1

Supporting Statement for a Request for OMB Review under

the Paperwork Reduction Act

PART A

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: Survey of the Public and Commercial Building Industry

EPA ICR No.: 2494.01 OMB Control No.: 2070-NEW

1(b) Short Characterization

EPA’s Office of Pollution Prevention and Toxics (OPPT) is investigating whether 

renovation, repair and painting (RRP) activities in public and commercial buildings (P&CBs)

create lead-based paint hazards. If EPA finds that these activities create lead-based paint hazards, 

the Agency will consider the types of regulatory action that might be appropriate to control the 

resulting exposures to lead. EPA seeks to survey construction contractors, property managers and 

lessors, and building occupants about RRP activities in P&CBs. 

The information collected through the survey will allow OPPT to predict a baseline for 

the incidence of different types of RRP activities that disturb lead-based paint in P&CBs, the 

methods that are used to conduct these activities, the work practices that are used to contain and 

clean the resulting dust, and the characteristics of the buildings. OPPT will use this information 

to estimate the resulting exposures to lead dust, which will inform Agency decision making about 

the need for and scope of potential regulatory or other actions to reduce exposures to lead dust 

from RRP activities in P&CBs. If EPA determines that a regulation is needed, the Agency will 

use this data to assess the incremental benefits and costs of potential options to reduce such 

exposures. If this survey is not conducted EPA would have to rely on assumptions, anecdotal 

information, or information collected from convenience samples, rather than calculating 

nationally representative parameter estimates from a probability sample. 

The primary objectives of the Public and Commercial Building Industry survey include: 

(1) gathering information on building and activity patterns that may affect exposures to lead dust 

from RRP activities in P&CBs; (2) determining the number of firms that perform RRP activities 

in P&CBs, (3) determining the types and numbers of RRP activities that are performed, (4) 

determining the extent to which various work practices that disturb painted surfaces are currently 

being used in RRP jobs in P&CBs, and (5) determining the extent to which various work 

practices for the containment and cleanup of lead dust are currently being used in RRP jobs

performed in P&CBs. 

The survey will collect information from three different groups: (A) establishments that 

perform RRP activities in P&CBs for compensation on a contract basis, hereafter referred to as 

contractors; (B) lessors and managers of P&CBs; and (C) building occupants of P&CBs (both 

owners and tenants) who may use their own staff to perform RRP activities. There will be 

separate questionnaires for each group. Information will be collected using telephone and online 

survey instruments. 

The information collection will be a one-time data collection. Participation will be 

voluntary. Establishments will be selected using a stratified random sampling method. EPA 
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plans to have 402 respondents complete a questionnaire. Because of the difficulty of finding the 

population of the establishments engaged in RRP activities in P&CBs, EPA anticipates having to 

contact approximately 8,485 entities and ask them a few, brief screening questions. All of these 

entities are counted as respondents for the purpose of calculating the burden of the survey. 

Information on whether an establishment performs RRP activities in P&CBs is not 

available from any readily accessible source. Therefore, it is not feasible to design a random 

sampling method for the survey without contacting a large number of establishments and asking 

them a few brief questions in the screening portion of the questionnaire. It is worth noting that 

the information collected from the estimated 8,485 establishments that will not complete the full 

questionnaire is still very important to EPA. Specifically, together with the information collected 

from the 402 respondents expected to complete the full survey it will provide a basis for 

estimating the population of establishments engaged in RRP activities in P&CBs. The 

questionnaire has been designed to quickly screen out respondents who do not perform RRP 

activities in P&CBs, in order to reduce the burden of locating eligible respondents. 

EPA estimates that the screening portion of the survey will take about 3 minutes to 

complete on average. For respondents completing the contractor questionnaire, it is estimated 

that the remaining portion of the survey will require about 30 minutes on average. For 

respondents completing the property lessor/manager or building occupant questionnaires, the 

remaining portion of the survey is estimated to require about 5 minutes on average. EPA 

estimates that the roughly 8,485 survey respondents will incur a total burden of 564 hours for 

both the screening questions and the full survey. The total cost to respondents of this one-time 

collection is estimated to be $34,103. The cost to the agency is estimated to be approximately 

$710,000.

2. NEED AND USE FOR THE COLLECTION

2(a) Need and Authority for the Collection

Title IV of TSCA, 15 U.S.C. 2681 et seq. (see Attachment 1), was enacted to assist 

the Federal Government in reducing lead exposures, particularly those resulting from lead-based 

paint (LBP). Section 402(c)(3) of TSCA specifically requires EPA to revise its Lead-Based Paint 

Activities regulations,1promulgated under TSCA section 402(a), to apply to those renovation and 

remodeling activities in target housing, public buildings constructed before 1978, and commercial 

buildings that create lead-based paint hazards. In April 2008, EPA promulgated the RRP rule (40 

CFR part 745) under TSCA section 402(c)(3).2 The RRP rule covers renovation, repair, and 

painting activities in target housing (which is most pre-1978 housing) and child-occupied 

facilities (which includes a subset of P&CBs in which young children spend a significant amount 

of time).

Several lawsuits were filed against EPA asserting, among other things, that the Agency 

violated TSCA section 402(c)(3) by failing to address renovation activities in P&CBs. These 

lawsuits (brought by environmental and children's health advocacy groups as well as a 

homebuilders association) were consolidated in the Circuit Court of Appeals for the District of 

Columbia Circuit. EPA engaged in collective settlement negotiations with all the parties and on 

August 24, 2009, EPA entered into an agreement with environmental and children's health 

 

1 Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child-Occupied Facilities; Final 

Rule. Federal Register (61 FR 45778, August 29, 1996).

2Lead; Renovation, Repair, and Painting Program; Final Rule. Federal Register (73 FR 21692, April 22, 2008).
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advocacy groups in settlement of their lawsuits.3Shortly thereafter the homebuilders association 

voluntarily dismissed its challenge to the rule. As part of this settlement agreement, EPA agreed 

to commence rulemaking to address renovations in P&CBs (other than child-occupied facilities)

to the extent such renovations create LBP hazards. As an initial step, EPA issued an ANPRM in 

the Federal Register on renovations in public and commercial buildings on May 6, 2010.

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The settlement agreement has been amended and modified several times (primarily to 

extend deadlines), with the most recent amendment having been entered into by the parties on 

September 7, 2012. Under the terms of the amended settlement agreement, the date by which 

EPA has agreed to either sign a proposed rule covering RRP activities in P&CBs, or determine 

that these activities do not create LBP hazards, is July 1, 2015. If EPA publishes a proposed rule 

in the Federal Register, EPA agreed to take final action on or before the date 18 months after the 

proposed rule has published.

In addition, as part of the agreement EPA held a public meeting on June 23, 2013, and 

offered an opportunity for stakeholders and other interested members of the public to provide data 

and other information that EPA may use in making its regulatory determinations. 

The purpose of this ICR is to fill some of the key data gaps for EPA’s exposure 

assessment and for its economic analysis of potential options to reduce exposure to lead dust from 

RRP activities in P&CBs. Without the survey, the exposure assessment and the economic 

analysis would need to rely on assumptions, anecdotal information, or information collected from 

convenience samples, rather than calculating nationally representative parameter estimates from a 

probability sample. The survey results are expected to be more representative than these 

alternatives. 

2(b) Practical Utility and Users of the Data

This survey will allow EPA to produce statistically valid estimates for the population of 

RRP firms and jobs that disturb paint in P&CBs, and the work practices that are used. EPA will 

use the data collected though this one-time survey as part of its investigation. Without the 

proposed information collection, these estimates would have to be derived from assumptions, 

anecdotal information, or information collected from convenience samples, rather than 

calculating nationally representative parameter estimates from a probability sample.

The primary purposes of this survey include gathering information on building and 

activity patterns that may affect exposures to lead dust from RRP activities in P&CBs; estimating

the baseline usage of particular work practices, and how this usage varies with the type of RRP 

job; determining the number of firms that perform RRP activities in P&CBs; and determining the 

types and numbers of RRP activities that are performed.

Secondly, the survey will attempt to collect information on how the proportion of jobs 

that use particular practices differs between different types of firms. In addition to baseline work 

practice data, the survey will collect information on the number of contractors that are already 

trained and certified under the existing RRP Program.

 

3 EPA. Sierra Club, etc. Settlement, as amended and modified (2009, 2011, and 2012). 

4 Lead; Renovation, Repair, and Painting Program for Public and Commercial Buildings; Advanced Notice of 

Proposed Rulemaking. Federal Register (75 FR 24848, May 6, 2010).
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3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

3(a) Non-Duplication

To the best of EPA’s knowledge, the data to be collected through this survey is not 

available elsewhere. EPA has investigated various sources of data on RRP firms and practices, 

including other surveys, trade association literature, academic studies, government reports, and 

information provided to EPA through public comments. In general, other sources of information 

on RRP either do not address the issues where EPA needs data; are based on judgments rather 

than a comprehensive and rigorous collection of information; lack the specificity and level of 

detail that EPA is requesting in this survey in order to estimate the potential risks, the industry 

baseline, and the costs and benefits of potential regulatory requirements; or are not representative 

of the universe of entities and activities associated with RRP in P&CBs. 

Although EPA has already collected information about RRP practices from various 

Federal entities, this information may not be representative of RRP activities in P&CBs. 

Renovations of Federal buildings can cost tens or hundreds of millions of dollars and take 

multiple years to conduct. This is very different from the RRP activities that many entities 

(including small businesses) undertake in P&CBs such as preparing surfaces for repainting in a 

motel, creating an opening in a wall to perform electrical work in a doctor’s office, or removing a 

section of a wall in order to repair a broken water pipe in a shopping mall. Federal entities may 

have more time and money to address LBP in the absence of any requirement to do so. Thus, the 

prevalence of work practices to control lead exposures from RRP activities may differ between 

the Federal government and other entities. EPA’s proposed probabilistic method for survey 

sampling allows a sampling error to be calculated, so it is a better approach from a statistical 

standpoint than limiting the data collection to Federal entities. Administering the survey to a 

random sample of entities will better describe the characteristics of P&CBs, P&CB contractors, 

RRP activities in P&CBs, and baseline work practices in P&CBs. Therefore, EPA’s survey does 

not duplicate existing data sources.

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

In proposing this ICR, EPA provided a 60-day public notice and comment period that 

ended on December 6, 2013. EPA received two comments, from the Commercial Properties 

Coalition and from the Independent Electrical Contractors, during the comment period. Copies of 

the comments and EPA’s response to the comments are included in Attachment 3.

3(c) Consultations

Additionally, under 5 CFR 1320.8(d)(1), OMB requires agencies to consult with potential 

ICR respondents and data users about specific aspects of ICRs before submitting an ICR to OMB 

for review and approval. In accordance with this regulation, EPA submitted questions to nine 

parties via email. The individuals contacted were: 

Associated General Contractors

Leah Pilconis 

pilconisl@agc.org

Building Owners Managers Association

Karen Penafiel 

kpenafiel@boma.org
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Finishing Contractors Association

Bob Weaver

bweaver@finishingcontractors.org

National Association of Home Builders

Tabby Waqar 

twaqar@nahb.org

National Association of Plumbing–Heating-Cooling Contractors

Mark Riso 

riso@naphcc.org

National Association of the Remodeling Industry

Patrick Kennedy 

pkennedy@superiorwoodcraft.com

National Roofing Contractors Association

Harry Dietz 

hdietz@nrca.net

National Systems Contractors Association

Kathy Mrosko 

cmrosko@nsca.org

Painting and Decorating Contractors of America

Mark Casale 

markcasale@paintspecialists1.com

EPA received no responses to its solicitation for consultations. A copy of EPA’s consultation email to the above nine potential respondents is included in Attachment 2.

EPA also conducted a pretest of the contractor survey instrument with 6 respondents. 

The respondents were asked to comment on the ease of answering the questions and about how 

they interpreted the questions. Several changes to the draft instrument were made based on 

insights gained by conducting the pretest (see Subpart B of this ICR supporting statement for a 

description of the changes).

3(d) Effects of Less Frequent Collection

This survey is a one time only data collection activity for the respondents.

3(e) General Guidelines

This information collection complies with the guidelines in 5 CFR 1320.5(d)(2). 

3(f) Confidentiality

EPA is not collecting information of a sensitive or private nature. Only the contractor 

conducting the survey for EPA will have access to personal identifiers in the raw survey data. 

(These personal identifiers include the respondent’s name, the respondent’s phone number, and 

the name of the organization the respondent works for.) All personal identifiers will be stripped 
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from the data before it is conveyed to EPA, so the respondents will be anonymous. The original 

survey database will remain under the control of the contractor hired to perform the survey. 

3(g) Sensitive Questions

Not applicable. The information requested is not sensitive in nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

Table 4.1 shows the North American Industrial Classification System (NAICS) codes of 

the establishments affected by this ICR. 

Table 4.1: Respondents Primary Industries: NAICS and Definitions

NAICS Code NAICS Definition

A. Contractors

2361 Residential Building Construction

2362 Nonresidential Building Construction

2381 Foundation, Structure, and Building Exterior Contractors

2382 Building Equipment Contractors

2383 Building Finishing Contractors

2389 Other Specialty Trade Contractors

B. Lessors, Property Managers, and Facility Support Services

5612 Facilities Support Services

53112 Lessors of Nonresidential Buildings (except Miniwarehouses) 

53131 Real Estate Property Managers 

C. Building Occupants

All Building occupants include entities from all NAICS except those listed above

4(b) Information Requested

(i) Data Elements

This survey will be administered to (A) contractors, (B) lessors and property managers, 

and (C) building occupants (both owners and tenants). The survey will employ mixed-mode 

online and phone data collection. An initial notification letter to respondents will explain the 

survey and provide instructions for completing the survey online. Those respondents who do not 

complete the online survey will be contacted by telephone using trained interviewers calling from

a survey telephone center. Respondents that confirmed that they do nonresidential work, but did 

not complete the survey after 8 call attempts will be sent an additional mail or courier mail 

contact with an invitation to complete the survey on the web. Non-responders who have provided 

an email address will receive up to two follow-up email reminders, as needed. Table 4.2 

summarizes the information the survey will request from respondents. The survey instruments 

are included as attachments to this ICR supporting statement. In order to reduce respondent 

burden, lessor and property managers and building occupants are not asked all the questions that 

are being put to contractors. Instead, these groups are only asked questions that they are in a 

unique position to answer.

(ii) Respondent Activities 

Individuals who are contacted to participate in this survey could potentially perform each 

of the following tasks:
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 Read notification letter;

 Listen to or read to introductory information;

 Respond to screening questions; and

 Complete survey

These activities represent a voluntary information collection for each respondent and are 

not customary practices of the respondents.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION

5(a) Agency Activities 

The Agency will conduct the following activities to complete the survey:

 Send letters to respondents, notifying them of the upcoming survey and instructions on 

how to complete the online version of the final approved questionnaire;

 Place up to 8 telephone calls (as needed) to each respondent who did not complete the 

survey online to identify a knowledgeable person to complete the survey and complete 

the survey over the phone using the Computer Assisted Telephone Interview (CATI) 

instrument based on final approved questionnaire;

 Eligible respondents who are particularly hard to reach will be sent an additional mail 

contact with invitation to complete the survey on the web. Non-responders who have 

provided an email address will receive up to two follow-up email reminders, as needed;

 Preliminary data review;

 Calculation of sampling weights;

 Non-response bias study;

 Performance of weighted statistical summaries, variance estimation, and technical 

analyses; and

 Report findings.
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Table 4.2: Information Collected From Respondents

Question 

Category

Purpose of Questions Question Number in Questionnaire

Contractor 

Instrument

Property 

Manager/

Lessor 

Instrument

Building 

Occupant 

Instrument

Respondent 

Identification

These questions will be used to identify the individual at the firm with the knowledge required 

to complete the survey.

S1-S5 S1-S5 S1-S5

Screening 

and Scope

These questions will be used to determine whether a respondent performs RRP activities in 

P&CBs. Only those who perform RRP activities in P&CBs will be asked to complete the full 

survey. Responses from the screening and scope questions will be used to estimate the universe 

of relevant firms.

Q1-Q2B Q1-Q3 Q1-Q3

Firm Type 

and Size

Responses from these questions will be used to assign the appropriate sampling weights. Q3-Q3B Q4-Q6 Q4-Q6

Total Number 

of Activities

The survey includes 11 categories of RRP activities that disturb painted surfaces. For each of 

these 11 activity categories, the survey asks two questions: (1) the total number of jobs and (2) 

the total number where more than a minor amount of paint is disturbed by the respondent

establishment’s employees. The response to the second question is of most interest for the 

analysis. The primary purpose of the first question will be to aid in the respondents’ recall of 

an accurate answer to the second question.

Contractors who report painting activities will be asked about the numbers of activities where 

they use the following paint removal techniques: (1) open flame or torch, (2) high temperature 

heat gun, (3) abrasive blasting, and (4) needle gun/scaler. In general, the survey collects 

information about paint removal techniques only for the most recent job a respondent 

performed. However, these four techniques are the exception because they potentially generate 

high levels of lead dust and are believed to be uncommon enough that information about them 

may not be captured if respondents are only asked about their most recent job.

Q4-Q5.4 Q7-Q7k2 Q7-Q7k3

Recent Job:

Job Size, Job 

Duration, 

LBP Testing, 

Access to 

Work Area 

A single activity type that was reportedly performed by each respondent will be randomly 

selected for a more detailed series of questions. Once the activity type is selected, the 

respondent will be prompted to recall the most recent job where LBP might have been 

disturbed (either because a test indicated the presence of LBP or because surfaces coated with 

older paint that might have been applied before 1978 were disturbed). If there were no recent 

jobs where LBP may have been disturbed they will be asked about the most recent job. 

Q5.5-Q5.10 Q8.1-Q8.5 Q8.1-Q9.5
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Respondents will be asked to characterize the type of building, the number of stories the 

building has (when asked about an exterior job) and the number of rooms and walls/ceilings 

where painted surfaces were disturbed (when asked about an interior job). This will provide 

information on how much paint might be disturbed and the number of people potentially 

exposed to dust generated. 

For respondents being asked about a recent painting job, they will be asked the percent of the 

painted surface disturbed and the average number of layers of paint that were removed during 

the paint preparation. This will be used to estimate how much paint was removed. 

For respondents being asked about a recent window or exterior door job, they will be asked 

how many windows or doors were replaced. This will be used to estimate how much paint was 

disturbed. 

All respondents will be asked about: (1) the total duration of the job, (2) the times of day the 

work was done, and (3) access to the work area by building occupants. Responses to these 

questions will be used to inform the level of exposure building occupants might experience.

Job 

Combinations

For the most recent activity a respondent is asked about, s/he will be asked to report what other 

activities were performed at the same time. The responses to these questions will be used to 

ensure that the estimates of the number of activities are not based on double counting. 

Q6-Q6k N/A N/A

Containment There are seven questions related to dust containment practices. Responses to these questions 

will be used to estimate the extent to which firms are already using containment practices. One 

question is asked to all respondents (Q8a), three are only asked to those being asked about a 

recent exterior job (Q8b, Q8c, Q8d), and three are only asked to those being asked about a 

recent interior job (Q8e, Q8f, Q8g).

Q7-Q7g N/A N/A

Cleanup Responses to these questions will be used to estimate the extent to which firms are already 

using cleaning practices. There are eight questions related to cleanup practices that will be 

asked to all respondents being asked about a recent interior job. Those that report vacuuming 

will be asked if they used a HEPA vacuum. Those that reported that there were uncarpeted 

floors will be asked if they mopped.

Q8-Q8k N/A N/A
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Paint 

Preparation 

and Removal 

Techniques

Respondents being asked about a recent job involving paint preparation will be asked about the 

paint preparation and removal techniques they used. There are a total of 16 questions about 

paint preparation and removal techniques:

 9 are asked to all respondents

 7 are asked conditional on an affirmative response to another question

Q9a-Q10 N/A N/A

Routine 

Cleaning

Respondents will be asked how often most areas of the building receive routine janitorial 

cleaning.

N/A Q9 Q10

Motivation 

for lead-safe 

work 

practices

Respondents will be asked what one or two factors usually influence the level of dust 

containment and cleaning for a given job in P&CBs. This is asked to help EPA understand 

what motivates the use of lead safe work practices.

Q11 N/A N/A

Baseline RRP 

Certification

Respondents will be asked whether they are already certified under the residential rule. This is 

asked because being certified for residential work may affect firms’ baseline work practices in 

P&CBs. It will also be used to estimate the potential costs if additional firms are required to 

become certified in order to work in P&CBs.

Q12 N/A N/A

Open Ended Respondents will be given the option to provide additional comments or information. Q13 Q11 Q12
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5(b) Collection Methodology and Management

Information will be collected using telephone and online survey instruments. Samples of 

RRP contractors, property managers/lessors, and building occupants will be drawn from the Dun 

& Bradstreet “Dun’s Market Identifiers” (DMI) file provided by Survey Sampling, Inc. A 

telephone and online mixed-mode survey appears to be the most appropriate approach for 

minimizing the two main anticipated challenges: (1) problems of recall (working from memory) 

and understanding (are the terms used familiar to the respondent), and (2) problems in contacting 

people who may spend little time in an office. Telephone surveys maximize cooperation through 

direct contact with the respondents and provide an opportunity to clarify terms and aid 

recollection through probes. Telephone surveys also provide a rapid turnaround time. Many 

respondents who may spend little time in the office and have busy schedules may be more likely 

to respond to an online survey. The online questionnaire can also include more instructions and 

definitions of terms for respondents that need clarification. In addition, the online survey is 

expected to make it easier to elicit responses from larger firms, who are less likely to have a 

single individual who can provide the answers to all questions, because multiple individuals can 

collaborate on the response.

The survey field period will be relatively short and the target population is not likely to 

be motivated to participate in the survey. Contractor respondents are expected to be an especially 

difficult population to reach and motivate to participate in the study. They are much less likely 

than building occupants or management/lessor companies to be in the office during business 

hours. Based on experience with the pretest and prior informal EPA surveys (i.e., surveys 

administered to fewer than 10 respondents), this population is not likely to be motivated to 

participate in the survey. (Although not strictly comparable, a prior informal EPA survey of 

renovation contractors required contacting nearly 1,000 respondents to find 9 that were in the 

office at the time of the call and would agree to complete the survey.) Because EPA expects that 

it will be extremely difficult to get contractors to agree to participate in the survey, the EPA 

contractor who is administering the survey will offer an incentive of $50 for eligible respondents 

who complete the full survey. For budget estimation purposes, EPA’s contractor estimated that 

with the $50 incentive 1,645 of the 2,632 potential respondents that are successfully contacted 

will complete the screener portion of the survey. Getting 1,645 respondents to agree to complete 

the screener portion of the survey by successfully contacting 3,500 respondents is the break-even 

point for the incentive cost. Thus, a reduction of 25% or more in the number of respondents 

EPA’s contractor needs to successfully contact would mean that the cost of the incentive would 

be recouped through lower survey administration costs. Thus, the Agency believes that the costs 

of administering the survey would be considerably higher without offering the incentive for 

contractors. 

Because building occupants and management/lessor companies are more likely to be in 

the office during business hours and the survey for these respondents is much shorter in duration 

(5 minutes compared to 30 minutes for the contractor survey) an incentive is not necessary for 

these groups of respondents.

A mail survey would be very ineffective in this situation, although respondents will 

receive an initial notification letter describing the survey and encouraging them to follow the 

instructions provided for completing the survey using the online instrument. 

Those respondents who do not complete the survey online will be contacted by telephone 

by trained interviewers calling from a survey telephone center (Abt SRBI). The telephone survey 

instrument will use a CATI screener questionnaire and detailed interview questionnaire. The 
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main advantage of a telephone survey is the ability to make multiple call attempts over a 

relatively short field period. The call attempts and scheduled call backs can be customized to the 

hours that contractors are available to respond to the survey – this may involve early morning 

calls and late afternoon/evening calls. The screener questionnaire includes several questions 

involving skip patterns and terminations that depend on whether the respondent is eligible to 

complete the detailed interview. The detailed interview also contains some key skip patterns and 

a series of questions related to work practices. This type of questionnaire design is well suited for 

both the online and CATI administration. The telephone survey will be conducted from an Abt 

SRBI telephone center where trained supervisors and interviewers will be assigned to the study.

5(c) Small Entity Flexibility

Small entities make up the majority of the establishments that perform the RRP projects 

that are of interest in this survey. Therefore, since this is the primary target population for the 

survey, the majority of respondents will be small entities. The instrument has been developed to 

minimize the burden on all respondents while obtaining sufficient and accurate information. 

5(d) Collection Schedule

Exhibit 5.1 provides the schedule of the various tasks involved in conducting the 

proposed survey. As shown in the schedule, data collection would start within one week of OMB 

approval of the ICR and would end nine weeks later. Telephone data collection will start one 

week after the pre-notification letter. An email alert will be sent to the screened and eligible nonresponding businesses after seven weeks to encourage them to complete the survey on the online. 

EPA would then process the data and analyze it for potential non-response bias. 

Exhibit 5.1: Survey Collection Schedule

Task Week (from receipt of OMB approval)

1 2 3 4 5 6 7 8 9 10 11 12 13 14

Send pre-notification letter to 

respondents in selected sample

Conduct telephone calls to 

conduct screener and main 

questionnaire to complete 120 

responses

Analyze data collection of the 

first two weeks to decide if 

sample allocation needs to be 

modified

Resume telephone interviews 

Send out email alert to eligible 

non-responding sample 

Process data

Analyze data, including 

potential non-response bias
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6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden 

This section details the estimated burden to respondents participating in this ICR. For the 

contractor questionnaire, the accuracy of EPA’s burden estimates was confirmed during the 

survey pretest. The estimates of the time burden involved in responding to the other two 

questionnaires are based on the length of the survey instruments. It is worth noting that the 

burden on respondents will be less than the length of the questionnaires might seem to imply 

because no respondents will need to answer all of the questions listed. For example, after a 

respondent completes Question 4 in the contractor questionnaire a single activity type will be 

selected and the respondent will only need to respond to additional questions relevant to that job 

type. For example, respondents who are being asked about replacing windows will not be asked 

questions about paint removal techniques, and respondents being asked about exterior painting 

will not be asked questions about interior containment and clean-up practices.

The respondent burden is presented by respondent type. Two types of respondents were 

identified:

 Ineligible respondents do not perform or make decisions related to RRP activities in 

P&CBs. They complete a portion of the survey screening to determine their ineligibility. 

Hereafter, respondents of this type are referred to as initial completes.

 Eligible respondents perform or make decisions related to RRP activities in P&CBs. 

Hereafter, respondents of this type are referred to as full completes.

It is estimated that the screening portion of the survey will take about 3 minutes on 

average. For respondents completing the contractor questionnaire, it is estimated that the 

remaining portion of the survey will require about 30 minutes on average. For respondents 

completing the property lessor/manager or building occupant questionnaires, the remaining 

portion of the survey is estimated to require about 5 minutes on average. Table 6.1 summarizes 

the burden per respondent.

Table 6.1: Average Burden Per Respondent

Respondent Type Average Per-Respondent Burden*

Initial Completes 0.05 hours

Full Completes (Contractors) 0.55 hours

Full Completes (Lessors, 

Property Managers, and 

Facility Support Services;

Building Occupants)

0.13 hours

*Note that the respondent burden for a full complete includes the time to answer the 

screening questions.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

EPA estimated respondent costs using the burden estimates presented above and the 

average wage figures provided by the Bureau of Labor Statistics (BLS) occupational employment 

statistics series. Wage rates for each category of personnel are derived with methods and from 

sources either identical to or similar to those used in prior ICR renewals and economic analyses

for EPA’s RRP program. According to the December 2012 BLS data for Employer Costs for 
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Employee Compensation, wages and salaries accounted for 69.2% of employee compensation, 

implying a wage multiplier of 1.445.5 Based on Appendix I of the National Association of Home 

Builders' 2010 Cost of Doing Business Study, an additional 8.3% was added to the fringe 

multiplier for overhead costs to estimate a multiplier of 1.53 for fully loading wages. A uniform 

loading factor of 53% for fringe benefits and overhead was applied to all categories of labor for 

this ICR. 

Contractors’ fully loaded wages ($47/hour) are estimated from the wages earned by FirstLine Supervisors/Managers of Construction Trades and Extraction Workers (Occupation 47-

1011). Lessors and property managers’ fully loaded wages ($47/hour) are estimated from the 

wages earned by Property, Real Estate and Community Association Managers (Occupation 11-

9140). The wage rates ($78/hour) for building occupant respondents are estimated as the fully 

loaded wages earned by Miscellaneous Managers (Occupation 11-9190). Table 6.2 presents the 

wages for the occupations that best match the ICR labor categories. Table 6.3 presents the 

individual respondent costs by respondent type associated with this ICR. 

Table 6.2: Private Sector Wage Rates for Calculating Labor Costs (2012$)

ICR Labor Category BLS Occupation Category May 2012 

Hourly 

Wage Rate

Hourly Wage 

with Fringe and 

Overhead

Contractors First-Line Supervisors of 

Construction Trades and 

Extraction Workers

$30.40 $47

Lessors and Property Managers Property, Real Estate, and 

Community Association 

Managers

$30.56 $47

Building Occupants Miscellaneous Managers $50.79 $78

Table 6.3: Average Individual Respondent Cost

Respondent Type

Average PerRespondent 

Burden*

Respondent Loaded 

Hourly Wage

(2012$)

Average Labor Cost 

per-Respondent

Contractors

Initial Completes 0.05 hours $47 $2.35

Full Completes 0.55 hours $47 $25.85

Lessors and Property Managers

Initial Completes 0.05 hours $47 $2.35

Full Completes 0.13 hours $47 $6.11

Building Occupants

Initial Completes 0.05 hours $78 $3.90

Full Completes 0.13 hours $78 $10.14

*Note that the respondent burden for a full complete includes the time to answer the screening question.

 

5 The percent of employee compensation that accounts for salaries and wages is based on civilian works, which 

includes private industry workers, as well as state and local government workers. This information is 

available at: http://www.bls.gov/news.release/pdf/ecec.pdf (released March 12, 2013).
15

(ii) Estimating Capital and Operations and Maintenance Costs

EPA does not expect respondents to incur any capital or operations and maintenance 

(O&M) costs. This information collection is voluntary and does not require special equipment.

(iii) Capital/Start-up Operating and Maintenance (O&M) Costs

Not applicable.

(iv) Annualizing Capital Costs

Not applicable.

6(c) Estimating Agency Burden and Costs

EPA will use in-house staff and contractors to conduct the survey. EPA staff will oversee 

the contractor staff working on the survey, and send out the pre-notification letters to potential 

respondents. It is estimated that administering the survey will require 1/7th of a full-time 

employee (FTE) at EPA headquarters. The cost for EPA staff is estimated to be $77.62 per hour, 

based on the 2012 wage rate for a GS-13, Step 5 employee in the Washington-Baltimore locality, 

with a government overhead factor of 1.6 to account for fringe benefits and overhead. This is 

equivalent to an EPA staff cost of approximately $23,064. EPA’s cost for sending the prenotification letters will be $112,000, the cost of sending 66,000 pre-notification letters costing 

$1.69 each ($0.49 in postage and $1.20 in materials and processing cost).

EPA will incur costs for contractor staff to administer the telephone survey, process and 

analyze the data, and prepare survey documentation. 

Table 6.4 presents the Agency costs for each activity associated with conducting the 

survey. Total Agency costs are estimated at $710,000. 

Table 6.4. Estimated Agency Costs

Activity Agency Cost

EPA Staff Time $23,000 

Pre-Notification Letters $112,000 

CATI and Web Programming $20,000 

Sampling $22,000 

Interviewing and Web Data Collection $466,000 

Data Cleaning and Processing $31,000 

Weighting $23,000 

Incentives $13,000 

Total Cost $710,000

6(d) Estimating the Respondent Universe and Total Burden Costs

See section 2(b) of Part B of this supporting statement for a description of how the 

necessary sample sizes (i.e., respondent universe) were estimated. The per-respondent burden 

and cost are described above. Table 6.5 presents the respondent universe and the total hour and 

cost burden by respondent type.

Table 6.5: ICR Respondent Universe and Total Burden Cost

Respondent Estimated Estimated Per- Total Per- Total 
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Type* Respondent 

Universe*

Universe of 

Small 

Respondents**

Respondent 

Burden*

(hours)

Respondent 

Burden

(hours)

Respondent 

Cost (2012$)

Respondent 

Cost (2012$)

A. Contractors

Initial Completes 1,391 1,349 0.05 70 $2.35 $3,269 

Full Completes 254 246 0.55 140 $25.85 $6,566 

B. Lessors and Property Managers

Initial Completes 1,972 1,913 0.05 99 $2.35 $4,634 

Full Completes 68 66 0.13 9 $6.11 $415 

C. Building Occupants

Initial Completes 4,720 4,578 0.05 236 $3.90 $18,408 

Full Completes 80 78 0.13 10 $10.14 $811 

Summary for All Respondents

Initial Completes 8,083 7,840 0.0501 405 $3.26 $26,311

Full Completes 402 390 0.3955 159 $19.38 $7,792

All Completes 8,485 8,231 0.0665 564 $4.02 $34,103

*Note that the respondent burden for a full complete includes the time to answer the screening questions.

**Note that larger firms (who are expected perform disproportionately more RRP activities) will be oversampled. 

While over 99% of the entities in these industries are small, roughly 97% of survey respondents are expected to be 

small entities.

6(e) Bottom Line Burden Hours and Cost Tables 

Table 6.6 details the total bottom-line burden (respondent and EPA) associated with this 

ICR. Tables 6.1 through 6.5 detail how these total figures were derived.

Table 6.6: Bottom Line Burden and Costs

Cost Category Labor Hours Cost

Respondent Labor 564 $34,103

EPA Labor N.A. $23,000 

Other Direct EPA Costs N.A. $687,000 

Total 564 $744,103 

6(f) Reasons for Change in Burden 

Not applicable because this request does not renew or modify an existing ICR.

6(g) Burden Statement 

The annual public burden for this collection of information is estimated to average 0.07

hours per response. This includes an average respondent burden of 0.05 hours for respondents 

that are not eligible to complete the full study (initial completes) and 0.40 hours for respondents 

who complete the full study (full completes). 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-HQOPPT-2013-0715, which is available for online viewing at www.regulations.gov, or in-person 

viewing at the Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). 

The EPA/DC Public Reading Room is located in the William Jefferson Clinton (WJC) West 

Building, Room 3334, 1301 Constitution Ave., N.W., Washington, DC. The EPA/DC Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 
17

holidays. The telephone number for the EPA/DC Public 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-2013-0715 and OMB Control No. 2070-NEW, to (1) EPA online 

using www.regulations.gov (our preferred method), or by mail to: Pollution Prevention and 

Toxics Docket, Environmental Protection Agency Docket Center (EPA/DC), Mailcode: 28221T, 

1200 Pennsylvania Ave., N.W., Washington, DC 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, N.W., Washington, DC 20503.
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ATTACHMENTS TO THE SUPPORTING STATEMENT

Attachment 1 - Toxic Substances Control Act Section 402; 15 U.S.C. 2681 et. seq.

Attachment 2 - Public Consultations

Attachment 3 - Public Comments on Proposed ICR and EPA Responses to Public Comments

Attachment 4 - EPA Public and Commercial Building Contractor Survey Questionnaire

Attachment 5 - EPA Public and Commercial Building Manager/Lessor Survey Questionnaire

Attachment 6 - EPA Public and Commercial Building Occupant Survey Questionnaire