providers Applying for (Re)accreditation ................................................... 3-1

Exhibit 3-2: Fifty Year Net Present Value and Annualized Cost Savings for Individuals and Firms Applying 

for (Re)certification, and Training Providers Applying for (Re)accreditation (2014$) ................................ 3-2

Exhibit 3-3: Procedure to estimate in-person classroom refresher training course tuition ........................... 3-4

Exhibit 3-4: Estimated refresher training tuition summary ........................................................................... 3-4

Exhibit 3-5: Total Renovator Travel Cost ..................................................................................................... 3-5

Exhibit 3-6: Incremental Renovator Training Cost Savings under the Proposed Rule ................................. 3-5

Exhibit 3-7: Expected Number of Renovators Seeking Training ................................................................. 3-7

Exhibit 3-8: Expected Number of Renovators Seeking In-person and E-learning Refresher Training 

Options .......................................................................................................................................................... 3-7

Exhibit 3-9: Fifty Year Net Present Value and Annualized Cost Savings for Renovators Seeking In-person 

Classroom Training Under the Proposed Rule (2014$) ................................................................................ 3-8

Exhibit 3-10: Fifty Year Net Present Value and Annualized Cost Savings for Renovators Seeking 

E-learning Classroom Training Under the Proposed Rule (2014$) .............................................................. 3-8

Exhibit 3-11: Combined Fifty Year Net Present Value and Annualized Renovator Recertification Cost 

Savings Under the Proposed Rule (thousands 2014$) .................................................................................. 3-9

Exhibit 3-12: Total and Annualized Industry Cost Savings of the Proposed Amendments Over 50 Years 

(thousands 2014$) ......................................................................................................................................... 3-9

Exhibit 4-1: EPA Wage Rate ........................................................................................................................ 4-1

Exhibit 4-2: Fifty Year Net Present Value and Annualized Cost to EPA Under the Proposed Rule (2014$) 4-

1

Exhibit 5-1: Total and Annualized Social Cost Savings of the Proposed Amendments Over 50 Years 

(thousands 2014$) ......................................................................................................................................... 5-1

Exhibit 7-1: Incremental RRP Training Provider Hour Burden ................................................................... 7-2

Exhibit 7-2: Loaded RRP Training Provider Wage Rates ............................................................................ 7-3

Exhibit 7-3: RPP Incremental Training Provider Cost (2014$) .................................................................... 7-3

Exhibit A-1: Sample of Renovation (Re)certification Training Courses ..................................................... A-1
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ES-1 

Executive Summary 

The United States Environmental Protection Agency (EPA) is considering two cost saving amendments to 

the regulations for Lead-based Paint Poisoning Prevention in Certain Residential Structures, codified at 40 

CFR part 745 and promulgated under TSCA §402(a) and §402(c). This report estimates the cost savings 

from the proposed rule that includes these amendments to the Lead-based Paint (LBP) Activities rule for 

lead abatement and the Residential Property Renovation rule for renovation, repair and painting (RRP). 

The first amendment removes the multi-jurisdiction registration fee that individuals and firms pay for 

(re)certification and that training programs pay for (re)accreditation in the lead abatement program. Under 

the existing regulations, there is a $35 fee for each additional EPA-administered jurisdiction for which 

organizations apply to perform LBP abatement activities or to provide lead abatement training. In a typical 

year, individuals, firms, and training providers apply to perform lead-based paint activities or provide 

training in a total of 431 additional EPA-administered jurisdictions. Removing the $35 fee will result in 

total estimated cost savings of approximately $15,000 per year to these entities. 

The second amendment removes the hands-on training requirement from the lead renovation refresher 

training course. Under the existing rule, both the initial and refresher renovator training courses must 

include a classroom component (which may be taken in person or online) and a hands-on component 

(which must be taken in person). Removing the hands-on training requirement is estimated to reduce the 

tuition for refresher training courses by an average of $37. Removing the hands-on requirement is also 

expected to make online renovator refresher training more attractive to training providers and renovators. If 

renovators become recertified solely by taking an e-learning course (i.e., without an in-person component) 

they are estimated to save an additional $165 by avoiding the time and associated expenses needed to travel 

to a training site. 

Renovator training and certification became mandatory in 2010 and a large number of renovators were 

trained that year, with smaller numbers becoming trained in each subsequent year. Training and 

certification are valid for five years, and many renovators will need to be recertified over the next few 

years. The largest number of recertifications is expected in 2015, when 168,000 renovators are expected to 

seek refresher training. Over time, the number of renovators seeking refresher training is predicted to 

equilibrate to approximately 48,000 per year. Nearly all of these renovators are assumed to choose to 

receive their refresher training online if the hands-on requirement is removed, thus reducing travel costs. 

Removing the hands-on requirement for renovator refresher training is estimated to save over $9 million per 

year. 

If the hands-on requirement is removed, training providers currently accredited for the renovator refresher 

training course are expected to apply for an e-learning refresher training accreditation to accommodate the 

high demand for the course. EPA will incur additional costs because the Agency must review and process 

applications submitted by training providers to become accredited for an e-learning course. An estimated 

275 training providers would apply for an e-learning refresher course accreditation if the rule is 

promulgated. Reviewing and processing the additional accreditation applications is estimated to cost the 

EPA over $80,000. 

The rule includes a correction to the training notification requirements to add back regulatory text on posttraining notifications that was inadvertently overwritten in a 2011 rulemaking (although most training 

providers are continuing to provide post-training notifications to EPA in a timely manner). EPA has 
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ES-2 

already accounted for the burden and cost of requiring accredited providers of renovation training to 

provide notification to EPA after each training course the provider delivers. For example, the currently 

approved Information Collection Request for the RRP program1

 estimates that 600 renovation training 

providers will submit an average of 14 post-training notifications per year. This yields a total of 8,400 posttraining notifications per year at an average burden of 1.6 hours per response, resulting in a total burden for 

this activity of 13,440 hours at a cost of $339,578. In order to avoid double-counting cost that has already 

been accounted for, the current analysis does not include the burden and cost of reinstating the post-training 

notification requirements. 

The rule also adds clarifying language explaining that training providers must follow the regulations. This 

does not affect the cost of compliance because it does not change any requirements for accredited training 

providers, and the analysis assumes that training providers already comply with the regulations. 

Exhibit ES-1 presents estimates for the total and annualized industry cost savings and Agency costs 

associated with the enactment of the proposed amendments, as well as the total and annualized social cost 

savings. Estimates are discounted at 3 and 7 percent. The cost savings to society is estimated to be between 

$9.6 and $9.8 million per year with the passage of the proposed amendments to the LBP activities and 

renovation regulations (see Exhibit ES-1). 

Exhibit ES-1: Total and Annualized Social Cost Savings of the Proposed Amendments 

Over 50 Years (millions 2014$)1

Category 

Net Present Value Annualized Cost Savings 

3% 7% 3% 7% 

Total Industry Cost Savings $246.551 $134.938 $9.583 $9.777

Multi-jurisdiction Amendment $0.388 $0.208 $0.015 $0.015

Refresher Training Amendment $246.163 $134.730 $9.568 $9.762

Total Agency Costs $0.083 $0.080 $0.003 $0.006

E-learning Application Processing $0.083 $0.080 $0.003 $0.006

Social Cost Savings $246.468 $134.858 $9.580 $9.771

1

 A fifty year analytical period is selected to be consistent with economic analyses of prior Lead-based Paint 

Activities program rules and RRP program rules.

 

1

 Information Collection Request for the TSCA Sections 402 and Section 404 Training, Certification, Accreditation 

and Standards for Lead-Based Paint Activities and Renovation, Repair, and Painting (EPA ICR No. 1715.13, OMB 

Control No. 2070-0155). 
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1-1 

1. Introduction 

This report assesses the cost savings expected to result from amendments to EPA’s Lead-based Paint (LBP) 

Activities rule and to the Residential Property Renovation rule. These amendments would eliminate EPA’s 

multi-jurisdiction registration fee in the abatement program and remove the hands-on requirement from the 

renovator refresher training course curriculum. This chapter provides background information on EPA’s 

lead-based paint (LBP) regulations, a brief summary of the methodology used in the analysis, and a 

description of the organization of the remainder of this report. 

1.1 Regulatory and Programmatic Background 

1.1.1 Abatement Multi-jurisdiction Registration Fee 

In 1996 EPA promulgated final regulations for Lead-based Paint Activities under TSCA §402(a) that 

govern LBP inspections, lead hazard screens, risk assessments, and lead abatements in target housing and 

child-occupied facilities (61 FR 45778, codified at 40 CFR part 745). On June 9th, 1999, EPA amended the 

regulations (64 FR 31092) to include a fee schedule for individuals and firms seeking EPA (re)certification 

and for training programs seeking EPA (re)accreditation. The fee schedule created a multi-jurisdiction 

registration fee of $35 per discipline for each additional EPA-administered jurisdiction (e.g., a state) in 

which an individual, firm, or training program applies for (re)certification or (re)accreditation (40 CFR 

§745.238 (c)(3)). For purposes of this multi-jurisdiction registration fee, an EPA-administered jurisdiction 

is an individual state without an authorized program or all tribes without authorized programs in a given 

EPA Region. The EPA-administered jurisdictions for the lead abatement program are: 

 States – Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico, New York, South 

Carolina, South Dakota, and Wyoming; 

 U.S. territories – American Samoa, Guam, and the Northern Marianas; and 

 Tribal lands – tribal lands except the Cherokee Nation, Lower Sioux Nation, and Upper Sioux 

Community. 

All other states, U.S. territories, as well as the Cherokee Nation, Lower Sioux Nation, and Upper Sioux 

Community, have EPA-authorized LBP abatement programs (U.S. EPA 2014b). 

1.1.2 Hands-on Refresher Training for Renovators

In 2008, EPA issued a final rule for Residential Property Renovations under the authority of §402(c)(3) of 

TSCA to address LBP hazards created by Renovation, Repair, and Painting (RRP) activities that disturb 

LBP in target housing and child-occupied facilities (73 FR 21692). To become a certified renovator, an 

individual must successfully complete an appropriate training course accredited by EPA (40 CFR §745.90). 

Individuals who have not previously been trained must complete an initial training course lasting a 

minimum of eight hours, including a minimum of two hours of hands-on training. To maintain renovator 

certification, an individual must complete a refresher course from an accredited training provider within 

five years of completing the initial course. The rule requires renovator refresher training courses to last a 

minimum of four hours (40 CFR §745.225 (e)(2)) and include a hands-on component (40 CFR §745.225 

(e)(3)). EPA manages the RRP program in most areas of the country. However, the states of Alabama, 

Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode 

Island, Utah, Washington, and Wisconsin are authorized to administer their own programs in lieu of the 

federal program. The proposed rule, and this analysis, apply only in states that do not have authorized 

programs. 
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1-2 

 

1.2 Summary of Analytic Approach 

This analysis seeks to quantify, to the extent possible, the cost savings to society of the two amendments. 

The costs to industry associated with the multi-jurisdiction registration fee include a $35 fee for each 

additional EPA-administered jurisdiction for which organizations apply to perform lead-based paint 

abatement activities or to provide lead abatement training. The cost savings to industry for eliminating the 

fee is the amount in fees that they would no longer be required to pay. 

Costs to renovators associated with the refresher training course currently include course tuition and travel 

cost to a training site to receive hands-on training. Tuition costs are estimated to decrease if the hands-on 

requirement is removed. For those renovators choosing to take the refresher course online, there is an 

additional cost savings because there is no travel cost. The cost savings from eliminating the hands-on 

requirement for renovator refresher training includes reductions in both average tuition cost and average 

travel cost. 

1.3 Organization of This Report 

Regulated entities are characterized in Chapter 2. Chapter 3 includes the economic analysis of cost savings 

to regulated entities. The small entity impacts are discussed in Chapter 4. Several additional impacts are 

described in Chapter 7. Cited references are listed in Chapter 8. The Appendix contains the tuition data for 

renovator initial and refresher training courses that were used in the analysis. Note that all dollar values in 

this analysis are reported in 2014 dollars. 
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2-1 

2. Affected Entities 

2.1 Regulated Community 

The multi-jurisdiction registration fee amendment may affect individuals, firms, and training providers 

regulated by the Lead-based Paint Activities rule, with the exception of non-profit training providers 

(which are exempt from the fee). The renovator refresher training course amendment directly affects 

individuals who must take a training course to comply with the Residential Property Renovation rule. 

The number of entities affected under both amendments is estimated from data in EPA’s Federal Leadbased Paint Program (FLPP) database (U.S. EPA 2014a). 

Exhibit 2-1 presents the number of all applications submitted by individuals and firms engaging in leadbased paint activities, and all training providers offering lead-based paint activities training courses, from 

2011 through 2013 (not just those applying to work in additional jurisdictions). Exhibit 2-1 also presents 

the number of additional jurisdictions in which individuals and firms are sought (re)certification and 

training providers are sought (re)accreditation. 

Exhibit 2-1: Lead-based Paint Activities Individuals and Firms Applying for (Re)certification 

and Training Providers Applying for (Re)accreditation from 2011-2013 

Applicant Total Number of Applications Additional Jurisdictions Sought 

Individuals 5,127 864 

Firms 1,780 403 

Training Providers (for-profit) 23 27 

 

The RRP rule required that, starting in 2010, all regulated renovations disturbing lead-based paint must be 

performed by renovators who have taken an 8 hour training course (including 2 hours of hands-on 

training). Renovators must take a 4 hour refresher training class (which currently includes a required 

hands-on component) every five years. Exhibit 2-2 presents the number of renovator certifications from 

2010 through 2013. Column 1 of Exhibit 2-2 lists the year the certification was issued, and Column 2 lists 

the year the certification expires. The number of certifications was highest in 2010 because that was the 

year that the renovator training requirement became effective. Consequently, the number of refresher 

trainings is expected to be highest five years later (in 2015), and decline for several years at a rate 

analogous to the rate of decline observed in certifications from 2011 to 2013. 

Exhibit 2-2: Renovator Initial Certifications under the Renovation, 

Repair, and Painting Program Rule from 2010 through 2013. 

Year Certified Expiration Year Number of Initial Certifications 

2010 2015 357,500 

2011 2016 52,800 

2012 2017 38,800 

2013 2018 29,300 
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3-1 

3. Industry Cost Savings 

3.1 Introduction 

This chapter presents estimates of the cost savings associated with the amendments. Section 3.2 presents 

estimates for the multi-jurisdiction registration fee amendment and Section 3.3 presents estimates for the 

renovator refresher training course amendment. Total cost savings of both amendments are summarized in 

Section 3.4. A fifty year analytical period is used in this to be consistent with prior economic analyses of 

abatement and RRP program rules. Net present value and annualized savings are presented for this time 

period using 3 and 7 percent discount rates. 

3.2 Abatement Multi-jurisdiction Registration Fee Amendment 

If jurisdictions are eliminated, regulated entities will no longer have to send an application and fees to 

EPA for the purpose of adding additional EPA-administered state jurisdictions to their certification or 

accreditation. Once a regulated entity applies and is approved in the Lead-based Paint Activities program, 

it will be able to work in any EPA-administered state. EPA’s multi-jurisdiction registration fee data for 

2011 through 2013 are presented in Exhibit 3-1. Column 2 and Column 3 of Exhibit 3-1 present the total 

and annual average number of additional EPA-administered jurisdictions for which organizations applied 

to perform lead-based paint activities or provide training from 2011 through 2013, respectively. Note that 

non-profit training programs are excluded from the analysis because they are exempt from the multijurisdiction registration fee. The average annual costs borne by regulated entities are summarized in the 

last column of Exhibit 3-1 and are calculated by applying the $35 multi-jurisdiction registration fee to 

Column 3. Removing the multi-jurisdiction fee would save individuals, firms, and training providers a 

combined $15,085 per year. 

Exhibit 3-1: Annual Multi-jurisdiction Registration Fees for Individuals and Firms 

Applying for (Re)certification, and Training Providers Applying for (Re)accreditation

Applicant 

Additional Jurisdictions 

Total Annual Fees 

2011 - 2013 Average 

Annual 

Individuals 864 288 $10,080 

Firms 403 134 $4,690 

Training Providers (for-profit) 27 9 $315 

Total 431 $15,085 

Exhibit 3-2 presents the fifty year net present value and annualized cost savings under the proposed rule 

for individuals and firms applying for (re)certification, and training providers applying for 

(re)accreditation (2014$). The cost savings are discounted using rates of 3 and 7 percent. 
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3-2 

Exhibit 3-2: Fifty Year Net Present Value and Annualized Cost Savings for Individuals and Firms 

Applying for (Re)certification, and Training Providers Applying for (Re)accreditation (2014$) 

Period Additional 

Jurisdictions 

Unit 

Incremental 

Cost Savings 

Incremental 

Cost Savings 

Discounted Incremental 

Cost Savings 

3% 7% 

2015 431 $35 $15,085 $14,646 $14,098

2016 431 $35 $15,085 $14,219 $13,176

2017 431 $35 $15,085 $13,805 $12,314

2018 431 $35 $15,085 $13,403 $11,508

2019 431 $35 $15,085 $13,012 $10,755

2020 431 $35 $15,085 $12,633 $10,052

⁞

2064 (year 50) 431 $35 $15,085 $3,441 $512

Net Present Value $388,133 $208,184

Annualized Cost Savings $15,085 $15,085 

3.3 Renovator Refresher Training Course Amendment 

Incremental training cost savings associated with the proposed amendment include tuition and travel cost. 

The cost of the time spent on training activities is not affected because the proposed rule does not change 

the duration of the refresher training course. 

3.3.1 Tuition

Under the existing rule, both the initial and refresher renovator training courses consist of both a 

classroom and a hands-on component. The classroom component can be taken in-person or online, 

whereas the hands-on component must be taken in-person. Under the proposed rule, the hands-on 

requirement would be rescinded from the refresher training course, allowing renovators to become 

recertified remotely solely by taking an e-learning course. Traveling to a training provider’s facility, or 

contracting a traveling training provider, would no longer be obligatory. The refresher training course 

tuition is estimated under both the existing rule (with a hands-on training requirement) and the proposed 

rule (no hands-on training requirement). Estimates are based on tuition data collected from the websites of 

a sample of training providers offering refresher and/or initial renovator training. The tuition data and 

summary statistics can be found in Appendix A. 

A renovator is currently able to enroll in an in-person classroom and hands-on refresher training course. 

(The current rule would allow a renovator to take an e-learning classroom and hands-on refresher training 

course, but no training providers currently offer refresher training courses with an e-learning classroom 

component.2

) The mean tuition for an in-person classroom and hands-on refresher training course is 

 

2

 The number and variety of refresher training courses has been more limited than initial training courses because 

renovators will not need to be recertified until 2015. The refresher course has so far only been offered to 

renovators with prior lead-safety training in order to receive certification under the RRP rule. In 2015, when the 

refresher training course is in its highest demand, training providers will offer the course more frequently and may 

offer an e-learning option as well. 
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3-3 

$134.65 (see Appendix A). Based on data from initial renovator training courses3

, it appears that training 

providers tend to charge the same tuition whether the classroom component is taught in-person or online. 

From the sample of training provider course tuitions, four training providers listed tuitions for both 

options on their websites. Three of the four training providers offered both options for the same tuition. 

Accordingly, it is assumed that if a refresher training course with an e-learning classroom component and 

a hands-on component were offered, the mean tuition would also be $134.65 (identical to the tuition for a 

course with an in-person classroom component). As shown in Appendix A, the mean tuition for the 8 

hour initial renovator training course (which includes 2 hours of hands-on training) is $214.86. The mean 

tuition for the 2 hour hands-on training component by itself is estimated to be $150.02. 

Removing the hands-on requirement is expected to make online renovator refresher training more 

attractive to training providers and renovators.4

 Under the proposed rule, a renovator can enroll in an 

in-person or an e-learning classroom refresher training course. While the tuition for an e-learning 

classroom refresher training course is assumed to be the same as for an in-person class, it is worth noting 

that the e-learning classroom refresher training course tuition could be less expensive than the in-person 

option. For example, lower overhead costs may allow training providers to offer the course at a lower 

price, or new firms that have a competitive advantage in providing e-learning courses may begin offering 

the renovator refresher training course.5

 

The procedure to estimate the tuition for the classroom portion of a refresher course relies on the mean 

tuition for an initial and refresher training course, and the mean tuition for the hands-on component of an 

initial training course. The estimated tuition for an in-person classroom refresher training course is 

$97.68. The steps taken to produce this estimate are detailed in Exhibit 3-3. 

The difference between the tuition of $134.65 (for an in-person refresher course with a hands-on 

component) and $97.68 (for an in-person refresher course without a hands-on component) is $36.97. This 

$36.97 in savings results from decreases in the cost of supplies and instruction if the hands-on 

requirement is removed.6

 

3

 Unlike for refresher training, there are training providers currently offering the classroom portion of the initial 

renovator course online. 

4

 There may be less incentive for training providers to offer an e-learning option – or for renovators to take 

advantage of it – if there is a hands-on training requirement. If the renovator and/or the instructor are traveling to the 

training site, they are incurring the travel costs whether or not the classroom portion is taken in-person or online. If 

the hands-on requirement is removed the renovator can take the entire refresher course online, eliminating these 

travel costs. This makes e-learning more attractive to both the renovator and the training provider. 

5

 Currently, many e-learning courses for initial training are developed by third party firms and are offered by 

training providers who package the course with their hands-on training course. 

6

 The cost of providing instruction decreases if the hands-on component is removed because the recommended 

student teacher ratio is 6-to-1 for the hands-on component of the course, compared to 25-to-1 for the rest of the inperson classroom course. The tuition for the hands-on component also covers the cost of various supplies (such as 

EPA-recognized test kits, disposable plastic drop cloths, tape, electrostatically charged cleaning cloths, disposable 

wet cleaning wipes, garbage bags, and so on) for each student. 
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3-4 

Exhibit 3-3: Procedure to estimate in-person classroom refresher training course 

tuition

Estimation Steps Value Formula 

Tuition data (mean) 

(A) Initial Course $214.86 

(B) Refresher Course $134.65 

(C) Hands-on Training (2 hours) $150.02 

Derived estimates 

(D) Cost of 3 classroom hours and 1 hands-on training hour $80.21 (A) - (B) 

(E) Fixed cost of Initial Course $54.44 (B) - (D) 

(F) Incremental costs of 2 hours of hands-on training $95.58 (C) - (E) 

(G) Hands-on training cost per hour $47.79 (F) ÷ 2 

(H) Cost of 3 classroom hours $32.42 (D) - (G) 

(I) Classroom cost per hour $10.81 (H) ÷ 3 

In-person classroom refresher training course, 4 hours $97.68 (E) + [4 * (I)] 

Note: Unlike the initial training course, there is no mandatory duration for the hands-on component of the 

refresher course. The hands-on portion of the initial course must be at least 2 hours, which is 25% of the total 

8 hours of training. So for the refresher course, the hands-on component is assumed to be 1 hour, which is 

25% of the 4 hour duration of the refresher course. 

Exhibit 3-4 presents a summary of the estimated refresher training course tuitions under the existing and 

proposed rule. 

Exhibit 3-4: Estimated refresher training tuition summary 

Existing Rule 

In-person classroom and in-person hands-on $134.65 

E-learning classroom and in-person hands-on $134.65 

Proposed Rule removing hands-on requirement 

In-person classroom (no hands-on) $97.68 

E-learning classroom (no hands-on) $97.68 

3.3.2 Travel Cost 

Travel cost consists of the cost for a renovator to travel to the training site, incidental expenses, and the 

value of the time spent traveling to and from the training site. The estimated cost of travel relies on the 

Standard Mileage Rates published by the Internal Revenue Service (IRS). The IRS published a rate of 

$0.56 per mile, effective January 1st, 2014 (IRS 2013). The travel distance is assumed to be 100 miles (50 

miles each way), as in the 2008 economic analysis of the RRP program rule (U.S. EPA 2008). The total 

cost of travel is estimated to be $56. Expenses comprise the cost of lunch and are estimated using the 

Meals and Incidental Expenses Breakdown published by the General Services Administration. These 

expenses are estimated to be $14.17 and are calculated by averaging the six tiers of lunch reimbursement 

rates representing the lower 48 states (GSA 2014). 

The travel duration and the average renovator wage rate are used to estimate the cost of renovators’ time 

to travel to a training site. Travel duration is assumed to be two hours, as in the 2008 economic analysis 

of the RRP program rule (U.S. EPA 2008). The wage rate assigned to renovators is derived with methods 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-5 

and from sources identical to or similar to those used in previous Information Collection Request 

renewals and economic analyses for EPA’s RRP program. A renovator’s fully loaded wage rate 

incorporates wages and salaries, benefits, and overhead. A renovator’s wages and salaries are represented 

by the mean hourly wage rate of First-Line Supervisors of Construction Trades and Extraction Workers, 

published by the Bureau of Labor Statistics (BLS) - Occupational Employment Statistics (OES). The 

mean hourly wage rate inflated to 2014 dollars is $31.12 for First Line Supervisors of Construction 

Trades and Extraction Workers (BLS 2012; BLS 2014). The base wage rate is inflated to 2014 dollars by 

applying the Consumer Price Index (CPI) for All Urban Consumers published by the Bureau of Labor 

Statistics (BLS 2014). The September 2013 release of the BLS Employer Costs for Employee 

Compensation (ECEC) data indicates that wages and salaries constitute 69.1% of total employee 

compensations for civilian workers, implying a wage multiplier of 1.45 to account for benefits (BLS 

2013). An overhead of 8.3% is derived from the 2012 publication of the Cost of Doing Business (NAHB 

Business Management & Information Technology 2012). By combining 1.45 and 8.3%, a multiplier of 

1.53 is used to estimate a fully loaded hourly wage rate of $47.61 for renovators. Taking into account the 

total travel duration of two hours, the cost of travel time for a renovator attending training is estimated to 

be $95.22. 

Exhibit 3-5 summarizes the components of the travel cost to attend in-person training. 

Exhibit 3-5: Total Renovator Travel Cost

Category Cost 

Mileage Cost $56.00 

Expenses (lunch) $14.17 

Cost of Travel Time $95.22 

Travel Cost $165.39 

3.3.3 Incremental Training Cost Savings per Renovator 

Exhibit 3-6 presents the incremental training cost savings per renovator seeking recertification under the 

proposed rule. The cost savings includes reduced tuition and avoided travel costs. Renovators switching 

to the e-learning course realize the greatest cost savings because they avoid the costs associated with 

traveling to a training provider’s facility. 

Exhibit 3-6: Incremental Renovator Training Cost Savings under the 

Proposed Rule 

Training Course Existing Rule 

Costs 

Proposed Rule 

Costs Cost Savings 

In-person classroom 

 Tuition $134.65 $97.68 $36.97 

 Travel Cost $165.39 $165.39 0 

 Total $300.04 $263.07 $36.97 

E-learning classroom 

 Tuition $134.65 $97.68 $36.97 

 Travel Cost $165.39 0 $165.39 

 Total $300.04 $97.68 $202.36 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-6 

3.3.4 Number of Individuals Seeking Renovator Recertification 

Renovator training and certification for persons conducting covered renovation activities became 

mandatory in 2010, and a large number of renovators were trained that year. There was a decrease in the 

number of individuals trained in 2011, and a further decrease in 2012 and 2013. The total number of 

renovators expected to seek refresher training in 2015 through 2018 is estimated using certification 

expiration data for the current stock of trained and certified renovators (see Exhibit 3-7) and an assumed 

turnover rate for renovators exiting the industry. The total number of renovators expected to seek training 

in 2019 is assumed to equal the total in 2018 because expiration data is not yet available for that year. 

Beyond 2019, it is assumed that the total number of renovators expected to seek training each year will 

stabilize. Exhibit 3-7 presents the total number of renovators expected to seek training from 2015 through 

2064, as well as the subset expected to seek refresher training. 

The number of expired certifications presented in Column 2 of Exhibit 3-7 is equal to the number of 

initial certifications attained five years earlier. Each year, some certified individuals exit the industry and 

are replaced by new entrants who seek initial training and certification. Due to this turnover, the number 

of individuals seeking renovator refresher training and recertification will be less than the numbers of 

individuals with expiring certifications (which represents the total number of individuals assumed to be 

trained each year). 

It is assumed that 53 percent of the stock of renovators seeking training exits the industry during the five 

year certification period. This turnover rate is based on the average percent of Abatement Supervisor 

applications that are for initial certification, recorded in the FLPP database between 2007 and 2009 (U.S. 

EPA 2010). Therefore, the number of renovators seeking refresher training in a given year is equal to the 

number of renovators that remained active throughout the certification period, which is 47 percent of the 

number of renovators trained five years earlier (see Column 2 of Exhibit 3-7). The other 53 percent are 

assumed to exit the industry and be replaced by new entrants who take the initial training course. 

Because renovators were required to be trained and certified starting in 2010 and because renovator 

training and certification is valid for five years, a large number of renovators are expected to seek 

refresher training in 2015, with a decrease in 2016, 2017, and 2018. Beginning in 2020, the number of 

renovators seeking training each year is assumed to equilibrate to 101,540, one fifth of the total stock of 

certified renovators. The total stock of certified renovators is equal to the sum of expiring certifications 

from 2015 through 2019 (507,700 renovators). 

The number of renovators receiving initial training decreased each year from 2010 through 2013. One 

might expect a spike in refresher training starting in 2015 followed by a decrease for the next four years, 

followed by another spike in 2020, with a repeating pattern every five years. That is, one might expect a 

cyclical pattern of retraining to emerge. However, over time the original cohort of trained individuals will 

retire or leave the market and be replaced by new renovators whose training cycle is not tied to the start of 

the RRP program in 2010. So the cycle will be dampened and eventually disappear. Trying to model 

such a trend in the declining cyclicality would add little to the analysis while significantly increasing the 

complexity of the calculations. Instead, the analysis uses a declining level for the first cycle of refresher 

training (because this mirrors the historical data on initial training shown in Exhibit 3-7). Then, in order to 

simplify the calculations, the analysis assumes a constant average number of individuals receive refresher 

training each year starting in 2020. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-7 

Exhibit 3-7: Expected Number of Renovators Seeking Training 

Year1

Number of Renovators 

Seeking Initial or 

Refresher Training1

Renovators Seeking 

Refresher Training2

2015 357,500 168,025 

2016 52,800 24,816 

2017 38,800 18,236 

2018 29,300 13,771 

2019 29,300 13,771 

Average for 2015-2019 101,540 47,723 

2020 101,540 47,723 

⁞

2064 (year 50) 101,540 47,723 

1

 The number of renovators seeking training in 2019 is assumed to equal the number in 2018. 

2

 Each year 47 percent of renovators with expiring certifications are expected to seek refresher training. The other 

53 percent are assumed to exit the industry, and be replaced by new entrants who take the initial training course.

If the refresher hands-on training requirement is removed, renovators seeking refresher training would 

have the option to become recertified by enrolling in an in-person course or an e-learning course. 

Ninety-eight percent of renovators seeking training are assumed to enroll in an e-learning course due to 

the convenience of taking the course online and the savings in travel costs.7

 The remaining 2 percent of 

renovators are assumed to continue taking in-person training after the amendment because they prefer to 

take their training in class rather than online. Enrollment expectations are summarized in Exhibit 3-8. 

Exhibit 3-8: Expected Number of Renovators Seeking In-person and 

E-learning Refresher Training Options

Year1 In-person E-learning 

2015 3,361 164,665 

2016 496 24,320 

2017 365 17,871 

2018 275 13,496 

2019 275 13,496 

Average for 2015-2019 954 46,769 

2020 954 46,769 

⁞

2064 (year 50) 954 46,769 

1

 The number of renovators seeking training in 2019 is assumed to equal the number in 2018. 

 

7

 The 98% value is a demonstrative assumption for analytical purposes. It is not based on experience with any other 

training programs, such as the initial renovator training. (Because the initial renovator training requires hands-on 

training, as well as travel expenses, that online training does not result in comparable cost savings or adoption rates.) 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-8 

3.3.5 Total Renovator Training Costs Savings 

Exhibit 3-9 and Exhibit 3-10 present the net present value and annualized cost savings under the proposed 

rule, over a fifty year period from 2015 through 2064, for the in-person and e-learning classroom 

refresher training courses, respectively. The cost savings are discounted using rates of 3 and 7 percent. 

Exhibit 3-9: Fifty Year Net Present Value and Annualized Cost Savings for Renovators Seeking In-person 

Classroom Training Under the Proposed Rule (2014$) 

In-person classroom 

training Recertifications 

Unit 

Incremental 

Cost Savings 

Incremental 

Cost Savings 

(1,000$) 

Discounted Incremental Cost 

Savings (1,000$) 

3% 7% 

2015 3,361 $36.97 $124 $121 $116

2016 496 $36.97 $18 $17 $16

2017 365 $36.97 $13 $12 $11

2018 275 $36.97 $10 $9 $8

2019 275 $36.97 $10 $9 $7

2020 954 $36.97 $35 $30 $24

⁞ 

2064 (year 50) 954 $36.97 $35 $8 $1

Net Present Value $914 $500

Annualized Cost Savings $36 $36

Exhibit 3-10: Fifty Year Net Present Value and Annualized Cost Savings for Renovators Seeking 

E-learning Classroom Training Under the Proposed Rule (2014$) 

E-learning classroom 

training Recertifications 

Unit 

Incremental 

Cost Savings 

Incremental 

Cost Savings 

(1,000$) 

Discounted Incremental Cost 

Savings (1,000$) 

3% 7% 

2015 164,665 $202.36 $33,322 $32,351 $31,142

2016 24,320 $202.36 $4,921 $4,639 $4,298

2017 17,871 $202.36 $3,616 $3,310 $2,952

2018 13,496 $202.36 $2,731 $2,426 $2,083

2019 13,496 $202.36 $2,731 $2,356 $1,947

2020 46,769 $202.36 $9,464 $7,926 $6,306

⁞ 

2064 (year 50) 46,769 $202.36 $9,464 $2,159 $321

Net Present Value $245,249 $134,230

Annualized Cost Savings $9,532 $9,726

Exhibit 3-11 presents the combined net present value and annualized incremental cost savings accrued by 

renovators over a fifty year period from 2015 through 2064, under the proposed rule. Costs are discounted 

using rates of 3 and 7 percent. 

 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-9 

Exhibit 3-11: Combined Fifty Year Net Present Value and Annualized Renovator 

Recertification Cost Savings Under the Proposed Rule (thousands 2014$) 

Category 

Net Present Value Annualized Costs 

3% 7% 3% 7% 

Proposed Rule Cost 

Savings $246,163 $134,730 $9,568 $9,762

3.4 Total Industry Cost Savings 

The net present value and annualized industry cost savings for both proposed amendments are 

summarized in Exhibit 3-12. These savings reflect a 50 year period from 2015 through 2064, and are 

discounted using rates of 3 and 7 percent. The net present value of the industry cost savings ranges from 

$134,938 thousand to $246,551 thousand, in 2014$. Annualized industry cost savings are expected to 

range from $9,583 thousand to $9,777 thousand per year, in 2014$. 

Exhibit 3-12: Total and Annualized Industry Cost Savings of the Proposed Amendments 

Over 50 Years (thousands 2014$)

Category 

Net Present Value Annualized Cost Savings 

3% 7% 3% 7% 

Multi-jurisdiction Amendment $388 $208 $15 $15

Refresher Training Amendment $246,163 $134,730 $9,568 $9,762

Total Industry Cost Savings $246,551 $134,938 $9,583 $9,777

3.5 Other Industry Costs 

3.5.1 Abatement Multi-jurisdiction Registration Fee Amendment 

EPA does not anticipate other direct or indirect impacts resulting from the proposed rule that would cause 

entities regulated under the abatement program to experience increases or reductions in their costs. 

3.5.2 Renovator Refresher Training Course Amendment 

Individual training providers offering RRP training courses could be negatively impacted by the proposed 

rule if (1) their profit margins are lower for the e-learning course, or (2) they lose market share with the 

introduction of the e-learning course. 

Under the proposed rule, a much larger portion of renovators are expected to enroll in the e-learning 

refresher training course than the e-learning component of the initial training course. This is because 

renovators would not have to travel to a training facility in the absence of a hands-on refresher training 

requirement. (By contrast, renovators taking the initial training course will still have to travel to take the 

hands-on portion.) If training providers do not develop their own e-learning course, they must contract a 

third-party firm to offer the course online. In this scenario, training providers will incur costs in the form 

of fees paid to the third-party firms to develop and administer the e-learning courses. At the same time 

other training provider costs, such as classroom space and faculty costs, will decrease. In addition, tuition 

is expected to be lower if the hands-on requirement is removed. Thus, tuition is expected to decrease 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

3-10 

while some costs are expected to increase and others are expected to decrease. Many uncertainties and 

data gaps exist about the extent to which individual training provider profit margins might change. Some 

training providers may exit the market, others may add market share, and new entrants might also seek 

training provider accreditation. Alternatively, if many renovators choose to take refresher training from 

the provider of their initial training, there may be little change in market shares. 

Third-party firms developing renovator e-learning refresher training courses could decide to become 

accredited RRP training providers. In this scenario, third-party firms could gain a large portion of the 

market share due to their competitive advantage gained by experience and economies of scale. Assuming 

there are relatively few third-party firms developing e-learning courses, the proposed rule could result in 

the consolidation of the market of training providers offering refresher training courses. While there 

would not be a net loss to the economy, training providers unable to compete with third-party firms that 

might attain accreditation would likely experience reduced profits or exit the refresher training market 

(although they might continue to offer initial certification training). 

 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

4-1 

4. Agency Costs 

EPA will incur costs resulting from the new rule associated with reviewing the expedited e-learning 

applications submitted by training providers to attain accreditation. It is estimated to take an average of 4 

hours apiece for an Agency employee to review each of the 275 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 

Management (OPM). A loaded wage rate of $78.13 is then derived by applying a 1.6 fringe benefits and 

overhead multiplier to the base wage rate of a GS-13 Step 5 government employee (see Exhibit 4-1) 

(OPM 2014). 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 (U.S. EPA 2009). 

Exhibit 4-1: EPA Wage Rate 

Labor 

Category Date

Base 

Wage1

Fringe Benefits and 

Overhead Multiplier2

Loaded 

Wages 

(a) (b) (c)=(a)*(b) 

GS-13 Step 5 1/14 $48.83 1.6 $78.13 

1 Office of Personal Management (2014). 2014 General Schedule (GS) Locality Pay 

Tables: WASHINGTON-BALTIMORE-NORTHERN VIRGINIA, DC-MD-VAWV-PA. SALARY TABLE 2014-DCB . 

2 U.S. EPA (2009). "ICR Handbook- EPA’s Guide to Writing Information Collection 

Requests." 

Exhibit 4-2 presents net present value and annualized cost accrued by EPA over a fifty year period from 

2015 through 2064, under the proposed rule. Costs are discounted using rates of 3 and 7 percent. It is not 

known how many training providers will only offer refresher training online and how many will maintain 

dual accreditations (one for in-person training and one for online training). Therefore, it is unknown 

whether there will be a change in the number of reaccreditation applications after 2015. If most training 

providers begin offering refresher training only online, EPA’s work load for reviewing accreditation 

applications would not change much in future years since the training providers would be substituting an 

online accreditation for one that is in-person. As a result, the analysis only considers EPA’s costs for 

reviewing additional accreditation applications in 2015. 

Exhibit 4-2: Fifty Year Net Present Value and Annualized Cost to EPA Under the Proposed 

Rule (2014$) 

Application 

Review Costs 

Hours per 

Application 

Cost per 

Application 

($78.13/hour) 

Applications 

Reviewed Total Cost 

Discounted Total Cost

3% 7% 

2015 4.00 $312.52 275 $85,943 $83,440 $80,321 

Net Present Value $83,440 $80,321 

Annualized Cost $3,243 $5,820 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

5-1 

5. Social Cost Savings 

The estimated total social cost savings of the proposed rule is equal to the sum of industry cost savings 

less Agency costs. Exhibit 5-1 presents the net present value and annualized equivalent value of expected 

cost savings to society over a fifty year period ranging from 2015 to 2064. Estimates are discounted using 

rates of 3 and 7 percent. 

Exhibit 5-1: Total and Annualized Social Cost Savings of the Proposed Amendments 

Over 50 Years (thousands 2014$) 

Category 

Net Present Value Annualized Cost Savings 

3% 7% 3% 7% 

Industry Cost Savings $246,551 $134,938 $9,583 $9,777

Multi-jurisdiction Amendment $388 $208 $15 $15

Refresher Training Amendment $246,163 $134,730 $9,568 $9,762

Total Agency Costs $83 $80 $3 $6

E-learning Application Processing $83 $80 $3 $6

Social Cost Savings $246,468 $134,858 $9,580 $9,771
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

6-1 

6. Small Entity Impact Analysis 

The Regulatory Flexibility Act (RFA) of 1980, amended by the Small Business Regulatory Enforcement 

Fairness Act (SBREFA) of 1996, requires regulators to assess the effects of regulations on small entities 

including businesses, nonprofit organizations, and governments. In some instances, agencies are also 

required to examine regulatory alternatives that may reduce adverse economic effects on significantly 

impacted small entities. The RFA requires agencies to prepare an initial and final regulatory flexibility 

analysis for each rule unless the Agency certifies that the rule will not have a significant economic impact 

on a substantial number of small entities. 

The proposed rule would eliminate multi-jurisdiction registration fees and eliminate the hands-on training 

requirement from the lead renovation refresher training course, resulting in cost savings for entities that 

no longer would pay the multi-jurisdiction registration fees and renovators that would have a less 

expensive refresher training option available to them. Training providers might incur costs associated 

with accrediting e-learning courses. However, it is expected that only training providers that anticipate 

recovering accreditation costs through tuition charges would opt to apply for the additional accreditation 

because there is no requirement mandating these firms to offer an e-learning refresher training option 

under the proposed rule. Therefore, there would be no direct negative cost impacts on small entities as a 

result of the proposed rule. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-1 

7. Other Impact Analyses 

Several statutes and executive orders (EOs) pertain to the proposed rule. This chapter presents 

statements discussing unfunded mandates, environmental justice, children’s health, and 

paperwork burden, among others. 

7.1 Paperwork Reduction Act 

The Paperwork Reduction Act of 1995 (PRA) (superseding the PRA of 1980), as implemented by 

the Office of Management and Budget (OMB), requires that agencies submit a supporting 

statement to OMB for any information collection that solicits the same data from more than nine 

parties. The PRA seeks to ensure that Federal agencies balance their need to collect information 

with the paperwork burden imposed on the public by the collection. The definition of 

“information collection” includes activities required by regulations such as permit development, 

monitoring, recordkeeping, and reporting. The term “burden” refers to the “time, effort, or 

financial resources” the public expends to provide information to or for a Federal agency, or to 

otherwise fulfill statutory or regulatory requirements. PRA paperwork burden is measured in 

terms of annual time and financial resources the public devotes to meet one-time and recurring 

information requests (44 U.S.C. 3502(2); 5 C.F.R. 1320.3(b)). Information collection activities 

may include: 

 reviewing rule requirements; 

 using technology to collect, process, and disclose information; 

 adjusting existing practices to comply with requirements; 

 searching data sources; 

 completing and reviewing the response; and 

 transmitting or disclosing information. 

Agencies must provide information to OMB on the parties affected, the annual reporting burden, 

and the annual cost of responding to the information collection. 

7.1.1 Industry Burden 

RPP Training Provider Burden 

Currently accredited training providers that wish to add an already reviewed and accepted RRP 

e-learning course from another training provider to their training curriculum are eligible for an 

expedited e-learning course approval. All requests to add an already-reviewed e-learning 

curriculum to an already-accredited training providers' record must include a cover letter; a 

training provider application to amend their accreditation; and an e-learning quality control (QC) 

plan. The e-learning QC plan must address issues such as how the trainer will ensure that 

students successfully complete the e-learning modules and the e-learning module final 

assessment. Training providers that are already accredited are not charged a fee when adding an 

already-reviewed e-learning curriculum. 

Training providers currently accredited for the renovator refresher training course are expected to 

apply for an e-learning refresher training accreditation if the hands-on requirement is removed. 

Therefore they would incur an incremental paperwork burden. Training providers applying for 

accreditation incur a one-time burden associated with becoming familiar with the new rule’s 

requirements, as well as the burden of completing the accreditation application. Recordkeeping 

burdens and reporting burdens associated with notification are not incorporated into the 

incremental burden because they are incurred with or without this proposed rule. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-2 

There are 275 training providers with accredited renovator refresher training programs. It is 

estimated that renovation training providers will spend half as long on becoming accredited for an 

e-learning refresher training course as on initial accreditation for an initial training course. (Less 

information needs to be provided for an expedited e-learning application, given that the training 

provider has already been accredited for an in-person course.) Burden for the initial accreditation 

of an initial renovation training course is taken from the previously approved ICR (EPA No. 

1715.13). Burden hour estimates were rounded to one decimal place for this ICR. The resulting 

burden is estimated to be 4 hours for training providers to familiarize themselves with the rule 

requirements; 4.8 hours to complete the accreditation statement; and 5 hours to complete the 

Quality Control Plan (see Exhibit 7-1). 

Wage rates for each category of personnel are derived with methods and from sources either 

identical or very similar to those used in previous ICRs and economic analyses. Loaded wage 

rates of $53.66 and $26.79 represent training provider wages for professional and clerical 

workers, respectively. Wage and fringe benefits data are taken from the Employer Cost for 

Employee Compensation data series published by the Bureau of Labor Statistics (BLS 2013). 

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

for All Urban Consumers published by the Bureau of Labor Statistics (BLS 2014). The overhead 

data is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Program

(U.S. EPA 2002). The overhead loading factor is added to the benefits loading factor, and the 

total is then applied to the base wage to derive the fully loaded wage. See Exhibit 7-2 for a 

detailed derivation of the training provider loaded wage rates. 

Exhibit 7-1: Incremental RRP Training Provider Hour Burden 

Activity Professional 

Hours1

Clerical 

Hours1

Burden 

Hours Per 

Activity1

Number of 

Training 

Providers 

Number of 

Events Per 

Provider2

Total 

Burden 

Hours 

E-learning Accreditation 

Rule Familiarization 4.00 0.00 4.00 275 1 1,100

Accreditation Statement 3.80 1.00 4.80 275 1 1,320

Quality Control Plan 4.00 1.00 5.00 275 1 1,375

Total Reporting 11.80 2.00 13.80 275 1 3,795

1 Burden hour estimates per activity for an expedited e-learning application are assumed to be half the burden in the previously 

approved ICR EPA No. 1715.13. The hour estimates were rounded to one decimal place for this ICR. 

2 Number of events are from the previously approved ICR EPA No. 1715.13. 

 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-3 

Exhibit 7-2: Loaded RRP Training Provider Wage Rates 

Labor 

Category 

Occupation 

Category (BLS)1 Date 

Base

Wage1

Fringe 

Benefits

Benefits

(% of 

Wage)1 

Overhead

(% of 

Wage)2 

Wage 

Multiplier 

Loaded 

Wages3 

(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. 

As shown in Exhibit 7-1, training providers would incur an incremental burden of 3,795 hours. 

Exhibit 7-3 presents the incremental costs to training providers associated with new training 

program accreditation, which are estimated to be $188,861.8

 Wage rates of $53.66 and $26.79 are 

applied to the professional and clerical hour burdens, respectively, to calculate costs. 

Exhibit 7-3: RPP Incremental Training Provider Cost (2014$) 

Cost Element 

Professional 

Costs 

($53.66/hour)

Clerical 

Costs 

($26.79/hour)

Costs per 

Activity 

Number of 

Training 

Providers 

 Events per 

Training 

Provider 

Total Cost1

E-learning Accreditation 

Rule Familiarization $214.64 $0.00 $214.64 275 1 $59,026

Accreditation Statement $203.91 $26.79 $230.70 275 1 $63,442

Quality Control Plan $214.64 $26.79 $241.43 275 1 $66,393

Total Reporting $633.19 $53.58 $686.77 275 1 $188,861

1

 Wage rates of $53.66 and $26.79 are applied to the professional and clerical hour burdens, respectively. 

 

7.2 Unfunded Mandates Reform Act 

 Title II of the Unfunded Mandates Reform Act of 1995 (UMRA), 2 U.S.C. 1531-1538, directs 

agencies to assess the effects of significant regulatory actions that impose Federal mandates on 

State, local, and tribal governments, and the private sector. This proposed rule would not impose 

an enforceable duty on any State, local or tribal governments or the private sector, nor does it 

contain any regulatory requirements that might significantly or uniquely affect small 

governments. Training providers (both those in the private sector as well as local or tribal 

 

8

 The cost of training providers becoming accredited is incorporated into the tuition they charge their 

students, so the labor cost of the accreditation is not listed separately in the social cost estimate for the rule. 

But since the activity involves disclosing information, it is accounted for separately as part of the 

paperwork burden analysis. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-4 

governments) that choose to offer e-learning refresher renovator training would incur a cost to 

apply for accreditation of their e-learning courses. However, only training providers that 

anticipate recovering accreditation costs through tuition charges would opt to apply for the 

additional accreditation because there is no requirement mandating these firms to offer an 

e-learning refresher training option under the proposed rule. 

7.3 Executive Order 13132 – Federalism 

Executive Order 13132 (64 FR 43255, August 10, 1999) applies to policies that have substantial 

direct effects on the States, on the relationship between the national government and the States, or 

on the distribution of power and responsibilities among the various levels of government. This 

proposed rule would not have substantial direct effects on the States, on the relationship between 

the national government and the States, or on the distribution of power and responsibilities among 

the various levels of government. Local governments can serve as training providers, and thus 

might incur costs associated with accrediting their e-learning courses as a result of this action. 

However, only training providers that anticipate recovering accreditation costs through tuition 

charges would opt to apply for the additional accreditation because there is no requirement 

mandating these firms to offer an e-learning refresher training option under the proposed rule. 

7.4 Executive Order 13175 – Consultation and Coordination with Indian 

Tribal Governments 

Executive Order 13175 (65 FR 67249, November 9, 2000) directs agencies to consult and 

collaborate with tribal officials in Federal policy decisions that have tribal implications. This 

proposed rule would not have tribal implications. Tribal governments can serve as training 

providers, and thus might incur costs associated with accrediting their e-learning courses. 

However, only training providers that anticipate recovering accreditation costs through tuition 

charges would opt to apply for the additional accreditation because there is no requirement 

mandating these firms to offer an e-learning refresher training option under the proposed rule. 

7.5 Executive Order 13045 - Children’s Health 

Executive Order 13045 (62 FR 19885, April 23, 1997) applies to rules that are economically 

significant and that concern health or safety risks that EPA has reason to believe may 

disproportionately affect children. This action is not an economically significant regulatory action 

as defined by Executive Order 12866 because it is not likely to result in a rule that may have an 

annual effect on the economy of $100 million or more, or adversely affect in a material way the 

economy, a sector of the economy, productivity, competition, jobs, the environment, public health 

or safety, or State, local or tribal governments or communities. 

7.6 Executive Order 13211 – Energy Supply, Distribution, or Use 

Executive Order 13211 (66 FR 28355, May 22, 2001) addresses actions that effect the supply, 

distribution, or use of energy. This proposed rule is not likely to have any adverse effect on the 

supply, distribution, or use of energy. 

7.7 National Technology Transfer and Advancement Act 

Section 12(d) of NTTAA, 15 U.S.C. 272 note, directs agencies to use voluntary consensus 

standards in their regulatory activities unless to do so would be inconsistent with applicable law 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

7-5 

or otherwise impractical. Voluntary consensus standards are technical standards (e.g., materials 

specifications, test methods, sampling procedures, and business practices) that are developed or 

adopted by voluntary consensus standards bodies. This proposed rule does not involve technical 

standards. 

7.8 Executive Order 12898 – Environmental Justice 

 Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive policy on 

environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States. 

This proposed rule does not directly affect the level of protection provided to human health or the 

environment. This is a rule amendment that removes multi-jurisdiction fees for lead-based paint 

activities and removes the hands-on requirement for refresher renovator training. However, it 

does not change the work practice requirements for lead-based paint activities or renovation, 

repair or painting activities disturbing lead-based paint. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

8-1 

8. References 

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." Retrieved Jan. 30, 2014, from 

http://www.bls.gov/oes/current/oes471011.htm#(2). 

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

- September 2013." Retrieved Jan. 30, 2014, from 

http://www.bls.gov/news.release/archives/ecec_12112013.pdf. 

Bureau of Labor Statistics (BLS). (2014). "Consumer Price Index - All Urban Consumers, U.S. 

City Average (2004 to 2014)." CUSR0000SA0 Retrieved Mar. 21, 2014. 

Internal Revenue Service (IRS). (2013, Dec. 6). "2014 Standard Mileage Rates." Retrieved Mar. 

19, 2014, from http://www.irs.gov/2014-Standard-Mileage-Rates-for-Business,-Medicaland-Moving-Announced. 

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

2012 Edition, NAHB BuilderBooks.com®. 

Office of Personal Management (OPM) (2014). 2014 General Schedule (GS) Locality Pay 

Tables: WASHINGTON-BALTIMORE-NORTHERN VIRGINIA, DC-MD-VA-WVPA. SALARY TABLE 2014-DCB 

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. 

U.S. EPA (2008). Economic Analysis for the TSCA Lead Renovation, Repair, and Painting 

Program Final Rule for Target Housing and Child-Occupied Facilities. 

U.S. EPA (2009). "ICR Handbook- EPA’s Guide to Writing Information Collection Requests." 

U.S. EPA (2010). "Federal Lead-Based Paint Program (FLPP) Database 2007-2009." 

U.S. EPA (2014a). "Federal Lead-Based Paint Program (FLPP) Database 2010-2013." 

U.S. EPA. (2014b, Jan. 15). "Lead-Based Paint Activities Professionals." Retrieved Mar. 7, 

2014, from http://www2.epa.gov/lead/lead-based-paint-activities-professionals#map. 

U.S. General Services Administration (GSA). (2014, Jan. 14). "Meals and Incidental Expenses 

(M&IE) Breakdown." Retrieved Jan. 30, 2014, from www.gsa.gov/mie. 
*** EO 12866 Review Draft – Deliberative – Do Not Quote, Cite, or Release During Review***

A-1 

Appendix A. Training Courses Tuition Data 

Exhibit A-1: Sample of Renovation (Re)certification Training Courses 

Company 

Initial Refresher 

Complete Hands-on Complete 

Access Training $195.00 $150.00

AEHS, Inc. $200.00 $140.00 

Analytical Testing and Consulting Services, Inc. $150.00 

Benchmark Environmental Training $165.00 

Benchmark Environmental Training $200.00 

Cardno ATC $225.00 $135.00

CEI CNY Environmental Institute $150.00 $135.00

CEI CNY Environmental Institute $175.00 

Chem Scope $180.00 $125.00

Contractor Training1 $160.04 

Environmental Education $145.00

Environmental Management Institute $280.00 $180.00

GEBCO Associates, LP $220.00 $200.00

Greenville Technical College $215.00 $150.00

LEW Corporation $200.00 $120.00

Lianna Development Corporation Training Program $190.00 $100.00

Midwest Environmental Consulting, LLC $195.00 $95.00

Midwest Training Institute $175.00 $100.00

National Econ Corporation $185.00 $135.00

Northwest Independent Contractors Association $250.00 $200.00

Northwest Independent Contractors Association $295.00 

Northwest Independent Contractors Association $300.00 

Public Health and Safety Inc. $260.00 

Resolution, Inc. $225.00 $95.00

The Environmental Institute $250.00 $125.00

The Western Regional Lead Training Center $217.00 

The Westside Environmental Plan of Action Committee, LLC $225.00 

TORF Environmental Management $250.00 

Weecycle Environmental Consulting $200.00 

Weecycle Environmental Consulting $250.00 

Wunderlin Environmental Training Services LLC $209.00 $99.00

Number of Courses 29 2 17

Mean $214.86 $150.02 $134.65

Median $209.00 $150.02 $135.00

Minimum $150.00 $140.00 $95.00

Maximum $300.00 $160.04 $200.00

Standard Deviation $39.52 $14.17 $33.91

1 Initial hands-on training course tuition is derived by taking the tuition for the initial e-learning classroom and hands-on 

training course and subtracting the e-learning classroom component ($160.04 = $199.99 - $39.95). The e-learning 

component was developed by a third-party firm, Contractor Harbor.