April 26, 2010 Page 1 of 38

Supporting Statement for a Request for OMB Review

Under the Paperwork Reduction Act

1. Identification of the Information Collection

1(a) Title of the Information Collection

TITLE: ICR Amendment for Rulemaking entitled “Lead; Elimination of the Opt-out 

Provision and Other Amendments to the Renovation, Repair, and Painting 

Program; Final Rule”

ICR No. EPA ICR No. 1715.12; OMB 2070-0155

1(b) Short Characterization/Abstract

The following information collection request (ICR) addendum covers revisions to the 2008 

renovation, repair, and painting (RRP) rule which established reporting and recordkeeping requirements 

for individuals and firms conducting renovations in target housing, which is most housing constructed 

before 1978, and child-occupied facilities, which are pre-1978 residential, public, or commercial 

buildings where children under 6 are regularly present. EPA is revising the 2008 RRP final rule under the 

authority of Sections 402 and 407 of the Toxic Substances Control Act (TSCA). This ICR addendum 

revises the existing approved ICR to incorporate reporting and recordkeeping requirements in a rule 

expected to be published in the Federal Register on April 28, 2010. 

Section 402(a) of TSCA requires EPA to develop and administer a training and certification 

program as well as work practice standards for persons who perform lead-based paint activities. The 

current regulations in 40 CFR part 745, subpart L, cover inspections, lead hazard screens, risk 

assessments, and abatement activities in target housing, which is most pre-1978 housing, and childoccupied facilities. 

Like the regulations under Section 402(a) of TSCA, the regulations pertaining to renovation 

projects under Section 402(c)(3) of TSCA require reporting and/or recordkeeping from three entities: 

firms engaged in renovations in target housing and child-occupied facilities; training providers; and 

States/Territories/Tribes/Alaskan Native Villages (hereafter, the term “States” includes Territories, Tribes 

and Villages). Of these entities, the rule only affects firms and training providers. Accordingly, this 

document does not address the record keeping or reporting requirements for States. The following 

sections provide a general overview of the reporting and recordkeeping requirements for firms and 

training providers, discussed in more detail in section 4(b).

Firms. Firms that wish to engage in renovations in target housing or child-occupied facilities 

must obtain certification from EPA/States. This includes firms consisting only of one selfemployed individual. To receive certification, a firm must submit a letter to EPA/States 

certifying that it will employ certified renovators and conduct renovations in target housing in 

accordance with the work practice standards. Firms must re-certify every five years. The rule 

also requires firms to develop and retain records of the renovation activities they undertake to 

demonstrate compliance with standards and provide a written record for future reference. In 

addition, for renovations in child-occupied facilities located in public or commercial buildings, 

the rule requires firms to provide the building owner and adult representative of the childoccupied facility with a lead hazard information pamphlet. After providing the pamphlet to the 

owner and occupant and obtaining written acknowledgment, the firm must keep acknowledgment 

records on file for three years after completion of work. Renovation firms must also either (i) 

provide the lead hazard information pamphlet and general information on the renovation to 
April 26, 2010 Page 2 of 38

parents or guardians of children under age 6 using the facility, or (ii) erect signs that provide 

general information on the renovation accompanied by the pamphlet or information on how to 

obtain a copy of it. (Existing regulations require the distribution of a lead hazard information 

pamphlet, and the associated recordkeeping, before renovations in all target housing. This burden 

is reflected in EPA ICR No. 1669, Lead-Based Paint Pre-Renovation Information Dissemination 

– TSCA Sec. 406(b), and is approved under OMB Control No. 2070-0158.) The reporting and 

recordkeeping requirements are necessary to provide EPA compliance monitoring and 

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

inspections. The Agency believes that the distribution of the pamphlet will help to further reduce 

exposures that can cause serious lead poisonings in children under age six, who are particularly 

susceptible to the hazards of lead. Under the rule, firms would be required to provide information 

regarding compliance with the 2008 RRP rule to owners and occupants of target housing and 

child-occupied facilities. 

Training providers. Training programs seeking to offer training for renovators or dust sampling 

technicians must obtain EPA/State accreditation. In order for EPA/States to have the information 

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

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

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

Agency 1) prior to providing training courses, and 2) following completion of training courses. 

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

requirements are necessary to provide EPA compliance monitoring and enforcement personnel 

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

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

lead-based paint activities to ensure that individuals engaged in such activities are properly trained; that 

training programs are accredited; and that contractors engaged in such activities are certified. Such 

regulations shall contain standards for performing lead-based paint activities, taking into account 

reliability, effectiveness and safety.” 

Section 402(a)(2) states that “Final regulations promulgated under [section 402(a)] paragraph (1) 

shall contain specific requirements for the accreditation of ... training programs ... including, but not 

limited to:

- Minimum requirements for the accreditation of training providers;

- Minimum training curricula requirements;

- Minimum training hour requirements;

- Minimum hands-on training requirements;

- Minimum training competency and proficiency requirements;

- Minimum requirements for training program quality.”

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

renovation and remodeling activities that create lead-based paint hazards. Section 407 of TSCA states 

that regulations shall include such recordkeeping and reporting requirements as may be necessary to 

ensure effective implementation
April 26, 2010 Page 3 of 38

The Agency’s amendments to the regulations issued under Sections 402(a), 402(c)(3), 404, and 

407 fulfill these statutory mandates.

2(b) Practical Utility/Users of the Data

Owners and Occupants of Target Housing and Child-occupied Facilities

The rule will require renovation firms to provide training and work practice information to the 

owners and occupants of target housing and child-occupied facilities in a short, easily-read checklist or 

other form. This third-party notification will serve to reinforce the information provided by the lead 

hazard information pamphlet that renovation firms provide to these persons before beginning renovations 

covered by this rule. By addressing the significant training and work practice provisions of the RRP rule, 

this information will enable building owners and occupants to better understand what the renovation firm 

did to comply with the rule and how the rule’s provisions affected their specific renovation. Educating 

the owners and occupants in this way is likely to improve their ability to assist the EPA in monitoring 

compliance with the RRP rule.

EPA

This information collection will provide EPA with the materials necessary to serve as the 

accrediting and certifying body in States without authorized renovation programs.

EPA/States

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

requirements for renovation-specific training, certification, accreditation, and work practice standards. 

Without this collection, there would be no meaningful way of ensuring the implementation of the 

statutory objective: to ensure that trained individuals conduct renovations in such a way as to minimize 

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

relying on guidance and training to help renovators determine the best approaches to minimizing exposure 

to lead-based paint hazards created during renovation activities. The Agency believes this is the best 

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

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

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

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

keep track of which individuals have received accredited renovator training. This information will be a 

critical part of EPA’s compliance monitoring and enforcement activities.

It is also important to note that the re-accreditation requirements for training programs are meant 

to ensure that training programs incorporate new developments and technologies in their courses and that 

individuals receive training in them. The Agency believes this will ensure that individuals and firms 

conduct renovation activities in the safest and most effective manner possible.

The records renovation firms have to compile and retain are necessary as a reference for building 

owners/occupants, EPA or authorized entities. The records demonstrate that individuals conducting the 

activities do so in a safe and effective manner, according to the minimum work practice standards 

established by the rule. These recordkeeping requirements are also necessary to permit the Agency to 

target its enforcement activities and to ensure compliance within the contracting and training community.
April 26, 2010 Page 4 of 38

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

The Agency’s collection pursuant to the TSCA 402/404/406/407 regulations does not duplicate 

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

associated State program approval process, and there are currently no other Federal requirements for the 

training and certification of individuals engaged in these activities, for the accreditation of training 

programs, required standards for the conduct of these activities, or lead hazard information distribution 

requirements for renovations in child-occupied facilities.

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

The notice of final rulemaking served as the public notice for this ICR addendum. Interested 

parties submitted comments. Responses were taken into account in developing the final rulemaking.

3(c) Consultations

During the development of the 2008 RRP rule, the Agency consulted with a broad range of 

interested parties, including States, training providers, renovation contractors, and advocacy groups. 

More information on EPA’s consultations with stakeholders can be found in the preamble to the 2006 

RRP proposal and the preamble to the supplemental notice. Summaries and transcripts of meetings with 

stakeholders can be found in the rulemaking docket (EPA-HQ-OPPT-2005-0049).

3(d) Effects of Less Frequent Collection

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

particular, each firm must obtain certification and re-certification, each training program must provide 

specific notification and documentation prior to commencement and upon completion of each course, and 

each renovation activity is a separate and unique event requiring specific documentation.

3(e) General Guidelines

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

maintain records for three years and training providers to maintain records for three and one-half years.

3(f) Confidentiality

Neither the existing regulations nor the rule amendments address questions of a confidential 

nature.

3(g) Sensitive Questions

Neither the existing regulations nor the rule amendments address questions of a sensitive nature.
April 26, 2010 Page 5 of 38

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

Respondents for the reporting, third-party notification and recordkeeping requirements of this rule 

include: 1) firms and individuals engaged in residential renovations, 2) firms and individuals engaged in 

renovations in child-occupied facilities, and 3) training programs providing training services in lead-based 

paint activities and renovations. The North American Industrial Classification System (NAICS) codes 

associated with industries most likely affected by the paperwork requirements covered in the existing ICR

and this addendum are described below:

236118 Residential Remodelers

238210 Electrical Contractors

238220 Plumbing, Heating, and Air-Conditioning Contractors

238320 Painting and Wall Covering Contractors

238350 Finish Carpentry Contractors

238310 Drywall and Insulation Contractors

238170 Siding Contractors

238340 Tile and Terrazzo Contractors

238150 Glass and Glazing Contractors

238390 Other Building Finishing Contractors

238290 Other Building Equipment Contractors

531110 Lessors of Residential Buildings and Dwellings

531311 Residential Property Managers

541330 Engineering Services

541350 Building Inspection Services

611110 Elementary and Secondary Schools

611519 Other Technical and Trade Schools

624410 Child Day Care Services

4(b) Information Requested

The existing renovation regulations specify reporting and record keeping for training providers 

and individuals/firms undertaking renovation activities. The rule is expected to increase the number of 

firms and renovators expected to seek certification and training.

(i) Data Items

Training Providers

To comply with the Renovation, Repair, and Painting rule, training providers must notify EPA 

both before offering each course (to facilitate EPA’s enforcement activities) and after each course (so 

EPA has a record of the individuals who have completed the course). Training providers must use either 

the sample form entitled “Lead-Based Paint Activities and Renovation Training Notification” or a similar 

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

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

related burden and costs, associated with CDX user registration are described in another ICR that is 

currently approved by OMB under OMB Control No. 2025-0003.) The initial notice must include the 

following:

- Notification type (Original, Updated, Cancellation);

- Training program name, EPA accreditation number, address, and phone number;
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- Course discipline, type (initial/refresher), and the language in which instruction will be 

given;

- Date(s) and time(s) of training;

- Training location(s) phone number, and street address;

- Principal instructor’s name; and 

- Training manager’s name and signature.

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

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

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

courses, training providers must provide notice using either the sample form, entitled “Lead-Based Paint 

Activities and Renovation Post-Training Notification” or a similar form containing the required 

information. Training providers may provide electronic submissions using the Agency’s CDX. The 

notice must include the following:

- Training program name, EPA accreditation number, address, and phone number;

- Course discipline and type (initial/refresher);

- Date(s) of training;

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

o Name

o Address

o Date of birth

o Digital photograph

o Course completion certificate number

o Student test score

o Training manager’s name and signature

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

take a digital photograph of each trainee and submit it to EPA along with its training course follow-up 

information.

Training course providers must maintain the following records:

- Records demonstrating the qualifications of the training manager and the 

principal instructor(s);

- Current curriculum and course materials;

- Course test blueprints;

- Information on how hands-on assessments are conducted;

- Quality control plan;

- Results of students’ hands-on assessments and course test;

- Record of each student’s course completion certificate. 

Firms

The rule is expected to increase demand for certified firms, and therefore more firms are expected 

to seek certification to conduct renovation, repair and/or painting activities involving lead-based paint. 

To obtain certification firms must submit specific materials to EPA/State, using either the sample EPA 

Form 8500-27R entitled “Application for Firms to Conduct Renovations” or a similar form containing the 

required information:

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

field held by the firm;
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- Explanation of any violations related to lead-based paint;

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

individuals and that its employees will follow the specified work practice standards.

On occasion, firms may later amend their application to add or modify information. Certified 

firms must apply for re-certification every five years.

Firms performing renovations in target housing and child-occupied facilities in public or 

commercial buildings must provide lead hazard information pamphlets to property owners and tenants or 

child-occupied facility representatives. Firms must also either (i) provide the pamphlet and general 

information on the renovation to parents or guardians of children under age 6 using the facility, or (ii) 

erect signs that provide general information on the renovation accompanied by the pamphlet or 

information on how to obtain a copy. Firms must prepare and maintain documentation providing proof 

that pamphlets were provided to building owners and child-occupied facility representatives, or that an 

attempt was made to provide the pamphlets. Examples of such documentation include signed 

acknowledgment forms, self-certifications for failed deliveries, and postal receipts for mailings. Firms 

must also document their activities with respect to the notification of parents and guardians of childoccupied facilities. For example, the firm could prepare a signed, dated description of the notification 

activities performed in connection with a particular renovation.

In addition, firms conducting renovations are required to maintain records demonstrating 

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

posting signs, containing the renovation work area, cleaning the renovation work area, and performing a 

post-renovation cleaning verification or dust clearance testing after the renovation activity has been 

completed. The rule will require these firms to give owners and if different, the occupants a checklist 

indicating that the firm complied with the rule requirements.

(ii) Respondent Activities

The rule is expected to increase the number of renovators that require training. Training 

providers will perform the following activities for the additional trainees that will seek renovation 

training:

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

- Provide notice of completion of all courses offered;

- Retain records; and

- Provide accrediting entity access to records as requested.

The rule is expected to increase the number firms seeking certification. Firms perform the 

following activities:

- Read the regulations;

- Submit applications for certification; 

- Provide lead hazard information pamphlets to building owners and child-occupied facility 

operators and make them available to parents/guardians; and

- Prepare and retain records. 

The rule will also require all firms to complete the checklist and provide it to the owner and if different, 

the occupant of the target housing or child-occupied facility.
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5. Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

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

- Receive, review, and file initial, update, and course completion notices and 

digital photographs of trainees from training providers; and

- Receive, review, and act on applications for certification from renovation firms.

5(b) Collection Methodology and Management

For purposes of this rule, the Agency will make use of existing technology to simplify the 

application and notification process where possible. In addition to the more traditional methods (mail, 

commercial delivery service, or hand delivery), the Agency would accept fax and e-mail course 

notifications from training providers as well as notifications through the Central Data Exchange (CDX). 

E-mail notification would have to be followed by a written notification for the record, but the original email notice would satisfy the applicable notification time requirements. In addition, firms may use CDX 

to apply for certification and re-certification.

5(c) Small Entity Flexibility

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

businesses. As part of the development process for the 2008 RRP rule, the Agency convened a Small 

Business Advocacy Review Panel under the Regulatory Flexibility Act. More information on the Panel, 

and the Agency’s assessment of the impacts on small businesses, can be found in the preamble to the 

2008 RRP rule. 

5(d) Collection Schedule

For certification, and accreditation, collection activities will occur according to the following 

schedule:

- Training programs submit notification of training to EPA;

- Training programs submit post-training notification to EPA;

- Firms may apply for certification at any time;

- Firms must seek re-certification at five-year intervals following initial certification.

The Agency believes that receipt of notification 7 business days prior to conducting training courses is 

necessary to facilitate the inspection of training locations. The regulation also includes provisions for 

updating the original notification. The Agency determined that the time periods for initial notification 

will also apply to a change in course location, or if the course is to be presented earlier than described in 

the original notification. Other changes, including cancellation of courses, need only be received by the 

Agency at least 2 business days before a training course is scheduled to begin. Such notification periods 

are appropriate to allow proper allocation of EPA compliance monitoring and enforcement resources, and 

to prevent the arrival of Agency personnel at the wrong location or time.
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6. Estimating The Burden And Cost

This section estimates the incremental burden of reporting and recordkeeping for the revisions to 

the 2008 lead renovation, repair, and painting program final rule (73 FR 21692), also known as the RRP 

or LRRP rule. This burden is incremental to the burden already accounted for in the existing, approved 

ICR (EPA ICR No. 1715.10). The estimates of the number of entities subject to the rule’s requirements 

and the unit burden and cost of the requirements were taken from the ICR supporting statement Final 

Rule Addendum to an Existing EPA ICR Entitled: TSCA Sections 402/404 Training and Certification, 

Accreditation, and Standards for Lead-Based Paint Activities (EPA ICR No. 1715.10, OMB 2070-0155), 

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

Target Housing and Child-Occupied Facilities, also referred to as the Economic Analysis for the Final 

Rule, and from the Economic Analysis for the TSCA Lead Renovation, Repair and Painting Program OptOut and Recordkeeping Final Rule for Target Housing and Child-Occupied Facilities (EPA 2008, 2010). 

This supporting statement provides burden and cost estimates for the first three years of the program. All 

costs are presented in year 2005 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 demand for certified firms and renovators is predicted to increase as a result of the 

elimination of the opt-out provision, and therefore more firms and renovators are predicted to seek 

certification and training as a result of the revisions. Separate impacts are estimated for these firms and 

individuals that would not have otherwise sought certification and training without the elimination of the 

opt-out provision. Hereafter these entities are referred to as “opt-out entities.” Likewise, those firms and 

individuals that would have sought certification and training without the elimination of the opt-out 

provision are referred to as “currently regulated entities.” The impacts of the revisions to the rule on the 

opt-out entities include all the costs associated with the requirements of the revised LRRP rule. In 

contrast, the only impacts of the revisions on the currently regulated entities are those associated with the 

recordkeeping requirement that renovation firms provide owners and occupants with a copy of the records 

demonstrating compliance with the training and work practice requirements of the RRP rule. This 

requirement is hereafter referred to as the “recordkeeping checklist requirement”.

6(a) Estimating Respondent Burden

Two types of respondents will be affected by this information collection request: training 

providers and entities performing renovation, repair, and painting activities.1 The paperwork burden 

associated with reporting and recordkeeping for these two types of respondents is estimated separately. 

The reporting estimates include the time associated with reviewing instructions, collecting the 

information needed to complete the notification form, and completing and sending the notification forms 

to the appropriate authority. The recordkeeping burden estimates include the time required for the 

respondent to file a record of the information.

 

1

The rule allows for the training and use of a sampling technician to perform dust clearance testing following a 

renovation instead of performing cleaning verification. Because dust clearance testing is substantially more 

expensive than the cleaning verification, EPA expects few buildings to have dust clearance testing performed. Since 

the frequency of dust clearance testing is expected to be low, and therefore not to have a significant cost impact, this 

analysis assumes that cleaning verification is always performed instead of dust clearance testing.
April 26, 2010 Page 10 of 38

Training Providers

To comply with the Renovation, Repair, and Painting rule, training providers must gain 

accreditation and keep records on both the courses they provide and the students they train. They must 

notify EPA both before offering each course (to facilitate EPA’s enforcement activities) and after each 

course (so EPA has a record of the individuals who have completed the course). 

It is assumed that enough training providers will become accredited under the 2008 LRRP rule to 

cover the increased demand from RRP firms seeking certification and training as a result of the 

elimination of the opt-out provision. Therefore, it is estimated that no new training providers will become 

accredited as a result of the revisions. However, these training providers will have to offer more courses

due to the increased demand which will result in incremental notification costs.

Under the rule, pre-course notification is required at least 7 business days prior to the start of a 

lead-based paint activities course. Re-notification is required if the course date changes. Within 10 days 

of course completion, training providers are required to submit a post-course notification. The following 

sections discuss how the reporting and recordkeeping burden estimates in this analysis were developed. 

Exhibit 6.1 presents the estimation of Training Provider burden for course notifications.

This analysis assumes that training providers will complete a separate notification form for each 

lead-based paint activity course conducted. The number of pre-course and post-course notification events 

was estimated by dividing the total number of students in a given year by an estimated average class size 

of 25 students and the estimated number of training providers. (See the Economic Analysis of the 2008 

LRRP rule (EPA 2008) for details.) The numbers of notification events were rounded upwards to reflect 

the possibility that some courses will be under subscribed. There is one pre-notification and one postnotification for each training course, with an average burden of 0.15 and 1.54 hours each. (Postnotifications are more time consuming because the Training Provider must send records pertaining to 

each student who attended the course.) In addition, some courses may require re-notification. Renotification events are calculated based on notification events in the FLPP database. Re-notifications 

occur for approximately 12 percent of original pre-course notifications, and are also estimated to require 

0.15 hours of time. Estimates of the amount of time required to complete the pre-course and post-course 

notification forms are determined in the existing approved ICR. 

The training provider burden estimates described above also include the recordkeeping burden 

associated with filing a one page record of the notification form sent to the administering agency. An 

estimate of the amount of time needed to file a record was adopted from the existing approved ICR, and is 

estimated to be 0.01 hours per training event.

Training providers are also required to take a digital photo of each certified renovator upon initial 

and refresher training. The estimated time burden associated with taking and processing each photo is 3 

minutes per photo (EPA 2008), or 1.25 hours per training course of 25 individuals.

As presented below in Exhibit 6.2, the burden for all training providers is estimated to be 15,127

hours in Year 1 of the regulation, 3,007 hours in Year 2, and 2,977 hours in Year 3. (The burden drops 

to reflect the decrease in the number of renovators needing training each year, since initial training is 

generally only needed for new entrants to the market and retraining is only required every five years.) 

The average annual aggregate burden for training providers over the three years covered by this ICR is 

7,037 hours.
April 26, 2010 Page 11 of 38

Exhibit 6.1 Training Providers: Notification Burden

Category Events per Training Provider Reporting

Hours/Event

Recordkeeping

Hours/Event

Total 

Year 1 Year 2 Year 3 Avg. Hours/Event

Pre-notification 30 6 6 14 0.15 0.01 0.16

Re-notification 4 1 1 2 0.15 0.01 0.16

Post-notification 30 6 6 14 1.54 0.01 1.55

Digital Photo 30 6 6 14 1.25 0.00 1.25

Annual Total 94 19 19 44

Notification Burden Hours per Training Provider

Year 1 Year 2 Year 3

90 18 18

Training Providers per Year

Year 1 Year 2 Year 3

168 167 166

Total Notification Burden Hours per Year

Year 1 Year 2 Year 3

15,127 3,007 2,977 

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

Exhibit 6.2 Total Training Provider Burden

Year 1 Year 2 Year 3 Average

Total Burden 15,127 3,007 2,977 7,037

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 

2010).

Renovation, Repair, and Painting Firms: Certification-Related Burden

Under the revisions to the renovation, repair, and painting (RRP) rule, firms wishing to conduct 

renovations in opt-out housing would be required to apply for certification.2 They would also be required 

to keep records reflecting RRP events conducted by trained employees. This ICR presents the costs to 

firms seeking certification as a result of the elimination of the opt-out provision. 

It is estimated that firms that become certified under the rule will spend a total of three hours 

familiarizing themselves with the rule’s requirements when they are initially certified. They will spend 

another half an hour filling out and mailing the Application for Firm Certification each time they are 

certified or re-certified. (Re-certification is required every five years.) As shown in Exhibit 6.3, 111,426 

firms are estimated to become certified in the first year as a result of the rule. In the second year, 22,193

firms will become certified (19,974 initial certifications and 2,219 re-certifications). When combined 

with the 88,775 firms still operating that are already certified, this yields a total of 110,968 certified firms. 

 

2 Only target housing contractors would be affected by the elimination of the opt-out provision. 
April 26, 2010 Page 12 of 38

In the third year, 22,103 firms will become certified (19,893 initial certifications and 2,210 recertifications). When combined with the 88,411 firms still operating that are already certified, this yields 

a total of 110,514 certified firms. The number of firms certified each year is calculated in the Economic 

Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

Averaged across three years, there are an estimated 110,969 opt-out entities operating annually, 

all of which are private firms. Small businesses comprise 110,672 of these firms.

Additionally, all RRP firms, regardless of whether they are applying for certification in a given 

year, will spend time keeping records of RRP work. An estimate of the amount of time needed to file a 

record was adopted from EPA ICR No. 1715.07. On average, RRP firms will spend 4.8 hours on 

recordkeeping per year. This is based on a burden of 5 minutes per response and an average of 58 

responses per firm. The number of events per firm is estimated in the Economic Analysis for the Opt-Out 

and Recordkeeping Final Rule (EPA 2010).

In the first year, it is assumed that the number of firms that seek certification is equal to the 

number that is necessary to meet the demand for lead-safe RRP services in that first year. From the 

second year on, this analysis makes the simplifying assumption that one fifth of the number of firms 

certified in the first year seek initial- or re-certification year (since re-certification is required every five 

years). The number of certifications is assumed to decline by 0.41 percent annually to reflect the decline 

in the pre-1978 housing stock

As indicated above, this analysis assumes a steady annual number of firm certifications after the 

second year of regulation. If all the firms needed to meet the demand for lead-safe RRP were certified in 

the first and second years, one might expect a drop in the level of certification in the third year, followed 

by a spike in the next year. That is, one might expect a cyclical pattern of training and certification to 

emerge. However, it is difficult to predict how cyclical training and certification demand might be, or 

how this cyclicality might diminish over time. Therefore, this analysis assumes that a typical amount of 

certification occurs each year after the first two years because modeling a cyclical component would add 

little to the analysis without being able to estimate the extent of any cyclicality more precisely.

This analysis accounts for turnover in the regulated RRP industry by assuming a certain 

percentage of certifications each year are initial certifications. Specifically, after the first year, 90 percent 

of firms seeking certification are assumed to be seeking their initial certification based on the relative 

annual average frequency of initial certifications observed for abatement firms in FLPP database.

As presented below in Exhibit 6.4, this amendment estimates the burden for all opt-out firms 

conducting renovations in Year 1 to be 924,836 hours for all entities. The burden is estimated to be 

603,665 hours for all opt-out firms in Year 2, and 601,198 hours in Year 3 (reflecting the decrease in the 

number of opt-out firms needing certification, since re-certification is only required every five years). 

There is an annual average of 709,899 hours during the three year period covered by this ICR. This 

yields an average burden of 6.4 hours per year for opt-out RRP firms. 
April 26, 2010 Page 13 of 38

Exhibit 6.4: Average Annual Number of Certifications and Burden per Response

Number of Small 

Respondents

Number of 

Respondents

Burden per 

Response (hours)*

Private Firms

Initial Certification 50,296 50,431 8.3

Recertification 1,472 1,476 5.3

No Certification 58,904 59,062 4.8

Total 110,672 110,969

Note(s): * Includes annual recordkeeping time of 4.8 hours.

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

Total Certification/Recordkeeping Burden- Hours

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

Year 1 Year 2 Year 3 Average

Rule Familiarization 334,278 59,922 59,679 151,293

Certification Form 55,713 11,097 11,052 25,954

Recordkeeping 534,845 532,646 530,467 532,653

Total 924,836 603,665 601,198 709,899

Note(s): Numbers may not calculate due to rounding. Re-certification required every five years. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

Renovation, Repair, and Painting Firms – Burden Related to Recordkeeping Checklist

Under the revisions to the 2008 LRRP rule, all renovation firms are required to provide a copy of 

the records demonstrating compliance with the training and work practice requirements of the RRP rule to 

the owner and, if different, the occupant of the building being renovated or the operator of the childoccupied facility. Firms performing work in owner-occupied target housing would be required to 

distribute one copy of the checklist while firms performing work in renter-occupied target housing would 

be required to provide a copy each to the owner and the occupant. If the work occurs in the common area 

of an apartment building, the checklist, or information on how to obtain the checklist, must be posted on a 

Exhibit 6.3 Number of Certified Firms

Year 1 Year 2 Year 3 Average

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

Receiving Initial Certification 111,426 19,974 19,893 50,431

Receiving Re-Certification 0 2,219 2,210 1,476

Subtotal: Firms Receiving 

Certification or Re-Certification 111,426 22,193 22,103 51,907

Already Certified - Not Receiving 

Certification or Re-Certification 0 88,775 88,411 59,062

Total 111,426 110,968 110,514 110,969

Certification/Re-Certification/Recordkeeping Burden- Hours Per Firm

Certification Year

Re-Certification 

Year Other Years

Rule Familiarization 3 0 0

Certification Form 0.5 0.5 0

Recordkeeping 4.8 4.8 4.8

Total 8.3 5.3 4.8
April 26, 2010 Page 14 of 38

sign in the common area or delivered to each of the affected units. (This analysis always assumes that a 

sign will be posted.) Child-occupied facilities that perform work themselves must post the checklist, or 

information on how to obtain the checklist, on a sign that is accessible to parents or guardians of the 

children or mail this information to these individuals. Similarly, landlords that perform work would have 

to supply one copy of the checklist attached to a sign in the area where the work is being performed or 

provide a copy to each affected unit. Contractors who perform work in owner-occupied COFs must 

provide two copies of the checklist: one copy to the owner of the COF and one copy to be posted on a 

sign in the COF (they may also choose to mail this information to the parents or guardians). In addition 

to the two copies required in owner-occupied events, contractors working in renter-occupied COFs must 

also provide the operator of the COF with a third copy of the checklist.

Number of RRP Firms and Events Performed

All RRP firms are required to comply with the recordkeeping checklist provision during each 

RRP event they perform. As discussed in detail in Section 4.4 of the Economic Analysis for the Opt-Out 

and Recordkeeping Final Rule (EPA 2010), 323,147 entities (111,426 opt-out and 211,721 currently 

regulated) are expected to perform RRP events in Year 1. Exhibit 6.5 presents the number of opt-out and 

currently regulated firms that are expected to incur costs as a result of the recordkeeping checklist 

provision and elimination of the opt-out provision. Exhibit 6.5 also presents the estimated number of 

events these firms will perform. Events are presented in groups based on the number of checklist copies 

required for each type of event. 

Exhibit 6.5: Number of Opt-Out and Currently Regulated Firms and RRP Events

Year 1 Year 2 Year 3

Number of RRP Firms

RRP Entities Certified as a Result of 

Eliminating the Opt-Out Provision 111,426 110,968 110,514

RRP Entities Regulated under the 2008 

LRRP Rule 211,721 210,853 209,989

Total - All Entities 323,147 321,821 320,503

Number of RRP Events

Events as a Result of Eliminating the Opt-Out Provision

Owner Target Housing 7,271,555 7,241,742 7,212,050

Events Currently Regulated under the 2008 LRRP Rule

Owner Target Housing 1,459,940 1,453,954 1,447,993

Renter Target Housing 9,572,191 9,532,945 9,493,860

In-House/Landlord a100,056 99,646 99,238

Owner COF Contractor b267,534 266,437 265,344

Renter COF Contractor c12,900 12,847 12,794

Subtotal – Currently Regulated Events 11,412,621 11,365,829 11,319,229

Total - All Events 18,684,176 18,607,571 18,531,280

Source(s): Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

a. RRP is performed by the owner of a public or commercial building.

b. RRP is performed by a contractor in an owner-occupied public or commercial building.

c. RRP is performed by a contractor in a renter-occupied public or commercial building.

Exhibit 6.6 shows the three-year average annual number of respondents to the recordkeeping 

checklist requirements. During the three year span of this ICR, it is estimated that an average of 110,969

private firms, of which 110,672 are small, will seek certification as a result eliminating the opt-out 

provision. An additional 210,855 currently regulated entities, of which 207,340 are small, are estimated 

to incur costs of complying with the checklist provision requirements.
April 26, 2010 Page 15 of 38

Exhibit 6.6: Average Annual Number of Recordkeeping Checklist Respondents, Responses 

per Respondent, and Burden per Response

Number of 

Small 

Respondents

Number of 

Respondents

Responses 

per 

Respondent

Burden per 

Response 

(hours)

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Private Entity 110,672 110,969 65.26 0.05

State/Local Gov 0 0 0.00 0

Entities Currently Regulated by the 2008 LRRP Rule

Private Entity 200,202 203,105 55.65 0.05

State/Local Gov 7,138 7,750 8.13 0.05

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

Estimated Burden per Event

All renovation firms are required to provide a copy of the records demonstrating compliance with 

the training and work practice requirements of the RRP rule to the owner and, if different, the occupant of 

the building being renovated or the operator of the child-occupied facility. 

This analysis estimates the per-event burden of preparing photocopies and distributing the 

checklist. It is estimated that it will take entities performing RRP jobs an average of three minutes to 

photocopy and distribute the checklist.

Estimated Total Burden

Exhibit 6.7 presents the total burden and cost to respondents resulting from the recordkeeping 

checklist requirements. Total respondent burden was estimated by multiplying the numbers of RRP 

events by the corresponding per event burden estimates.

Exhibit 6.7: Total Recordkeeping Checklist Provision Burden Due to the Rule 

Total Burden Hours

Year 1 Year 2 Year 3

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Owner Target Housing 363,578 362,087 360,603

Entities Currently Regulated by the 2008 LRRP Rule

Owner Target Housing 72,997 72,698 72,400

Renter Target Housing 478,610 476,647 474,693

In-House/Landlord a5,003 4,982 4,962

Owner COF Contractor b13,377 13,322 13,267

Renter COF Contractor c645 642 640

Subtotal – Currently Regulated Events 570,631 568,291 565,961

Total - All Events 934,209 930,379 926,564

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).
April 26, 2010 Page 16 of 38

6(b) Estimating Respondent Costs

Introduction

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 based on wage rate information from the 

Bureau of Labor Statistics (BLS)3. Following are the wage rates used in this analysis, which are fully 

loaded (i.e., include fringe benefits and overhead), and are in 2005 US dollars4:

Training Provider Clerical Time $23.54/hr

RRP Firm Wage Rate $31.64/hr5

Training Providers

The loaded wage rate for training provider clerical staff is $23.54 per hour. Clerical staff will 

prepare and mail notifications and will perform recordkeeping activities. Training provider costs also 

include $0.37 per postage stamp and $0.02 per envelope for mailing notifications and $0.08 per one page 

copy of each notification for the firm’s records. Training providers are also required to take a digital 

photo of each renovator receiving certification. The use of a one-time digital camera costs $20.58 per 25 

photos and takes approximately three minutes per photo or 1.25 hours per 25 photos.

Exhibit 6.8 estimates the annual cost for training provider notifications. As shown in Exhibit 6.9, 

total training provider costs are estimated to be $465,625 in the first year of the rule, $92,571 in the 

second year, and $91,639 in the third year. The average annual cost over the three years covered by the 

ICR is $216,612. This yields an average cost of $1,297 per training provider.

 

3

U.S. Bureau of Labor Statistics. 2005. Occupational Employment Statistics Series.

4

Firm Wage Rates were Inflated from 2004 US dollars to 2005 US dollars the BLS Employment Cost Index for the 

Construction Industry.

5 Certified renovators’ fully loaded wages ($31.64/hour) are estimated from BLS wage data for First-Line 

Supervisors/Managers of Construction Trades and Extraction Workers (Occupation 47-1011) who work in the 

residential building construction industry. Wages are fully loaded to account for fringe benefits with an average 

fringe rate for the construction industry of 23.5 percent.
April 26, 2010 Page 17 of 38

Exhibit 6.8 Training Providers: Notification Cost Estimates

Category Events per Training Provider Reporting

Cost/Event

Recordkeeping

Cost/Event

Materials 

Cost/Event

Total

Year 1 Year 2 Year 3 Avg. Cost/Event

Pre-notification 30 6 6 14 $3.53 $0.24 $0.47 $4.24

Re-notification 4 1 1 2 $3.53 $0.24 $0.47 $4.24

Post-notification 30 6 6 14 $36.25 $0.24 $0.47 $36.96

Digital Photo 30 6 6 14 $29.43 $0.00 $20.58 $50.00

Cost per Training Provider

Year 1 Year 2 Year 3

$2,772 $554 $552

Training Providers per Year

Year 1 Year 2 Year 3

168 167 166

Total Cost per Year

Year 1 Year 2 Year 3

$465,625 $92,571 $91,639

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010); EPA ICR No. 1715.07; 

and U.S. Bureau of Labor Statistics Occupational Employment Statistics Series (2005). 

Exhibit 6.9 Total Training Provider Costs - 2005 Dollars

Year 1 Year 2 Year 3 Average

Total Notification Cost $465,625 $92,571 $91,639 $216,612

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 

2010); EPA ICR No. 1715.07; and U.S. Bureau of Labor Statistics Occupational 

Employment Statistics Series (2005). 

RRP Firms – Costs Related to Certification

The elimination of the opt-out provision is expected to increase the number of firms seeking 

certification. This ICR accounts for the burden and costs associated with these additional firms seeking 

certification. The average cost associated with initial certification is $111 per response, based on a 

response time of 3.5 hours and a loaded renovator wage rate of $31.64. The average re-certification cost 

per response is about $16. In addition to labor costs, firm certification costs also include $0.37 per 

postage stamp and $0.02 per envelope for mailing notifications and $0.08 per one page copy of each 

notification for the firm’s records. (Costs have not been updated from 2005 dollars in order to facilitate 

comparison with previous information collection requests, which were also in 2005 dollars. Consistent 

with this, postage costs have not been updated to 2009.) All firms incur a recordkeeping cost of $152 per 

response.
April 26, 2010 Page 18 of 38

As presented below in Exhibit 6.10, based on the burden estimates provided in section 6(a) and 

the wage rates discussed above, the costs associated with certification applications for all opt-out firms 

conducting renovations is estimated to be $29,323,089 in Year 1, $19,112,164 in Year 2, and $19,034,052

in Year 3. The average annual cost for these opt-out entities is $22.5 million over the three years covered 

by this ICR, resulting in an average cost per opt-out firm of $203. 

Exhibit 6.10 Opt-Out Firms: Certification Cost Estimates

Number of Firms

Year 1 Year 2 Year 3

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Receiving Initial Certification 111,426 19,974 19,893

Receiving Re-Certification 0 2,219 2,210

Subtotal: Firms Receiving 

Certification or Re-Certification 111,426 22,193 22,103

Already Certified - Not Receiving 

Certification or Re-Certification 0 88,775 88,411

Total 111,426 110,968 110,514

Total Certification/Recordkeeping Costs - 2005 Dollars

Year 1 Year 2 Year 3 Average

RRP Entities Certified as a Result of Eliminating the Opt-Out Provision

Rule Familiarization $10,576,556 $1,895,932 $1,888,244 $4,786,911

Certification Form $1,762,759 $351,093 $349,669 $821,174

Recordkeeping $16,922,489 $16,852,932 $16,783,982 $16,853,135

Material Costs $61,284 $12,206 $12,157 $28,549

Total $29,323,089 $19,112,164 $19,034,052 $22,489,768

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010); EPA 

ICR No. 1715.07; and U.S. Bureau of Labor Statistics Occupational Employment Statistics Series (2005). 

RRP Firms – Costs Related to Recordkeeping Checklist Provision

Under the revisions to the 2008 LRRP rule, all renovation firms are required to provide a copy of 

the records demonstrating compliance with the training and work practice requirements of the RRP rule to 

the owner and, if different, the occupant of the building being renovated or the operator of the childoccupied facility. This additional requirement would pertain to all firms, those regulated under the 2008 

LRRP rule as well as those that would not have otherwise sought certification and training without the 

elimination of the opt-out provision. Firms performing work in owner-occupied target housing would be 

required to distribute one copy of the checklist while firms performing work in renter-occupied target 

housing would be required to provide a copy to the owner and occupant. If the work occurs in the 

common area of an apartment building, the checklist, or information on how to obtain the checklist, must

be posted on a sign in the common area or delivered to each of the affected units. (This analysis always 

Certification/Re-Certification/Recordkeeping Cost per Firm - 2005 Dollars

Certification Year

Re-Certification 

Year Other Years

Average Cost Per Response

Rule Familiarization $94.92 $0.00 $0.00

Certification Form $15.82 $15.82 $0.00

Recordkeeping $151.87 $151.87 $151.87

Material Costs $0.55 $0.55 $0.00

Total $263.16 $168.24 $151.87
April 26, 2010 Page 19 of 38

assumes that a sign will be posted.) Child-occupied facilities that perform work themselves must post the 

checklist, or information on how to obtain the checklist, on a sign that is accessible to parents or 

guardians of the children or mail this information to these individuals. Similarly, landlords that perform 

work would have to supply one copy of the checklist attached to a sign in the area where the work is 

being performed or provide a copy to each affected unit. Contractors who perform work in owneroccupied COFs must provide two copies of the checklist: one copy to the owner of the COF and one copy 

to be posted on a sign in the COF (they may also choose to mail this information to the parents or 

guardians). In addition to the two copies required in owner-occupied events, contractors working in 

renter-occupied COFs must also provide the operator of the COF with a third copy of the checklist.

In addition to the time needed to prepare photocopies and distribute the checklist, entities 

performing RRP events will also incur the cost of photocopy materials. Based on per-page photocopy 

costs, EPA estimates that a single copy of the checklist costs $0.08. Exhibit 6.11 presents resulting perevent checklist costs. 

Exhibit 6.11 Number of Checklist Copies and Cost per Event

Target Housing Events Public and Commercial Building Events

Owner Renter

In-house / 

Landlord b

Contractor –

Owner c

Contractor –

Renter d

Labor Cost a

$1.58 $1.58 $1.58 $1.58 $1.58

Material Cost e

$0.08 $0.16 $0.08 $0.16 $0.24

Total Cost $1.66 $1.74 $1.66 $1.74 $1.82

a. Based on a burden of 3 minutes, at a wage rate of $31.64, based on Bureau of Labor Statistics (SOC 47-1011)

b. RRP is performed by the owner of a public or commercial building.

c. RRP is performed by a contractor in an owner-occupied public or commercial building.

d. RRP is performed by a contractor in a renter-occupied public or commercial building.

e. The average price of a photo copy at Copy Cop, Kinkos, Staples, and Office Max is eight cents.

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010).

Exhibit 6.12 presents the estimated total costs of the recordkeeping checklist provision to entities 

performing RRP events. RRP firms will incur time burden and material costs, presented in Exhibit 6.7

and Exhibit 6.11, respectively. To estimate total labor costs associated with the recordkeeping checklist, 

the total burden estimates in Exhibit 6.7 were multiplied by the loaded wage rate for clerical staff ($31.64 

per hour). Total pamphlet costs were estimated by multiplying the numbers of events in Exhibit 6.5 and 

by the corresponding per-event pamphlet cost estimates in Exhibit 6.11.
April 26, 2010 Page 20 of 38

6(c) Estimating Agency Cost

There are also government costs to administer the program. States, Tribes, and Territories are 

allowed, but are under no obligation, to apply for and receive authorization to administer these 

requirements. EPA will directly administer programs for States, Tribes, and Territories that do not 

become authorized. Because the number of States, Tribes, and Territories that will become authorized is 

not known, administrative costs are estimated assuming that EPA will administer the program 

everywhere. To the extent that other government entities become authorized, EPA’s administrative costs 

will be lower. States, Tribes, and Territories that choose to implement the rule themselves are expected to 

incur similar costs on a per-unit basis.

Under the preferred regulatory option, EPA will perform two tasks as part of administering the 

RRP program: certify firms and process training provider notifications. To reduce the burden on the 

Exhibit 6.12 Total Costs Associated with the Recordkeeping Checklist Provision

Year 1 Year 2 Year 3

Total Labor Cost

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

Owner Target Housing $11,503,600 $11,456,435 $11,409,464

Entities Currently Regulated under the 2008 LRRP Rule

Owner Target Housing $2,309,625 $2,300,156 $2,290,725

Renter Target Housing $15,143,206 $15,081,119 $15,019,286

In-House/Landlord $158,289 $157,640 $156,994

Owner COF Contractor $423,238 $421,503 $419,775

Renter COF Contractor $20,408 $20,324 $20,241

Subtotal $18,054,766 $17,980,742 $17,907,021

Total - All Entities $29,558,366 $29,437,177 $29,316,485

Total Materials Cost

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

Owner Target Housing $581,724 $579,339 $576,964

Entities Currently Regulated under the 2008 LRRP Rule

Owner Target Housing $116,795 $116,316 $115,839

Renter Target Housing $1,531,551 $1,525,271 $1,519,018

In-House/Landlord $8,005 $7,972 $7,939

Owner COF Contractor $42,805 $42,630 $42,455

Renter COF Contractor $3,096 $3,083 $3,071

Subtotal $1,702,252 $1,695,272 $1,688,322

Total - All Entities $2,283,976 $2,274,612 $2,265,286

Total Cost

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

Owner Target Housing $12,085,324 $12,035,775 $11,986,428

Entities Currently Regulated under the 2008 LRRP Rule

Owner Target Housing $2,426,420 $2,416,472 $2,406,564

Renter Target Housing $16,674,757 $16,606,390 $16,538,304

In-House/Landlord $166,294 $165,612 $164,933

Owner COF Contractor $466,044 $464,133 $462,230

Renter COF Contractor $23,504 $23,407 $23,311

Subtotal $19,757,018 $19,676,014 $19,595,343

Total - All Entities $31,842,342 $31,711,789 $31,581,771

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010); EPA ICR No. 

1669.04 (2004); U.S. Bureau of Labor Statistics Occupational Employment Statistics Series (2005); The 

average price of a photo copy at Copy Cop, Kinkos, Staples, and Office Max is eight cents.
April 26, 2010 Page 21 of 38

regulated community, EPA’s preferred option does not include formal certification for renovators or dust 

sampling technicians. 

Agency Cost of Processing Training Notifications

As it is estimated that no training providers will seek accreditation as a result of the revisions to 

the 2008 LRRP Rule, EPA will only incur the cost of processing notifications submitted by training 

providers prior to and following each course session. It is assumed that EPA technical staff with a fully 

loaded hourly wage of $34.696 will spend an average of two minutes processing each notification.

It is estimated that there will be 10,765 training notifications in Year 1, 2,140 in Year 2, and 

2,119 in Year 3. As shown in Exhibit 6.13, it will cost EPA $12,477 to process training notifications in 

the first year of the rule, $2,475 in Year 2, and $2,450 in Year 3. 

Exhibit 6.13 Total EPA Cost of Processing Training Notifications – 2005 Dollars

Year 1 Year 2 Year 3

Process Training Notification $12,447 $2,475 $2,450 

Total $12,447 $2,475 $2,450 

Note(s): Numbers may not calculate due to rounding. 

Sources: Economic Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010); U.S. 

Office of Personnel Management: 2005 General Schedule - Base Annual (OPM 2005).

Agency Costs of Certifying Renovation Firms

The revisions to the 2008 LRRP Rule will require opt-out renovation establishments to submit a 

completed application and fee. For the purpose of estimating costs, it is assumed that EPA Regions will 

incur variable processing costs, and fixed administrative and enforcement costs. Regional administrative 

activities include answering phone inquires from the public regarding the LRRP program, following up 

on the status of applications, providing information to other regions, coordinating with headquarters, and 

performing other customer service activities. Enforcement activities include conducting audits of training 

providers and firms. In addition, it is assumed that EPA Headquarters will incur fixed administrative 

costs related to coordination with regions and maintenance of the central database and registry. EPA 

Headquarters will also support enforcement activities.

Certification cost estimates are based on responses from a Time-Motion Study conducted in 

support of the 2009 Economic Analysis for the TSCA section 402 Lead-Based Paint Program 

Accreditation and Certification Fee Rule (i.e., the Fee Rule). In the Time-Motion Study, data were 

collected from three EPA Regions: Region 2, Region 4, and Region 9. Regions were asked to provide the 

number of hours and personnel required to process applications under the TSCA section 402(a) LeadBased Paint Activities program (i.e., the Abatement Rule). While TSCA section 402(a) defines training 

and certification requirements for five different categories of lead abatement professionals, the type of 

administrative activities associated with the TSCA section 402(a) rule are similar to those expected for 

the Renovation, Repair and Painting Rule. 

 

6 EPA used the Office of Personnel Management’s General Salary Table 2005-GS to estimate government employee 

wage rates. EPA used the wage for a GS-11, Step 1 employee and loaded the wage using the standard government 

multiplier of 1.6 to cover overhead and fringe benefits. 
April 26, 2010 Page 22 of 38

To estimate fees for the LRRP rule, EPA followed the approach used to estimate fees for the 

Abatement rule. To structure the fees, EPA first considered the variable and fixed costs associated with 

each applicant type. The variable costs reflect the regional processing costs for each application type. 

The fixed costs include the regional and headquarters administrative and enforcement costs, which apply 

across all the applications. EPA divided the total regional enforcement and administrative costs and the 

headquarters costs by the total estimated number of applicants over the five year projection period to 

obtain a fixed cost of $282 for training providers and firms. 

Fixed costs for renovators and sampling technicians were estimated by dividing the headquarters 

administrative costs by the total number of applicants over the five year period to obtain a fixed cost of 

$6. As renovators and sampling technicians are not required to obtain formal certification, their fixed 

costs are recouped by the fee charged to RRP firms. In addition, tribes will be charged a nominal fee ($20 

for firm applicants, and $10 for individual certifications) and firms applying for both an Abatement 

certification and a LRRP certification will only be charged for the more expensive Abatement 

certification. Firms that are ineligible for these discounts will be charged an additional $9 to cover the 

costs of the discounts. See the 2009 Fee Rule for an in-depth explanation of fee structure methodology 

and calculations. Exhibit 6.14 presents the fee schedule developed in the Economic Analysis for the Fees 

Rule. The actual fee charged to firms was rounded to $300; the rounded fee is used in subsequent 

calculations.

As described earlier in Exhibit 6.3, it is estimated that 111,426 firms would become certified in 

Year 1. In Year 2, 22,193 firms are expected to seek certification or re-certification, and in Year 3, 

22,103 firms are expected to be certified or re-certified. As shown in Exhibit 6.15, based on these 

estimates, it will cost EPA $33 million to certify these firms in Year 1. EPA’s costs for firm certifications 

are estimated to be less than $7 million in Years 2 and 3. 

Exhibit 6.15 Total Costs of Certifying Renovation Establishments

Year 1 Year 2 Year 3

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

Firms Seeking Certification 111,426 22,193 22,103 

Total Cost of Certification $33,427,800 $6,657,900 $6,630,900 

Note(s): Numbers may not calculate due to rounding. 

Sources: Analysis for the Opt-Out and Recordkeeping Final Rule (EPA 2010); The Economic 

Analysis for the TSCA section 402 Lead-Based Paint Program Accreditation and Certification 

Fee Rule (EPA 2009)

Exhibit 6.14 Fee Schedule for Certifying Renovation Establishments

Avg. 

Processing 

Cost Per 

Applicant Fixed Cost

Additional Fee 

(to cover costs 

of discounts) Total Fee

Estimated Initial Certification Fee $11 $282 $9 $301

Estimated Re-Certification Fee $12 $282 $9 $302

Actual Fee Charged $300 

Note(s): numbers may not calculate due to rounding. 

Sources: The Economic Analysis for the TSCA section 402 Lead-Based Paint Program Accreditation and 

Certification Fee Rule (EPA 2009)
April 26, 2010 Page 23 of 38

6(d) Bottom Line Burden Hours and Cost

The number of respondents is shown in Exhibit 6.16, and the number of responses in Exhibit 6.17. The 

respondent burden for the collection of notification information is shown in Exhibit 6.18. The annual 

paperwork burden over the first three years is estimated to average 1,647,321 hours. The average annual 

respondent cost for the collection of notification information is shown in Exhibit 6.19 and is estimated to 

be $54 million. The Agency cost is estimated to average $15.5 million per year, as shown in Exhibit 

6.20. 

Exhibit 6.16 Number of Respondents

Year 1 Year 2 Year 3 Average

Training Providers 168 167 166 167

Opt-Out Entities 111,426 110,968 110,514 110,969

Currently Regulated 

Entities 211,721 210,853 209,989 210,854

Total 323,315 321,988 320,669 321,991

Exhibit 6.18 Respondent Burden Hours

Year 1 Year 2 Year 3 Average

Training Providers 15,127 3,007 2,977 7,037

Opt-Out Firm 

Certification 924,836 603,665 601,198 709,899

Opt-Out Firm Checklist 363,578 362,087 360,603 362,089

Currently Regulated 

Checklist 570,631 568,291 565,961 568,295

Total 1,874,172 1,537,051 1,530,739 1,647,321

Exhibit 6.17 Number of Responses

Year 1 Year 2 Year 3 Average

Training Provider Notifications 10,765 2,140 2,119 5,008

Opt-Out Firm Initial Certifications 111,426 19,974 19,893 50,431

Opt-Out Firm Re-Certifications 0 2,219 2,210 1,476

Opt-Out Firm Checklist Events 7,271,555 7,241,742 7,212,050 7,241,782

Currently Regulated Firm Checklist 

Events 11,412,621 11,365,829 11,319,229 11,365,893

Total 18,806,367 18,631,904 18,555,501 18,664,591
April 26, 2010 Page 24 of 38

Exhibit 6.19 Respondent Cost

Year 1 Year 2 Year 3 Average

Training Providers $465,625 $92,571 $91,639 $216,612 

Opt-Out Firm

Certification $29,323,089 $19,112,164 $19,034,052 $22,489,768 

Opt-Out Firm Checklist $12,085,324 $12,035,775 $11,986,428 $12,035,842 

Currently Regulated 

Checklist $19,757,018 $19,676,014 $19,595,343 $19,676,125 

Total $61,631,056 $50,916,523 $50,707,461 $54,418,347

Exhibit 6.20 Agency Cost

Year 1 Year 2 Year 3 Average

EPA $33,440,247 $6,660,375 $6,633,350 $15,577,991 

Exhibit 6.21: Respondent Summary, Three-Year Average

Number of Small 

Respondents

Number of 

Respondents

Responses per 

Respondent

Burden per 

Response 

(hours)

Annual 

Burden

Training Providers - Existing Respondents, Additional Responses

Pre-notification 157 167 14 0.16 378

Re-notification 157 167 2 0.16 45

Post-notification 157 167 14 1.55 3,661

Digital Photos 157 167 14 1.25 2,953

Renovators – Private Firms – Additional Respondents

Initial Certification 50,296 50,431 1 8.3 418,577

Re-certification 1,472 1,476 1 5.3 7,825

Non-Certification Year 58,904 59,062 1 4.8 283,498

Recordkeeping Checklist Requirements

Entities Seeking Certification as a Result of Eliminating the Opt-Out Provision

New third party notification requirement for additional renovator respondents

Private Firms 110,672 110,969 65.26 0.05 362,089

Recordkeeping Checklist Requirements

Entities Currently Regulated by the 2008 LRRP Rule

New third party notification requirement for existing renovator respondents

Private Firms 200,202 203,105 55.65 0.05 565,145

Local Governments 7,138 7,750 8.13 0.05 3,150

Key

 Cells highlighted in yellow are incremental increases from previous ICR (EPA No. 1715.10, March 2008). 

 Cells highlighted in blue are revised estimates from previous ICR (EPA No. 1715.10, March 2008).

 Cells highlighted in pink are new requirement that were not in previous ICR (EPA No. 1715.10, March 2008). 

⁬ Cells that are not highlighted have not changed from the previous ICR (EPA No. 1715.10, March 2008). 

The total burden in OMB’s inventory for the existing, approved version of this ICR (EPA ICR No. 

1715.10) is 2,157,174 hours. With the addition of the 1,647,321 program change hours related to the rule

and 5,258 adjustment hours, the total burden requested for this ICR will be 3,809,753 hours. 

6(e) Reasons For Changes in Burden
April 26, 2010 Page 25 of 38

Most of the burden analyzed in this ICR addendum relates directly to the amended paperwork 

requirements contained in the rule and results in a program change increase. EPA is also correcting some 

miscalculations presented in the ICR addendum for the 2008 final RRP rule (ICR #1715.10) that results in 

adjustment-related increase in burden.

Program Changes

Most of the burden increase analyzed in this ICR is attributable to program changes related to the 

revisions to the 2008 final RRP rule. These changes would increase the number of respondents for certain 

approved information collection activities in some cases, and in other cases increase the number of events 

for certain approved information collection activities.

Additional Respondents Needing Certification

EPA estimates that an additional 110,969 firms would need to be certified as a result of the 

elimination of the opt-out provision, and therefore add a corresponding 110,969 annual responses. Of 

these 110,969 annual responses, EPA estimates that over the three years covered by the ICR, there will be 

an average of 50,431 new initial certification responses, 1,476 re-certification responses, and 59,062 noncertification year recordkeeping responses per year. The addition of these new responses is expected to 

increase the annual certification burden by 418,577 hours for firms seeking initial certification, 7,825

hours for firms seeking re-certification, and 283,498 hours for firms engaged in non-certification year 

recordkeeping activities

Additional Training Events

In direct relation to the increased number of firms that will be required to be trained and certified, 

training providers are expected to hold an additional 14 courses per year to accommodate the increase in 

the number of new respondents seeking RRP certification. Training providers are required to notify EPA 

before and after course completion, and in some instances re-notify if course rosters/schedules change. 

Therefore, EPA has increased the estimated number of pre-course and post-course notifications per firm 

each by 14, and the number of re-notifications per firm by 2. The annual notification burden for training 

providers related to these additional courses is expected to increase by 378 hours for pre-course 

notification, 45 hours for re-notifications, and 6,614 hours for post-course notification (including digital 

photographs).

New Third-Party Notification Requirements

EPA estimates that the 3rd-party notification requirements would result in an average burden 

increase of 930,384 hours per year. Each instance of the required 3rd-party notification is estimated to 

require about 3 minutes of the respondents’ time. However, as indicated in Ex. 6.21, the number of 

respondents and the estimated number of events per respondent combine to produce a substantial increase 

in the overall annual burden estimate.

Adjustments

Digital Photographs

EPA incorrectly accounted for the training provider burden associated with digital photographs of 

trainees seeking renovation certifications in the final rule ICR addendum (ICR No. 1715.10). In that ICR, 

EPA estimated that the burden associated with taking a single digital photograph would be 0.05 hours (3 

minutes). However, EPA inadvertently utilized this per-photograph estimate as the full burden estimate 

for a single course with an assumed training roster of 25 students. The digital photograph burden for a 
April 26, 2010 Page 26 of 38

single course with an assumed roster of 25 students should be 1.25 hours rather than 0.05 hours. This 

correction results in an adjustment burden increase of approximately 5,254 annual burden hours.

Estimated Baseline Number of Firms

In addition, this ICR addendum revises the estimated number of RRP firms upward by a single 

respondent. Specifically, EPA estimates that there will be a single additional respondent engaged in noncertification year record-keeping. Each respondent engaged in this activity will continue to have only a 

single annual response. This change is directly related to a rounding error and has the impact of adding 

about 4 hours to the overall estimated annual burden for this ICR.

6(f) Burden Statement

The incremental public burden for this collection of information, which is approved under OMB 

Control No. 2070-0155, is estimated to average approximately 42 hours per year for training providers. 

For firms that will seek certification as a result eliminating the opt-out provision, the average incremental 

burden is estimated to be about 9.7 hours per year. For firms that are currently regulated under the 2008 

LRRP Rule, the average incremental burden is estimated to be about 2.7 hours per year. According to the 

Paperwork Reduction Act, “burden” means the total time, effort, or financial resources expended by 

persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. For 

this collection it includes the time needed to review instructions; develop, acquire, install and utilize 

technology and systems for the purposes of collecting, validating, and verifying information, processing 

and maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able to 

respond to a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a currently valid 

OMB control number. The OMB control number for this information collection appears above. In 

addition, the OMB control numbers for EPA’s regulation, after initial display in the final rule, are listed in 

40 CFR part 9.
April 26, 2010 Page 27 of 38

ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachments to the supporting statement for this rule-related ICR addendum are available in the 

public docket established for the rulemaking under docket identification number EPA-HQOPPT-2005-0049. These attachments are available for online viewing at www.regulations.gov 

or otherwise accessed as described in section 6(f) of the supporting statement.

Attachment 1 Toxic Substances Control Act (TSCA), Sections 402 and 404 (15 USC 2682, 2684)

Attachment 2 Final Rule: Lead; Renovation, Repair, and Painting Program

Attachment 3 Application and Instructions for Training Providers - Applying for Accreditation of 

Lead-Based Paint Activity Training Programs - EPA Form 8500-25

Attachment 4 Application and Instructions for Firms - Applying for Certification to Conduct LeadBased Paint Activities - EPA Form 8500-27R

Attachment 5 Sample Form – Lead-Based Paint Activities Training Notification- (Pre-Training)

Attachment 6 Sample Form – Lead-Based Paint Activities Post Training Notification

Attachment 7 Sample Form - Optional Recordkeeping Checklist for Firms

Attachment 8 Sample Form – Pre-Renovation Form
April 26, 2010 Page 28 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 1

Toxic Substances Control Act Sections 402 and 404

15 U.S.C. 2682, 2684
April 26, 2010 Page 29 of 38

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 with 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 lead-based paint 

activities to ensure that individuals engaged in such activities are properly trained; that training 

programs are accredited; and that contractors engaged in such activities are certified. Such 

regulations shall contain standards for performing lead-based paint activities, taking into account 

reliability, effectiveness, and safety. Such regulations shall require that all risk assessment, 

inspection, and abatement activities performed in target housing shall be performed by certified 

contractors, 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 Act 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 purposes’‘, 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 regulations 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 requirements. 

 (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 applicable 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 activities 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 assessment, 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 leadbased 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 leadbased paint or lead-based paint hazards or to plan such activities. 

 (c) Renovation and remodeling 
April 26, 2010 Page 30 of 38

(1) Guidelines 

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 months 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 renovation 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 persons 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 hazard 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 revise 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 determining 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 

remodeling 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. 
April 26, 2010 Page 31 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 2

Final Rule: Lead; Renovation, Repair, and Painting Program

This attachment is available as a document in the electronic docket for this ICR at 

www.Regulations.gov (EPA-HQ-OPPT-2005-0049).
April 26, 2010 Page 32 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 3

Application and Instructions for Training Providers- Applying for Accreditation of LeadBased Paint Activity Training Programs - EPA Form 8500-25

For an electronic copy of the Training Provider Application Form and Instructions, go to 

http://www.epa.gov/lead/pubs/trainapp.pdf.
April 26, 2010 Page 33 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 4

Application and Instructions for Firms- Applying for Certification to Conduct Lead-Based 

Paint Activities - EPA Form 8500-27

For an electronic copy of the Firm Application Form and Instructions, go to 

http://www.epa.gov/lead/pubs/firmapp.pdf.
April 26, 2010 Page 34 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 5

Sample Form - Lead-Based Paint Activities Training Notification- (Pre-Training)

For an electronic copy of the Training Notification Sample Form, go to 

http://www.epa.gov/lead/pubs/form2-pre-training.pdf.
April 26, 2010 Page 35 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 6

Sample Form - Lead-Based Paint Activities Post Training Notification

For an electronic copy of the Training Notification Sample Form, go to 

http://www.epa.gov/lead/pubs/form3-post-training.pdf.
April 26, 2010 Page 36 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 7

Optional Recordkeeping Checklist for Firms
April 26, 2010 Page 37 of 38

Draft optional Recordkeeping Checklist for Firms:

Name of Firm:________________________________________________________________

Date and Location of Renovation:_________________________________________________

Brief Description of Renovation: _________________________________________________

____________________________________________________________________________

Name of Assigned Renovator:____________________________________________________

Name(s) of Trained Workers, if used:______________________________________________

____________________________________________________________________________

Name of Dust Sampling Technician, Inspector, or Risk Assessor, if used:__________________

_____________________________________________________________________________

 Copies of renovator and dust sampling technician qualifications (training certificates, 

certifications) on file. 

 Certified renovator provided training to workers on (check all that apply): 

 Posting warning signs  Setting up plastic containment barriers

 Maintaining containment  Avoiding spread of dust to adjacent areas

 Waste handling  Post-renovation cleaning

 Test kits used by certified renovator to determine whether lead was present on components 

affected by renovation (identify kits used and describe sampling locations and 

results):_____________________________________________________________

_______________________________________________________________________

_______________________________________________________________________

 Warning signs posted at entrance to work area. 

 Work area contained to prevent spread of dust and debris

 All objects in the work area removed or covered (interiors)

 HVAC ducts in the work area closed and covered (interiors)

 Windows in the work area closed (interiors)

 Windows in and within 20 feet of the work area closed (exteriors)

 Doors in the work area closed and sealed (interiors)

 Doors in and within 20 feet of the work area closed and sealed (exteriors)

 Doors that must be used in the work area covered to allow passage but prevent spread of 

dust 

 Floors in the work area covered with taped-down plastic (interiors)

 Ground covered by plastic extending 10 feet from work area—plastic anchored to 

building and weighted down by heavy objects (exteriors)

 If necessary, vertical containment installed to prevent migration of dust and debris to 

adjacent property (exteriors)

 Waste contained on-site and while being transported off-site

 Work site properly cleaned after renovation

 All chips and debris picked up, protective sheeting misted, folded dirty side inward, and 

taped for removal

 Work area surfaces and objects cleaned using HEPA vacuum and/or wet cloths or mops 

(interiors)

 Certified renovator performed post-renovation cleaning verification (describe results, including 

the number of wet and dry cloths used):________________________________

________________________________________________________________________

 If dust clearance testing was performed instead, attach a copy of report.

 I certify under penalty of law that the above information is true and complete.

_________________________________________________ ________________________

name and title date
April 26, 2010 Page 38 of 38

EPA ICR No. 1715.11; OMB Control No. 2070-0155

ATTACHMENT 8

Sample Form – Pre-Renovation Form

For an electronic copy of the Pre-Renovation Sample Form, go to 

http://www.epa.gov/lead/pubs/pre-renovationform.pdf