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 -**  **NE W**  **1(b) Short Characterization**  This information collection request ( ICR) addendum revises an existing, approved ICR (EPA ICR No. 1715.1 3, OMB Control No. 2070 - 0155 1 ) which covers the reporting and recordkeeping requirements for individuals or firms conducting lead - based paint activities or renovation in or on houses, apartments, or child - occupied facilities built before 1978, under the authority of sections 402 and 404 of the Toxic Substances Control Act (TSCA) (15 U. S. C. 2682, 2684; see Attachment 1 ). This addendum incorporate s reporting and recordkeeping requirements 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 currentl y 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 C**  **ollection** No Change **2(b) Practical**  **Util ity/Users of the D**  **ata** 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 I CR 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/ s tate, using the form entitled “Application and Instructions for Training Providers” (see Attachment 3) o r a similar form containing the required information . Under the 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**  N o 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 b y the proposed rule . Under the proposed rule, EPA expects training providers accredited for the renovator refresher course to appl y 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 c ourse:  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 I CR (EPA I CR No. 1715.1 3 , OMB Control No. 2070 - 0155 ). This supporting statement provides burden and cost estimates for thre e years of the program. All costs are presented in ye ar 20 14 dollars.Page 4 of 14

Sections 6(a) and 6(b) estimate the respondents’ paperwork burdens and costs, respectivel y. 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 pre dicted 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 traini ng providers that are accredited to o ffer r enovator refresher training courses. Training providers currentl y 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 appl yi ng 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 successfull y 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 I CR (EPA I CR No. 1715.13) . There are 275 training providers with accredited renovator refresh er training programs (see Exhibit 6 . 1 ) . Training provider accreditation data are taken from the Federal Lead- based Paint Program (FLPP) database.

**Exhi bit**  **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 b urden h our estimates are assumed to be half of the burden hour estimates from the previously approved IC R ( EPA I CR No. 171 5.13 ) because less information needs to be provided, given that the training provider has already been accredited for an in person course . As presented in Exhibit 6 . 3 , the burden for all training providers is estimated to be 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 th e e - learning course in Year 1.) The average annual aggregate burden for training providers over the three years covered b y 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 Year**  **1 Reporting Hours per**  **Activity 2**  **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 1 Number of activitie s are from the previously approved EPA ICR No. 1715.13. 2 Burden h our 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 Per**  ****

**Re s**  **pondent 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 S ection 6(a) . Wage rates for ea ch category of personnel are derived with methods and from sources either identical to or very similar to those used in previous I CR renewals and related economic analy ses. Exhibit 6 . 4 presents l oaded 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 b y the Bureau of Labor Statistics (BLS) 2

. Both the professional and clerical base wage rates are inflated to 2014 dollars by applying the CPIfo r All Urban Consumers published by

the BLS 3

. The overhead data is taken from Wage Rates for Economic Analyses of The Toxics Release Inventory Program 4

. Th e overhead loading factor is added to the benefits loading factor, and the total is then applied to th e 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/ne ws.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 Divis ion, Analytical Support Branch.Page 6 of 14

**Exhibit 6**  **. 4**  **Private Sector Wage Rates for Calculating Labor Costs (2014$) Labor**  **Category BLS Occupation** 

**Category 1**  **Date Wage**  **1 Fringe**  **Benefit Fringe** 

**(% of**  **Wage) 1**  **Overhead**

**(% of**  **Wage) 2**  **Wage**

**Multiplier Loaded** 

**Wages 3**  **(a) (b)**  **(c) =(b)/(a)**  **(d) (e)**  **=1+(c)+(d) (f)** 

**=(a)*(e)** Professional Professional

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

administrative support 9/12 $16.64 $7.32 44% 17% 1.61 $26.79 1 Bureau of Labor Statistics (BLS). (2013, Dec. 11). "Employer Costs for Employee Com pensation - September 2013." Private industry workers, goods - producing and service - producing. 2 U.S. EPA (2002). Wage Rates for Economic Analyses of The Toxics Release Inventory Program, U.S. Environmental Protection Age ncy, Office of Environmental Info rmation, Environmental Analysis Division, Analytical Support Branch. 3 Wage rates are rounded to the closest penny. Exhibit 6 . 5 estimates the cost per activity associated with this information collection for training providers offering r enovator cours es . This yields an average cost of $ 687 per training provider. As sh own 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 ye ar s. The average annual cost over the three years covered by th is ICR is $62,9 75 . **Exhibit 6**  **. 5**  **RRP Training Providers: Accreditation Cost Estimates (2014$)**  **Activity Reporting Hours per**  **Activity 1**  **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 1 Hour 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**  **Per**  

** Re** **s pondent**  **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 f or 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) Lo cality Pay Table for Washington - Baltimore -Northern Virginia , published by the Office of Personnel Manag ement. A loadedPage 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 appl yi ng the government e mployee 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 $ 62,9 75 . 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**

**Sm all**  **Respondents 1**  **Burden Per**  

** Re** **s pondent**  **Total Burden Cost**  **Per**   ** Re** **s pondent**  **Total Cost** 1 275 259 13.8 3,795 $687 $188,861 2 - - - - 3 - - - - 3 - Year Average 4.6 1,265 $229 $62,975 1 Consistent 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 I CR 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) R** **easons For Changes in Burden** The burden anal yz ed in this I CR 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 appl yi ng 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 re fresher training course as a result of the provision to eliminate the cours e ’ 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 inform ation 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 display s 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 I CR under Docket ID No. EPA - HQ - OPPT 201 4 - 0304 , which is available for online viewin g 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 op en from 8:30 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566 - 1744, and the telephone number for the Pollution Prevention and Toxics Docket is (202) 566 - 0280. You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Submit your comments, referencing Docket ID No. EPA - HQ - OPPT - 201 4 - 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: 7407 M , 1200 Pennsylvania Ave., NW, Washington, D.C. 20460, and (2) OMB b y mail to: Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503.Page 9 of 14 **ATTACHMENTS TO THE SUPPORTING STATEMENT** Attachments to the supporting statement are available in the public docket established for this I CR under docket identification number EPA - HQ - OPPT - 201 4 - 0304. **Attachment 1: 15 U.S.C. 2682**  **- Toxic Substances Control Act Sections 402**  **Attachment 2: Accreditation of training programs: target housing and child**  **- occupied facilities** 

**40 CFR 745.225 Attachment 3:**  **Application and Instructions for Training Providers -**  **Applying for**

**Accreditation of Lead -**  **Based Paint Activity Training Programs -**  **EP A Form**  **8500 -**  **25.**Page 1 0 of 14 EPA ICR No. 2502.01; OMB Control No. 2070 -NEW

ATTACHMENT 1 Toxic Substances Control Act Sections 402

15 U.S.C. 2682Page 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 lead based paint activities, taking into account reliability, effectiveness, and safety. Such regulations shall require that all risk assessment, inspection, and abatement activities performed in target housing shall be performed by certified contractor s, as such term is defined in section 4851b of title 42. The provisions of this section shall supersede the provisions set forth under the heading ‘’Lead Abatement Training and Certification’‘ and under the heading ‘’Training Grants’‘ in title III of the 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 p urposes’‘, Public Law 102 - 139 (105 Stat. 765, 42 U.S.C. 4822 note), and upon October 28, 1992, the provisions set forth in such public law under such headings shall cease to have any force and effect. (2) Accreditation of training programs Final 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 bridg es, and demolition. For purposes of paragraph (2), the term ‘’deleading’‘ means activities conducted by a person who offers to eliminate lead- based paint or lead based paint hazards or to plan such activities. (c) Renovation and remodeling (1) Gui delinesPage 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, p romulgate 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 occasi onal 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, exp erts 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 cop y of 40 CFR 745.225 , go to http://www.ecfr.gov/cgi - bin/text idx?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