Page 1 of 14

Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

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

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

[RIN 2070-AK02]

EPA ICR No.: 2502.01 OMB Control No: 2070-NEW

1(b) Short Characterization

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

ICR No. 1715.13, OMB Control No. 2070-01551) which covers the reporting and recordkeeping 

requirements for individuals or firms conducting lead-based paint activities or renovation in or on 

houses, apartments, or child-occupied facilities built before 1978, under the authority of sections 402 

and 404 of the Toxic Substances Control Act (TSCA) (15 U. S. C. 2682, 2684; see Attachment 1). This 

addendum incorporates reporting and recordkeeping requirements in a proposed rule that would

eliminate the hands-on requirement from the renovator refresher training course. If this change is 

implemented, EPA expects training providers that are currently accredited to teach the renovator 

refresher training to apply for accreditation to teach the course via e-learning (i.e., via the internet). Only

changes that would result from the proposed rule are included in this addendum. Portions of the existing 

ICR that are not affected by the proposed rule are not included in this document. 

2. NEED FOR AND USE OF THE COLLECTION

 2(a) Need/Authority for the Collection

No Change

2(b) Practical Utility/Users of the Data

No Change

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-Duplication

No Change

 

1

ICR Reference No. 201109-2070-002, available electronically at 

http://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201109-2070-002. 
Page 2 of 14

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

The notice of proposed rulemaking serves as the public notice for this ICR addendum. Interested 

parties should submit comments to the address listed at the end of this document. Responses will be 

taken into account in developing the final rulemaking.

3(c) Consultations and Public Comments

No Change

3(d) Effects of Less Frequent Collection

No Change.

3(e) General Guidelines

No Change

3(f) Confidentiality

No Change

3(g) Sensitive Questions

No Change

4. THE RESPONDENTS AND INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

No Change

4(b) Information Requested

No Change

(i) Data Items

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

providers must submit documents to EPA/state, using the form entitled “Application and Instructions for 

Training Providers” (see Attachment 3) or a similar form containing the required information. Under the 

proposed rule that this ICR addendum addresses, EPA expects training providers accredited for the 

renovator refresher course to apply for accreditation to teach the e-learning version of the course. 

Accredited training providers are eligible for an expedited e-learning course accreditation if they want to 

teach an already reviewed and accepted e-learning course. Currently-accredited training providers 

seeking accreditation for the e-learning refresher course must submit the following information to EPA. 
Page 3 of 14

 A cover letter

 A training provider application to amend their accreditation; 

 An e-learning quality control (QC) plan. 

(ii) Respondent Activities

No Change

5. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

5(a) Agency Activities

No Change

5(b) Collection Methodology and Management

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

the proposed rule. Under the proposed rule, EPA expects training providers accredited for the renovator 

refresher course to apply for accreditation to teach the e-learning version of the course. Accredited 

training providers are eligible for an expedited e-learning course accreditation if they want to teach an 

already reviewed and accepted e-learning course. Currently-accredited training providers must submit to 

EPA the following information to seek accreditation for the e-learning refresher course: 

 A cover letter

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

 An e-learning quality control (QC) plan. 

5(c) Small Entity Flexibility

No Change 

5(d) Collection Schedule

No Change 

6. ESTIMATING THE BURDEN AND COST

This section estimates the incremental reporting burden for training providers that may result 

from the proposed revisions to EPA’s renovation, repair, and painting (RRP) program requirements. 

This burden is incremental to the burden for EPA’s lead paint program that has already been accounted 

for in an existing, approved ICR (EPA ICR No. 1715.13, OMB Control No. 2070-0155). This 

supporting statement provides burden and cost estimates for three years of the program. All costs are 

presented in year 2014 dollars. 
Page 4 of 14

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 majority of RRP training providers are predicted to attain accreditation for an e-learning 

refresher training course as a result of the proposed rule. Accredited training providers may add an 

already-reviewed e-learning curriculum through an expedited course approval process. Impacts are 

estimated for training providers currently offering an accredited refresher training course that are 

assumed to seek accreditation for an e-learning course.

6(a) Estimating Respondent Burden

The burden estimates in this information collection request are for training providers that are 

accredited to offer renovator refresher training courses. Training providers currently accredited for the 

renovator refresher training course are expected to apply for an additional accreditation for an e-learning 

refresher training course as result of the proposed rule. Therefore they would incur an incremental 

paperwork burden associated with becoming familiar with the rule’s requirements and with applying for 

accreditation to teach an online version of the renovator refresher training. All requests to add an 

already-reviewed e-learning curriculum to an already-accredited training provider’s 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. 

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, and are accounted for 

under the existing approved ICR (EPA ICR No. 1715.13).

There are 275 training providers with accredited renovator refresher training programs (see 

Exhibit 6.1). Training provider accreditation data are taken from the Federal Lead-based Paint Program 

(FLPP) database.

Exhibit 6.1 Number of RPP Training Providers 

Entity Type Number of Entities Accredited in Year 1

RPP Training Provider 275

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

average burden hours per training provider. Unit burden hour estimates are assumed to be half of the 

burden hour estimates from the previously approved ICR (EPA ICR No. 1715.13) because less 

information needs to be provided, given that the training provider has already been accredited for an inperson course. As presented in Exhibit 6.3, the burden for all training providers is estimated to be 3,795 

hours in Year 1, and 0 hours in Year 2 and Year 3. (The burden is 0 hours in Year 2 and Year 3 because 

all 275 training providers are assumed to apply for accreditation for the e-learning course in Year 1.)

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

1,265 hours.
Page 5 of 14

Exhibit 6.2 RRP Training Providers: Accreditation Burden

Activity Number of Activities per Training 

Provider in first Year1

Reporting Hours per Activity2

Professional Hours Clerical 

Hours Total Hours

Rule Familiarization 1 4.0 0.0 4.0

Accreditation Statement 1 3.8 1.0 4.8

Quality Control Plan 1 4.0 1.0 5.0

Annual Total 11.8 2.0 13.8

1Number of activities are from the previously approved EPA ICR No. 1715.13. 

2Burden hour per activity are assumed to be half the vales in the previously approved EPA ICR No. 1715.13. The hour estimates were 

rounded to one decimal place for this ICR.

Exhibit 6.3 Total and Average Accreditation Burden Hours

Year Number of 

Respondents

Burden PerRespondent Total Burden

1

275

13.8 3,795

2 - -

3 - -

3-Year Average 4.6 1,265

6(b) Estimating Respondent Costs

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

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

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

Exhibit 6.4 presents loaded wage rates for training provider professional and clerical staff, which are

$53.66 and $26.79, respectively. Wage and fringe benefit data are taken from the Employer Cost for 

Employee Compensation data series published by the Bureau of Labor Statistics (BLS)2. Both the 

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

Consumers published by the BLS3. The overhead data is taken from Wage Rates for Economic Analyses 

of The Toxics Release Inventory Program4. 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 6.4).

 

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.

3 Bureau of Labor Statistics (BLS). (2014). "Consumer Price Index - All Urban Consumers, U.S. City Average (2004 to 

2014)." CUSR0000SA0 Retrieved Mar. 21, 2014.

4 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. 
Page 6 of 14

Exhibit 6.4 Private Sector Wage Rates for Calculating Labor Costs (2014$)

Labor 

Category

BLS Occupation 

Category1 Date

Wage1 Fringe 

Benefit

Fringe

(% 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

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

workers, goods-producing and service-producing.

2U.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.

3Wage rates are rounded to the closest penny.

Exhibit 6.5 estimates the cost per activity associated with this information collection for training 

providers offering renovator courses. This yields an average cost of $687 per training provider. As 

shown in Exhibit 6.6, total training provider costs are estimated to be $188,925 in the first year of the 

rule, and $0 in the second and third years. The average annual cost over the three years covered by this

ICR is $62,975. 

Exhibit 6.5 RRP Training Providers: Accreditation Cost Estimates (2014$)

Activity

Reporting Hours per Activity1 Reporting Cost per Activity

Professional 

Hours

Clerical 

Hours Total Hours Professional (53.66/Hr)

Clerical

($26.79/Hr) Total 

Rule Familiarization 4.0 0.0 4.0 $214.64 $0.00 $214.64

Accreditation Statement 3.8 1.0 4.8 $203.91 $26.79 $230.70

Quality Control Plan 4.0 1.0 5.0 $214.64 $26.79 $241.43

Total 11.8 2.0 13.8 $633.19 $53.58 $686.77

1Hour estimates are derived from the previously approved EPA ICR No. 1715.13. The hour estimates were rounded to one 

decimal place for this ICR.

Exhibit 6.6 Total and Average RPP Training Provider Accreditation Costs (2014$)

Year Number of 

Respondents

Cost PerRespondent Total Burden

1

275

$687 $188,925 

2 - -

3 - -

3-Year Average $229 $62,975

6(c) Estimating Agency Cost

There are also government costs associated with reviewing the expedited e-learning applications. 

EPA estimates that it will take 4 hours apiece for an Agency employee to review the 275 training 

provider e-learning program accreditation applications. The base wage rate of the federal government 

employee reviewing applications is taken from the 2014 General Schedule (GS) Locality Pay Table for 

Washington-Baltimore-Northern Virginia, published by the Office of Personnel Management. A loaded 
Page 7 of 14

wage rate of $78.13 is then derived by applying a multiplier of 1.6 to account for fringe benefits and 

overhead to the base wage rate of a GS-13 Step 5 government employee ($48.83)5.

Exhibit 6.7 presents the costs to EPA for Years 1, 2, and 3, as well as the average annual costs.

The costs are calculated by applying the government employee wage rate to the 4 hours of time for each 

of the 275 accreditation applications.

Exhibit 6.7 EPA Costs (2014$)

Year 1 Year 2 Year 3 Avg.

$85,943 $0 $0 $28,648

6(d) Bottom Line Burden Hours and Cost

Exhibit 6.8 presents a summary of the number of respondents, the respondent burden, and the 

respondent costs over 3 years. The three year average annual paperwork burden is estimated to be 1,265

hours. The three year average annual respondent cost is estimated to be $62,975. The Agency cost is 

estimated to average $28,648 per year, as shown in Exhibit 6.9. 

Exhibit 6.8 Respondent Burden and Cost Summary

Year Number of 

Respondents

Number of

Small

Respondents1

Burden PerRespondent Total Burden Cost PerRespondent Total Cost

1

275 259

13.8 3,795 $687 $188,861

2 - - - -

3 - - - -

3-Year 

Average 4.6 1,265 $229 $62,975

1Consistent with the previously approved EPA ICR No. 1715.13, 94% of training providers are assumed to be small entities.

Exhibit 6.9 EPA Costs

Year 1 Year 2 Year 3 Avg.

EPA $85,943 $0 $0 $28,648

The total burden in OMB’s inventory for the existing, approved ICR for the lead paint program 

(EPA ICR No. 1715.13) is 3,312,524 hours. With the addition of the 1,265 program change hours 

related to the proposed rule, the total burden requested for the lead paint program will be 3,313,789

hours. 

6(e) Reasons For Changes in Burden

The burden analyzed in this ICR addendum relates to EPA’s proposed program change to 

remove the hands-on requirement from the refresher renovator training. This is expected to result in a 

number of training providers applying for accreditation to offer e-learning refresher courses.

 

5 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.
Page 8 of 14

Program Changes: Additional Respondents Applying for Renovator Refresher Course Accreditation

EPA estimates that 275 RRP training providers would apply for an accreditation for an 

e-learning refresher training course as a result of the provision to eliminate the course’s hands-on 

training requirement from the course curriculum. The addition of these new responses is expected to 

increase the annual accreditation burden by 1,265 hours. 

6(f) Burden Statement

The incremental public burden for this collection of information is estimated to average 13.8 

hours per response. Burden is defined in 5 CFR 1320.3(b). An agency may not conduct or sponsor, and 

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

OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 

included on the related collection instrument or form, if applicable.

The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ-OPPT2014-0304, which is available for online viewing at www.regulations.gov, or in-person viewing at the 

EPA Docket Center (EPA/DC), EPA William Jefferson Clinton West, Room 3334, 1301 Constitution 

Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

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

(202) 566-0280. You may submit comments regarding the Agency's need for this information, the 

accuracy of the provided burden estimates and any suggested methods for minimizing respondent 

burden, including the use of automated collection techniques.

Submit your comments, referencing Docket ID No. EPA-HQ-OPPT-2014-0304 and OMB 

Control No. 2070-[NEW], to (1) EPA online using www.regulations.gov (our preferred method), or by 

mail to: Document Control Office (DCO), Office of Pollution Prevention and Toxics (OPPT), 

Environmental Protection Agency, Mail Code: 7407M, 1200 Pennsylvania Ave., NW, Washington, 

D.C. 20460, and (2) OMB by mail to: Office of Information and Regulatory Affairs, Office of 

Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, 

DC 20503.
Page 9 of 14

ATTACHMENTS TO THE SUPPORTING STATEMENT

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

docket identification number EPA-HQ-OPPT-2014-0304.

Attachment 1: 15 U.S.C. 2682 - Toxic Substances Control Act Sections 402 

Attachment 2: Accreditation of training programs: target housing and child-occupied facilities

40 CFR 745.225

Attachment 3: Application and Instructions for Training Providers - Applying for 

Accreditation of Lead-Based Paint Activity Training Programs - EPA Form 

8500-25. 
Page 10 of 14

EPA ICR No. 2502.01; OMB Control No. 2070-NEW

ATTACHMENT 1

Toxic Substances Control Act Sections 402 

15 U.S.C. 2682
Page 11 of 14

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 leadbased 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 leadbased 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 lead-based paint, 

deleading, removal of lead from bridges, and demolition. For purposes of paragraph (2), the term 

‘’deleading’‘ means activities conducted by a person who offers to eliminate lead-based paint or leadbased paint hazards or to plan such activities. 

 (c) Renovation and remodeling 

(1) Guidelines 
Page 12 of 14

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. 
Page 13 of 14

EPA ICR No. 2502.01; OMB Control No. 2070-NEW

ATTACHMENT 2

Accreditation of training programs: target housing and child-occupied facilities

40 CFR 745.225

For an electronic copy of 40 CFR 745.225, go to http://www.ecfr.gov/cgi-bin/textidx?SID=2181334de64d0515a321c606e0ea0b8d&node=40:32.0.1.1.14.6.1.3&rgn=div8. 
Page 14 of 14

EPA ICR No. 2502.01; OMB Control No. 2070-NEW

ATTACHMENT 3

Application and Instructions for Training Providers - Applying for Accreditation of Lead-Based Paint 

Activity Training Programs - EPA Form 8500-25

An electronic copy of the training provider application form and instructions is available at

http://www2.epa.gov/sites/production/files/2013-09/documents/trainapp_9_5_13.pdf