Page 1 of 28

Supporting Statement for an Information Collection Request (ICR)

Under the Paperwork Reduction Act (PRA)

1. EXECUTIVE SUMMARY

1(a). Identification of the Information Collection – Title and Numbers

Title: Lead Training, Certification, Accreditation and Authorization Activities

ICR Numbers: EPA ICR No.: 2507.01; OMB Control No.: 2070-New.

EPA Form Numbers: EPA Form 8500-25: Application and Instructions for Training 

Providers Applying for Accreditation of Lead-Based Paint Activity and Renovation Training 

Programs; EPA Form 8500-27: Application for Firms to Conduct Lead-based Paint Activities or 

Renovations; EPA Form 747-B-99-002: Application and Instructions for Individuals Applying for 

Certification to Conduct Lead-Based Paint Activities.

Docket ID Number: EPA-HQ-OPPT-2014-0486.

1(b). Docket Information

The information collection request (ICR) that explains the information collection activities and 

related burden and cost estimates, as well as other supporting documents related to the ICR, 

are available in the docket established for this ICR. The docket, designated as ID No. EPAHQ-OPPT-2014-0486, can be viewed online at http://www.regulations.gov or in person at the 

EPA Docket Center, William Jefferson Clinton West Bldg., Rm. 3334, 1301 Constitution Ave., 

NW., Washington, DC. The telephone number for the Docket Center is (202) 566-1744. For 

additional information about EPA’s public docket, visit http://www.epa.gov/dockets.

1(c). ICR Status

Under the Paperwork Reduction Act (PRA), 44 U.S.C. 3501 et seq., 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 control number issued by the Office of Management and 

Budget (OMB). The OMB control numbers are displayed either by publication in the Federal 

Register or by other appropriate means, such as on the related collection instrument or form, if 

applicable. The display of OMB control numbers for certain EPA regulations is consolidated in 

40 CFR part 9.

Before submitting an ICR to OMB for review and approval under the PRA, an agency must 

solicit comments pursuant to PRA §3506(c)(2)(A) and 5 CFR 1320.8(d)(1). After considering 

comments received on the draft ICR, the agency must submit the ICR to OMB for review and 

approval according to the procedures prescribed in 5 CFR 1320.12. In announcing the 

submission of the final ICR to OMB for review and approval, the agency must provide another 

opportunity for public review and comments on the revised ICR pursuant to 5 CFR 1320.12(c).
Page 2 of 28

This is a new ICR that seeks to consolidate the information collection activities that are 

currently covered by the following three ICRs that are currently approved by OMB under the 

separate OMB control numbers identified:

1) OMB Control No. 2070-0155; EPA ICR No. 1715.13; entitled “TSCA Sections 402 and 

Section 404 Training, Certification, Accreditation and Standards for Lead-Based Paint 

Activities and Renovation, Repair, and Painting”; approved through December 31, 2015.

2) OMB Control No. 2070-0158; EPA ICR No. 1669.06; entitled “Lead-Based Paint PreRenovation Information Dissemination – TSCA Sec. 406(b)”; approved through April 30, 

2015.

3) OMB Control No. 2070-0181; EPA ICR No.2381.02; entitled “ICR for the Final Rule 

entitled “Lead; Clearance and Clearance Testing Requirements for the Renovation, 

Repair, and Painting Program; Final Rule” (RIN 2070–AJ57); approved through April 30, 

2015.

EPA is currently soliciting comments on this new ICR pursuant to PRA §3506(c)(2)(A) and 5 

CFR 1320.8(d)(1). Please note that EPA is currently seeking to renew these three ICRs , 

unchanged from what is currently approved, in order to ensure that this consolidated ICR can 

complete the required PRA process.

Comment on 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 comments to (1) EPA online through 

http://www.regulations.gov and (2) OMB via email to oira_submission@omb.eop.gov and 

address your comments to the OMB Desk Officer for EPA. Include docket ID No. EPA-HQOPPT-2014-0486 and OMB control number 2070-New; in any correspondence but do not 

submit any other related information (e.g., forms, reports, etc.) to these addresses.

1(d). Abstract

This consolidated ICR will cover the information collection activities associated with the 

reporting and recordkeeping requirements for individuals, firms and state and local government 

entities conducting lead-based paint activities or renovations of target housing and childoccupied facilities; training providers; and states/territories/tribes/Alaskan native villages.

Legal authority: The Toxic Substances Control Act (TSCA), 15 U. S. C. 2601 et seq. In 

particular, sections 401, 402, 404, and 406; and related implementing regulations in 40 CFR 

part 745. More details are provided in Unit 2(a) of this Supporting Statement.

Respondents/affected entities: Entities potentially affected by this ICR are include 

persons who are engaged in lead-based paint activities and/or perform renovations of target 

housing or child-occupied facilities for compensation, dust sampling, or dust testing; or who 

perform lead-based paint inspections, lead hazard screens, risk assessments or abatements in 

target housing or child-occupied facilities; or who provide training or operate a training program 

for individuals who perform any of these activities; or state, territorial or Native American 

agencies that administer lead-based paint activities and/or renovation programs.
Page 3 of 28

Respondent’s obligation to respond: Responses are mandatory under TSCA (see 40 

CFR part 745).

Confidentiality of responses: Respondents may claim all or part of a document 

submitted to be as confidential. EPA will disclose information that is covered by a claim of 

confidentiality only to the extent permitted by, and in accordance with, the procedures in TSCA 

section 14 and 40 CFR part 2.

Estimated total number of potential respondents: 588,357.

Frequency of response: On occasion.

Estimated total annual burden: 5,585,213 hours. Burden is defined at 5 CFR 1320.3(b).

Estimated total annual costs: $ 277,147,047, which includes no annualized capital 

investment or maintenance and operational costs.

Changes in the estimates: The consolidation of the currently approved ICRs is expected 

to result in an overall decrease of 444,089 hours in the total estimated combined respondent 

burden that is currently approved by OMB. This decrease reflects changes in EPA's estimates 

of the burden including: revisions to the estimated number of respondents based on the 

number of respondents reporting to EPA for the prior information collection; the fact the 

housing market and related industries including housing rentals, property management and 

building renovation have yet to recover from the drop in the housing market; and the 2008 

Renovation, Repair and Painting (RRP) rule and the 2010 Opt-Out rule have been in place for 

several years and the ICR estimates can use actual certification data instead of making 

broader assumptions about industry behavior. Further details about these changes are 

included in this ICR supporting statement. This change is an adjustment.

2. NECESSITY OF THE INFORMATION COLLECTION

2(a). Related Legal and/or Administrative Requirements

The related legal authority is the Toxic Substances Control Act (TSCA), 15 U. S. C. 2601 et 

seq., with related requirements provided in 40 CFR part 745. The various applicable sections 

are provided in Attachment 1 and are briefly summarized here along with their implementing 

regulations, which are provided in Attachment 2.

TSCA section 401 defines target housing as any housing constructed before 1978 except 

housing for the elderly or disabled or 0-bedroom dwellings.

TSCA section 402(a) and 402(c)(3) require EPA to develop and administer a training and 

certification program as well as work practice standards for persons who perform lead-based 

paint activities and/or renovations. The current regulations in 40 CFR part 745, subpart E, 

cover work practice standards, recordkeeping and reporting requirements, individual and firm 

certification, and enforcement for renovations done in target housing or child-occupied 

facilities. The current regulations in 40 CFR part 745, subpart L, cover inspections, lead hazard 
Page 4 of 28

screens, risk assessments, and abatement activities (referred to as “lead-based paint 

activities”) done in target housing and child-occupied facilities. The current regulations in 40 

CFR part 745, subpart Q, establish the requirements that state or tribal programs must meet 

for authorization to administer the standards, regulations, or other requirements established 

under TSCA section 402. (See Attachment 2 for 40 CFR 745, Subparts E, L and Q.) Section 

401 of TSCA defines target housing as any housing constructed before 1978 except housing 

for the elderly or disabled or 0-bedroom dwellings.

TSCA section 406(b) requires EPA to promulgate regulations applicable to all renovations of 

target housing or child-occupied facilities (COFs) performed for compensation, except as 

otherwise specified, at 40 CFR part 745, subpart E to provide a lead hazard information 

pamphlet (attachment 10) to the owner and occupant of such housing no more than 60-days 

prior to commencing the renovation.

In addition, EPA has developed extensive guidance and other materials that are available at 

http://www.ep.gov/lead.

The following provides a general overview for requirements covered in this ICR for each entity:

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

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

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

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

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

undertake to demonstrate compliance with standards and provide a written record for future 

reference.

In addition, for renovations in child-occupied facilities, the rule requires firms to provide the 

building owner and adult representative of the child-occupied facility with a lead hazard 

information pamphlet. After providing the pamphlet to the owner and occupant and obtaining 

written acknowledgment, the firm must keep acknowledgment records on file for three years 

after completion of work. Renovation firms must also either (i) provide the lead hazard 

information pamphlet and general information on the renovation to parents or guardians of 

children under age 6 using the facility, or (ii) erect signs that provide general information on the 

renovation accompanied by the pamphlet or information on how to obtain a copy of it. The final 

Clearance rule modified some of the mandatory work practices for firms, but did not impose 

any additional reporting or recordkeeping requirements on firms.

In addition, under TSCA section 406(b), firms that perform renovations of target housing or 

child-occupied facilities (COFs) for compensation, except as otherwise specified, at 40 CFR 

part 745, subpart E, must provide a lead hazard information pamphlet (developed under 

section 406(a) of TSCA) to the owner and occupant of such housing no more than 60-days 

prior to commencing the renovation. The firm performing renovations also must prepare, sign, 

and date a statement describing the steps performed to notify all occupants of the intended 

renovation activities and to provide the pamphlet (section 745.84(b)(3)). If the scope, locations, 

or expected starting and ending dates of the planned renovation activities change after the 
Page 5 of 28

initial notification, the firm performing the renovation must provide further written notification to 

the owners and occupants providing revised information on the ongoing or planned activities.

This subsequent notification must be provided before the firm performing the renovation 

initiates work beyond that which was described in the original notice (section 745.84(b)(4)).

Firm must retain and, if requested, make available to EPA all records necessary to 

demonstrate compliance with the requirements of 40 CFR part 745, subpart E, for a period of 

three years following completion of the renovation activities in target housing or COFs.

Individuals: Individuals who wish to perform lead-based paint activities in target housing or 

child-occupied facilities must also receive certification from EPA/states. To obtain certification, 

an individual must complete an accredited training course and receive a course completion 

certificate, pass a third-party certification exam, meet specific education/experience 

requirements, and demonstrate this to EPA/states.

Individuals certified to perform lead-based paint activities must take a refresher course and 

apply for re-certification every three years (five for individuals who have passed a proficiency 

test as part of their training) (see attachment 5). The rule also requires individuals to develop 

records of the lead-based paint activities and renovations they undertake to demonstrate 

compliance with standards and provide a written record for future reference. These notification 

and recordkeeping requirements are necessary to provide EPA compliance monitoring and 

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

inspections.

Training providers: Training programs seeking to offer training for inspectors, risk assessors, 

project designers, abatement supervisors, abatement workers, renovators or dust sampling 

technicians must obtain EPA/state accreditation. In order for EPA/states to have the 

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

prepare and submit application packages (see Attachment 3). Once accredited, if there are 

any changes in the information submitted on the application, the training provider must submit 

an amendment to the EPA or the State, as applicable. Training programs also must maintain 

certain records related to their students and the qualifications of their training personnel. 

Training programs also must maintain certain records related to their students and training 

personnel qualifications. Training programs are required to notify the Agency (i) prior to 

providing training courses, and (ii) following completion of training courses. Training programs 

must apply for re-accreditation every four years. These notification requirements are necessary 

to provide EPA compliance monitoring and enforcement personnel with information necessary 

to track compliance activity and to prioritize inspections. The final Clearance rule made several 

minor modifications to the accreditation application package requirements and the notification 

requirements.

States: Under TSCA section 404, EPA must review and assess state submissions to 

determine whether to grant authorization to administer a program addressing training, 

certification, accreditation and standards for lead-based paint activities or renovation, repair, 

and painting. A state seeking authorization will need to provide information to EPA so the 

Agency may determine whether its program is at least as protective of human health and the 

environment as the federal program and whether it provides adequate enforcement.

Authorized states need to provide a report to EPA on their activities. The final Clearance rule 
Page 6 of 28

modified the minimum elements required for State programs in order to demonstrate that they 

are at least as protective as the Federal program. The final Clearance rule did not impose 

additional reporting or recordkeeping requirements on States.

Sections 402(a) and 402(c)(3) of TSCA require reporting and/or recordkeeping from four 

entities: firms engaged in lead-based paint activities or renovations in target housing and childoccupied facilities; individuals who perform lead-based paint activities in target housing and 

child-occupied facilities; training providers; and states/territories/tribes/Alaskan native villages 

(hereafter, the term “states” includes territories/tribes/villages).

2(b). Necessity of the Information Collection

The information collection activities covered by this ICR are necessary components of the 

Lead Program established under the TSCA mandates.

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

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

trained; that training programs are accredited; and that contractors engaged in such activities 

are certified. Such regulations shall contain standards for performing lead-based paint 

activities, taking into account reliability, effectiveness and safety.”

TSCA section 402(a)(2) states that “Final regulations promulgated under [section 402(a)] 

paragraph (1) shall contain specific requirements for the accreditation of ... training programs 

... including, but not limited to:

- Minimum requirements for the accreditation of training providers;

- Minimum training curricula requirements;

- Minimum training hour requirements;

- Minimum hands-on training requirements;

- Minimum training competency and proficiency requirements;

- Minimum requirements for training program quality.

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

apply to renovation and remodeling activities that create lead-based paint hazards.

Section 404(a) of TSCA states that “[a]ny State which seeks to administer and enforce the 

standards, regulations, or other requirements established under Section 402 may...develop 

and submit to the Administrator an application, in such form as the Administrator shall require, 

for authorization of such a State program.” The Agency shall approve such an application, if it 

finds that “...the State program is at least as protective of human health and the environment 

as the Federal program under section 402...and such State program provides adequate 

enforcement.” The statute also requires the Agency to implement the program in states that do 

not receive authorization.

TSCA section 407 states that regulations shall include such recordkeeping and reporting 

requirements as may be necessary to ensure effective implementation.
Page 7 of 28

TSCA section 406(b) requires EPA to promulgate regulations requiring certain persons who 

perform renovations of target housing for compensation to provide a lead hazard information 

pamphlet to the owner and occupant of such housing prior to commencing the renovation.

Regulations promulgated under the authority of section 406(b) of TSCA ensure that owners 

and occupants of target housing are provided information concerning potential hazards of leadbased paint exposure before certain renovations are begun on that housing. The Agency 

believes that the distribution of the pamphlet will help to reduce the exposures that cause 

serious lead poisonings, especially in children under age six, who are particularly susceptible 

to the hazards of lead.

2(c). Uses, Users, and Purpose of the Information Collection

Owners/Occupants of target housing and child-occupied facilities, child-occupied facility 

operators, and parents/guardians. The owner/occupant of target housing or a child-occupied 

facility must be provided with a lead hazard information pamphlet before any renovation 

commences. If the child-occupied facility is not operated by the owner of the building, an adult 

representative of the child-occupied facility must also be provided with a lead hazard

information pamphlet. Parents and guardians of children using child-occupied facilities must be 

provided with general information on the renovation as well as the pamphlet, or information on 

how to obtain a copy of the pamphlet.

Information contained in this pamphlet may be used by homeowners/occupants, public or 

commercial building owners, child-occupied facility operators, and parents or guardians to take 

appropriate precautions to minimize the exposure of children to lead-based paint hazards 

created by renovations. Parents and guardians may also use general information about the 

renovation for the purpose of minimizing the exposure of their children to lead-based paint 

hazards created by renovations.

The record of compliance could also serve as a crucial piece of information in civil actions to 

establish liability.

EPA. This information collection will provide EPA with materials necessary to authorize state 

renovation and training rule programs and to serve as the accrediting and certifying body in 

states without authorized programs (discussed further below).

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

the requirements for training, certification, accreditation, and work practice standards for 

renovations and lead-based paint activities. Without this collection, there would be no 

meaningful way of ensuring the implementation of the statutory objective: to ensure that 

trained individuals conduct renovations and lead-based paint activities in such a way as to 

minimize potential harm to occupants. The final Clearance rule made several minor 

modifications to the training provider accreditation application package requirements and the 

training provider notification requirements. These modifications were designed to improve the 

ability of EPA and the States to administer training accreditation programs.

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

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

these activities are central to the activity. In addition, EPA will be relying on training provider 
Page 8 of 28

notifications to keep track of which individuals have received accredited renovator training.

This information will be a critical part of EPA’s compliance monitoring and enforcement 

activities.

The re-certification and re-accreditation requirements for individuals and training programs are 

meant to ensure that training programs incorporate new developments and technologies in 

their courses and provide training to individuals. The Agency believes this will ensure that 

individuals and firms conduct renovations and lead-based paint activities in the safest and 

most effective manner possible.

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

building owners/occupants, EPA or authorized entities. These records demonstrate that the 

activities are done in a safe and effective manner, according to the minimum work practice 

standards established by the rules. These recordkeeping requirements are also necessary to 

permit the Agency to target its enforcement activities and to ensure compliance within the 

contracting and training community.

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

3(a). Non-Duplication

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

any other collection. There is no other Federal program for lead-based paint activities and 

renovations, or associated State program approval process, and there are currently no other 

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

for the accreditation of training programs, required standards for the conduct of these activities, 

or lead hazard information distribution requirements for renovations in target housing or childoccupied facilities.

3(b). Consultations and Public Comments

In addition to the public notice and comment period, OMB regulations, at 5 CFR 1320.8(d)(1), 

require agencies to consult with potential ICR respondents and data users about specific 

aspects of an ICR before the Agency submits the ICR to OMB for review and approval. In 

accordance with this regulation, EPA will pursue additional consultations with interested parties 

during the development of the renewal of this collection.

3(c). Effects of Less Frequent Collection

Due to the nature of the renovation and lead-based paint activities regulations and their related 

information collection activities, less frequent collection is not feasible. In particular, each 

individual and firm must obtain certification and re-certification, each training program must 

obtain accreditation and re-accreditation as well as specific notification and documentation 

prior to commencement and upon completion of each lead-based paint activity and renovation 

course, and each lead-based paint activity is a separate and unique event requiring specific 

notification and documentation. Program approval for states is a one-time activity, although 

there is ongoing reporting.
Page 9 of 28

The 406(b) information distribution requirements at 40 CFR part 745, subpart E, do not include 

any reporting requirements, only recordkeeping requirements. Therefore, a collection schedule 

is not applicable.

3(d). Small Entity Flexibility

EPA believes that the regulatory requirements do not unduly burden small businesses. The 

certification process for firms and individuals is very simple. EPA allows flexibility in the way 

that information is prepared and presented, in that there are no mandatory forms to complete, 

CDX can be used in many instances, and faxed notifications are also permitted. In addition, as 

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

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

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

preamble to the 2008 RRP rule. The Clearance final rule imposed minimal additional burden 

on the estimated 159 small business training providers affected.

In promulgating the regulations at 40 CFR part 745, subpart E, EPA attempted to minimize the 

406b reporting and recordkeeping burden for both large and small regulated entities. While 

small businesses constitute the majority of affected entities, hour and cost burden imposed by 

the regulations is not considered to be of sufficient magnitude to have significant economic 

impacts on such establishments.

3(e). General PRA Related Guidelines

This ICR is consistent with OMB’s general guidelines. Firms are required to maintain records 

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

Authorized States must report once a year for the first three years, and biannually thereafter.

The final Clearance rule requires training providers to maintain records of renovation and dust 

sampling technician training courses for five years, because five years is the length of the 

refresher training cycle for certified renovators and dust sampling technicians.

The 406(b) information distribution requirements at 40 CFR part 745, subpart E do not exceed 

any of the Paperwork Reduction Act guidelines at 5 CFR 1320.5.

3(f). Confidentiality

The regulations for the TSCA Section 402 and Section 404 Training, Certification, 

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

Painting do not address questions of a confidential nature.

Since the 406(b) information distribution requirements at 40 CFR part 745, subpart E involve 

only recordkeeping and 3rd-party notifications, EPA does not believe that respondents submit 

any information to the Agency or that, in doing so, would assert a confidentiality claim for 

information collected under this ICR. However, to the extent information submitted by 

respondents is business confidential, procedures are in place to protect the information from 

improper disclosure consistent with section 14 of TSCA; 40 CFR part 2, subpart B; and 40 

CFR 745.84.
Page 10 of 28

3(g). Sensitive Questions

This information collection does not include questions of a sensitive nature.

4. AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND 

INFORMATION MANAGEMENT

4(a). Agency Activities

EPA will perform the following activities in response to the submittals related to renovation and 

lead-based paint activity submissions:

• Receive, review, and act on applications from states

• Receive, review, and file reports from authorized states

• Receive, review, and act on applications and amended applications for accreditation 

from training providers

• Receive, review, and file notices of trainings from training providers 

• Receive, review, and file materials sent from accredited training providers

• Receive, review, and act on certification applications from firms/individuals

• Receive, review, and file notices of abatement activities from certified abatement firms.

There are no Agency activities associated with the distribution of the 406(b) lead hazard 

information pamphlets to owners and occupants of target housing and COFs prior to 

commencing renovations for compensation.

4(b). Estimated Agency Costs

EPA estimates that it costs the agency approximately $3,590,392 to carry out the activities 

associated with the information collection activities covered by this ICR. This ICR renewal 

includes a cost estimate for the administration of the LBP and RRP programs by the Agency.

The per-activity burdens are taken from those derived in EPA’s (2009) Economic Analysis for 

the TSCA Section 402 Lead-Based Paint Program Accreditation and Certification Fee Rule.1

The numbers of events are estimated for each respondent type, and following the previously 

approved ICR (EPA ICR No. 1715.10).

The Agency will make use of existing technology to simplify the application and notification 

processes where available. In addition to the more traditional methods (mail, commercial 

delivery service, or hand delivery), the Agency will accept faxed course notifications from 

training providers as well as notifications through EPA’s Central Data Exchange (CDX). E-mail 

notification must be followed by a written notification for the record, but the original e-mail 

notice would satisfy the applicable notification time requirements. In addition, lead abatement 

and evaluation firms may use CDX to apply for certification and re-certification, but individuals, 

renovation, repair, and painting firms must apply by mail.

There are no Agency activities associated with the distribution of the 406b lead hazard 

information pamphlet to owners and occupants of target housing and COFs prior to 

 

1 Burdens were rounded to the nearest significant two digits and burdens less than 0.01 were rounded up to 0.01.
Page 11 of 28

commencing renovations for compensation. However, under the provisions of 40 CFR 745.87, 

EPA may conduct inspections and issue subpoenas pursuant to the provisions of TSCA 

section 11 (15 U.S.C. 2610) to ensure compliance with 40 CFR part 745, subpart E.

4(b)(i). Collection Schedule

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

following schedule:

- Training programs may apply for accreditation at any time;

- Training programs must amend their applications when information changes, and the 

Clearance final rule establishes requirements for amending applications;

- Training programs must seek re-accreditation at four-year intervals following initial 

accreditation;

- Training programs submit notification of training to EPA before each course;

- Training programs submit post-training notification to EPA after each course;

- Firms may apply for certification at any time;

- Firms must amend their applications when information changes;

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

- Renovators and dust sampling technicians may take training at any time;

- Renovators and dust sampling technicians must take refresher training at five-year 

intervals following initial training;

- States may apply for authorization at any time;

- Authorized States must report once a year for the first three years, and biannually 

thereafter;

- Firms/individuals must apply for re-certification every three years (five for individuals 

who have passed a proficiency test as part of their training) after initial certification for 

lead-based paint activities.

The Agency believes that receipt of notification of five and seven business days respectively 

prior to conducting lead-based paint abatement activities or training courses is necessary to 

facilitate the inspection of abatement and training locations. The regulation also includes 

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

for initial notification will also apply to a change in course location, or if the course is to be 

presented earlier than described in the original notification. Other changes, including 

cancellation of courses or abatement projects, need only be received by the Agency at least 

two business days before a training course is scheduled to begin, or by the start date of an 

abatement activity. Such notification periods are appropriate to allow proper allocation of EPA 

compliance monitoring and enforcement resources, and to prevent the arrival of Agency 

personnel at the wrong location or time.

The 406(b) information distribution requirements at 40 CFR part 745, subpart E, do not include 

any reporting requirements, only recordkeeping requirements. Therefore, a collection schedule 

is not applicable.

4(b)(ii). Use of Technology to Facilitate Collection Activities

The Agency will make use of existing technology to simplify the application and notification 

processes where available. In addition to the more traditional methods (mail, commercial 
Page 12 of 28

delivery service, or hand delivery), the Agency will accept faxed course notifications from 

training providers as well as notifications through EPA’s Central Data Exchange (CDX). E-mail 

notification must be followed by a written notification for the record, but the original e-mail 

notice would satisfy the applicable notification time requirements. In addition, lead abatement 

and evaluation firms may use CDX to apply for certification and re-certification, but individuals, 

renovation, repair, and painting firms must apply by mail. EPA is currently modifying CDX to 

allow individuals and RRP firms to apply through CDX further simplifying these application 

processes.

5. The RESPONDENTS AND INFORMATION COLLECTION (IC) ACTIVITIES

For each respondent category, this section of the ICR describes the respondents, the 

information collection activities and related estimates for burden and costs associated with 

those activities.

5(a). Methodology for Estimating Respondent Burden and Costs

The lead-based paint activities and renovation, repair, and painting regulations specify 

reporting and recordkeeping for training providers and individuals/firms undertaking lead-based 

paint activities and/or renovations in target housing and child-occupied facilities.

The North American Industrial Classification System (NAICS) codes associated with industries 

most likely affected by the paperwork requirements are described below: 

236115 Single Family Housing Construction

236116 Multifamily Housing Construction

236210 Manufacturing and Industrial Building Construction

236220 Commercial and Institutional Building Construction

238220 Plumbing, Heating, and Air-Conditioning Contractors

238320 Painting and Wallpapering

238210 Electrical Contractors

238140 Masonry and Stone Contractors

238310 Drywall, Plastering, Acoustical, and Insulation Contractors

238340 Tile (except resilient) Contractors

238350 Carpentry Contractors

238330 Floor Laying and Other Floor Contractors

238160 Roofing, Siding, and Sheet Metal Contractors

238110 Concrete Contractors

213111 Water Well Drilling Contractors

238120 Structural Steel Erection Contractors

238210 Electrical Contractors and Other Wiring Installation Contractors

238910 Excavation Contractors

238910 Wrecking and Demolition Contractors

238290 Other Building Equipment Contractors

238390 Building fixture and fitting (except mechanical equipment) installation

236118 Residential Remodelers

238150 Glass and Glazing Contractors
Page 13 of 28

238170 Siding Contractors

238210 Electrical Contractors

238220 Plumbing, Heating, and Air-Conditioning Contractors

238290 Other Building Equipment Contractors

238310 Drywall and Insulation Contractors

238340 Tile and Terrazzo Contractors

238350 Finish Carpentry Contractors

238390 Other Building Finishing Contractors

531110 Lessors of Residential Buildings and Dwellings

531190 Lessors of Other Real Estate Property

531210 Offices of Real Estate Agents and Brokers

531311 Residential Property Managers

531320 Offices of Real Estate Appraisers

531390 Other Activities Related to Real Estate

541330 Engineering Services

541350 Building Inspection Services

562910 Remediation Services

611110 Elementary and Secondary Schools

611513 Apprenticeship Training

611519 Other Technical and Trade Schools

611699 All Other Miscellaneous Schools and Instruction

624410 Child Day Care Services

923120 Administration of Public Health Programs

924110 Administration of Air and Water Resource and Solid Waste Management 

Programs

925110 Administration of Housing Programs

5(b).

IC #1: LBP training provider accreditation applications, training notifications, and 

recordkeeping

Respondent NAICS Codes

611513 Apprenticeship Training

611519 Other Technical and Trade Schools

611699 All Other Miscellaneous Schools and Instruction

Information Collection Activities

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

providers must submit the following documents to EPA/state, using the form entitled either the 

sample EPA Form 8500-25, entitled “Accreditation Application for Training Programs” or a 

similar form.

Training providers are required to include documentation of training manager and principal 

instructor qualifications with their accreditation applications. In addition, if training providers 
Page 14 of 28

wish to use course materials approved by authorized State programs, the providers must 

submit copies of the course materials along with their applications.

On occasion, training providers may later amend their accreditation application to add or 

modify information. Accredited training providers must apply for re-accreditation every four 

years.

Before giving a lead-based paint activity training, training providers must provide notification to 

the Agency, using either the sample form entitled “Lead-Based Paint Activities and Renovation 

Training Notification” (see Attachment 6) or a similar form containing the required information.

Training providers may provide electronic submissions using the Agency’s secure, Internetbased Central Data Exchange (CDX). (The paperwork activities, related burden and costs with 

CDX user registration are described in an ICR approved under OMB Control No. 2025-0003.)

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

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

Following completion of lead-based paint activities training providers must provide notice using 

either the sample form entitled “Lead-Based Paint Activities and Renovation Post-Training 

Notification” (see Attachment 7) or a similar form containing the required information. Training 

providers may submit electronic submissions using the Agency’s CDX.

Training course providers must maintain records of the qualifications of key staff, current 

course materials, a quality control plan, results of hands-on assessments and course tests and 

a record of each student’s course completion certificate.

Providers of e-learning courses are required to maintain records on each student’s course logins, launches, progress, and completion.
Page 15 of 28

IC# 1. LBP training provider accreditation applications, training notifications, and 

recordkeeping

Citation: 40 CFR 745, subpart L

Data Element (w/ hyperlinks) Form Responses Burden Cost

LBP activity training providers / 

initial accreditation / reporting 8500-25 347 9,529 472,053 

LBP activity training providers / 

renewal accreditation / reporting N/A 

1,235 6,626 314,962 

LBP activity training providers / 

pre-training notification / 

reporting

Training Notification 

13,132 2,626 71,955 

LBP activity training providers / 

pre-training re-notification / 

reporting

N/A 

5,628 1,126 30,838 

LBP activity training providers / 

post-training notification / 

reporting

Post-Training 

Notification

 

7,504 11,744 300,772 

LBP training providers / 

recordkeeping 8500-25 

1,876 1,623 41,154 

Total 

 

29,722 

 

33,273 $ 1,231,734 

IC #2: LBP activity firm certification activities

Respondent NAICS Codes

562910 Remediation Services

Information Collection Activities

To obtain firm certification to perform lead-based paint activities or renovations in target 

housing or child-occupied facilities, firms must submit specific materials to EPA/state, using the 

Agency’s CDX, the EPA form “Application for Firms to Conduct Lead-based Paint Activities or 

Renovations” (EPA Form 8500-27; see Attachment 4) or a similar form requiring the same 

information.

Firms may later amend their applications to add or modify information. Lead-based paint 

activities firms must be recertified every three years.

Firms seeking certification for lead-based paint activities must perform the following activities:

 Read the regulation.

 Sign a statement certifying that the firm will only employ appropriately qualified 

individuals to conduct lead-based paint activities, and that the firm and its employees 

shall follow the work practice standards in 40 CFR 745.227.

 Retain Records of individuals that conduct lead-based paint activities, and that the 

firm and its employees shall follow the work practice standards in 40 CFR 745.227.

IC# 2. LBP activity firm certification activities
Page 16 of 28

Citation: 40 CFR 745, subpart L

Data Element (w/ hyperlinks) Form Responses Burden Cost

LBP activity firms / initial certification / 

reporting EPA Form 8500-27 

4,235 31,614 1,694,741 

LBP activity firms / renewal certification / 

reporting EPA Form 8500-27 

4,882 7,152 384,186 

LBP firms / certification / recordkeeping EPA Form 8500-27 

9,117 91 2,402 

Total 

 

18,234 38,858 $ 2,081,329 

IC #3: Individuals performing LBP abatement activities; certification and 

accreditation / reporting and recordkeeping Respondents

Respondent NAICS Codes

562910 Remediation Services

Information Collection Activities

Individuals who wish to perform lead-based paint activities in target housing or child-occupied 

facilities must also receive certification from EPA/states. To obtain certification, an individual 

must complete an accredited training course and receive a course completion certificate, pass 

a third-party certification exam, meet specific education/experience requirements, and 

demonstrate this to EPA/states.

Individuals certified to perform lead-based paint activities must take a refresher course and 

apply for re-certification every three years (five for individuals who have passed a proficiency 

test as part of their training). The rule also requires individuals to develop records of the leadbased paint activities and renovations they undertake to demonstrate compliance with 

standards and provide a written record for future reference. These notification and 

recordkeeping requirements are necessary to provide EPA compliance monitoring and 

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

inspections.

IC# 3. Individuals performing LBP abatement activities; certification and 

accreditation/reporting and recordkeeping

Citation: 40 CFR 745, subpart L

Data Element (w/ hyperlinks) Form Responses Burden Cost

Individuals performing LBP abatement 

activities; certification and accreditation / 

reporting and recordkeeping

EPA 747-B-99-002 31,168 24,906 $ 920,078 
Page 17 of 28

IC# 4: LBP activity firm pre-abatement reports and occupant protection plans, 

abatement activity notifications, post-abatement reports and recordkeeping

Respondent NAICS Codes

562910 Remediation Services

Information Collection Activities

In the performance of lead-based paint activities, firms/individuals must complete and retain a 

number of reports (contingent on the activity conducted), including an inspection report, a lead 

hazard screen report, a risk assessment report, an occupant protection plan, and an 

abatement report.

Certified firms must notify EPA prior to beginning lead-based paint abatement activities (except 

in emergency situations) and provide an updated notice if needed, using either the sample 

form entitled “Notification of Lead-Based Paint Abatement Activities” (see Attachment 8) or a 

similar form containing the required information. Certified firms may also provide electronic 

submissions using the Agency’s CDX.

IC# 4. LBP activity firm pre-abatement reports and occupant protection plans, abatement 

activity notifications, post-abatement reports and recordkeeping 
Page 18 of 28

 IC# 5: RRP training provider accreditation applications, training notifications, and 

recordkeeping

Respondent NAICS Codes

611513 Apprenticeship Training

611519 Other Technical and Trade Schools

611699 All Other Miscellaneous Schools and Instruction

Information Collection Activities

Training programs seeking to offer training for inspectors, risk assessors, project designers, 

abatement supervisors, abatement workers, renovators or dust sampling technicians must 

obtain EPA/state accreditation. In order for EPA/states to have the information necessary to 

evaluate and accredit the training programs, training providers must prepare and submit 

application packages (see Attachment 3). Once accredited, if there are any changes in the 

information submitted on the application, the training provider must submit an amendment to 

the EPA or the State, as applicable. Training programs also must maintain certain records 

related to their students and the qualifications of their training personnel. Training programs 

also must maintain certain records related to their students and training personnel 

qualifications. Training programs are required to notify the Agency (i) prior to providing training 

courses, and (ii) following completion of training courses. Training programs must apply for reaccreditation every four years. These notification requirements are necessary to provide EPA 

Citation: 40 CFR 745, subpart L

Data Element (w/ hyperlinks) Form Responses Burden Cost

LBP activity firms / evaluation 

reports / reporting EPA Form 8500-27 

218,816 402,402 21,626,357 

LBP activity firms / post-abatement 

report / reporting

Sample Renovation 

Recordkeeping 

Checklist

 

13,676 26,873 1,443,974 

LBP activity firms / occupant 

protection plan / reporting None 

13,676 13,197 711,214 

LBP activity firms / pre-abatement 

notifications / reporting

Notification of LeadBased Paint 

Abatement Activities

 

13,676 6,359 347,699

LBP firms / reports / recordkeeping

Notification of LeadBased Paint 

Abatement Activities, 

Sample Renovation 

Recordkeeping 

Checklist

 

259,844 2,598 2,598 

LBP activity firms / pre-abatement 

re-notifications / reporting

Notification of LeadBased Paint 

Abatement Activities

 524 112 6,248 

LBP Firms / re-notifications / 

recordkeeping

Notification of LeadBased Paint 

Abatement Activities

 524 5 

5 

Total 520,736 451,547 $ 24,138,096
Page 19 of 28

compliance monitoring and enforcement personnel with information necessary to track 

compliance activity and to prioritize inspections. The final Clearance rule made several minor 

modifications to the accreditation application package requirements and the notification 

requirements.

The final Clearance rule made several minor modifications to the training provider accreditation 

application package requirements and the training provider notification requirements. These 

modifications were designed to improve the ability of EPA and the States to administer training 

accreditation programs.

It is the nature of accreditation that an entity seeking such must provide materials to the 

accrediting body. The materials the Agency/state requires for these activities are central to the 

activity. In addition, EPA will be relying on training provider notifications to keep track of which 

individuals have received accredited renovator training. This information will be a critical part of 

EPA’s compliance monitoring and enforcement activities.

The re-certification and re-accreditation requirements for training programs are meant to 

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

and provide training to individuals. The Agency believes this will ensure that individuals and 

firms conduct renovations and lead-based paint activities in the safest and most effective 

manner possible.
Page 20 of 28

IC# 6: Private RRP firm certification activities

Respondent NAICS Codes

236115 Single Family Housing Construction

236116 Multifamily Housing Construction

236210 Manufacturing and Industrial Building Construction

236220 Commercial and Institutional Building Construction

238220 Plumbing, Heating, and Air-Conditioning Contractors

238320 Painting and Wallpapering

238210 Electrical Contractors

238140 Masonry and Stone Contractors

238310 Drywall, Plastering, Acoustical, and Insulation Contractors

238340 Tile (except resilient) Contractors

238350 Carpentry Contractors

238330 Floor Laying and Other Floor Contractors

238160 Roofing, Siding, and Sheet Metal Contractors

238110 Concrete Contractors

213111 Water Well Drilling Contractors

238120 Structural Steel Erection Contractors

238210 Electrical Contractors and Other Wiring Installation Contractors

C# 5. RRP training provider accreditation applications, training notifications, and recordkeeping

Citation: 40 CFR 745, subpart E

Data Element (w/ hyperlinks) Form Responses Burden Cost

RRP training providers / initial 

accreditation / reporting EPA Form 8500-25 265 7,314 361,960 

RRP training providers / reaccreditation / 

reporting None 67 630 31,097 

Accredited Cohort Rule Familiarization 

Maintenance None 329 658 35,256 

RRP training providers / pre-training 

notification / reporting Training Notification 

9,254 1,851 50,358 

RRP training providers / pre-training renotification / reporting Training Notification 

1,322 264 7,194 

RRP training providers / post-training 

notification / reporting

Post-Training 

Notification

 

9,254 14,427 369,164 

RRP training providers / digital 

photographs / reporting None 

9,254 11,651 298,788 

RRP training providers / recordkeeping EPA Form 8500-25 661 634 15,087 

Total

 

30,406 37,429 $ 1,168,903 
Page 21 of 28

238910 Excavation Contractors

238910 Wrecking and Demolition Contractors

238290 Other Building Equipment Contractors

238390 Building Fixture and Fitting (except mechanical equipment) Installation

236118 Residential Remodelers

238150 Glass and Glazing Contractors

238170 Siding Contractors

238210 Electrical Contractors

238220 Plumbing, Heating, and Air-Conditioning Contractors

238290 Other Building Equipment Contractors

238310 Drywall and Insulation Contractors

238340 Tile and Terrazzo Contractors

238350 Finish Carpentry Contractors

238390 Other Building Finishing Contractors

531110 Lessors of Residential Buildings and Dwellings

531190 Lessors of Other Real Estate Property

531311 Residential Property Managers

531390 Other Activities Related to Real Estate

541330 Engineering Services

541350 Building Inspection Services

562910 Remediation Services

611110 Elementary and Secondary Schools

611699 All Other Miscellaneous Schools and Instruction

624410 Child Day Care Services

Information Collection Activities

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

obtain certification from EPA/States. This includes firms consisting only of one self-employed 

individual, and property management companies, building owners, private schools and 

daycare centers performing work with their own employees. To receive certification, a firm 

must submit a letter to EPA/States certifying that it will employ certified renovators and conduct 

renovations in target housing in accordance with the work practice standards. Firms must recertify every five years and maintain a record of their certification.

To obtain firm certification to perform lead-based paint activities or renovations in target 

housing or child-occupied facilities, firms must submit specific materials to EPA/state, using the 

Agency’s CDX, the EPA form “Application for Firms to Conduct Lead-based Paint Activities or 

Renovations” (EPA Form 8500-27; see Attachment 4) or a similar form requiring the same 

information.
Page 22 of 28

IC# 6. Private RRP firm certification activities

Citation: 40 CFR 745, subpart E

Data Element (w/ hyperlinks) Form Responses Burden Cost

Private RRP firms / initial certification / reporting None 

27,916 

 

97,706 4,429,013 

Private RRP firms /recertification / reporting None 

32,627 

 

65,254 2,966,773 

Certified Cohort Rule Familiarization Maintenance None 

184,800 

 

184,800 8,343,720 

RRP firms / certification / recordkeeping None 

60,543 605 15,953 

Total

 

305,886 

 

348,365 

 

$ 15,755,459 

IC# 7: Distribution of pre-renovation lead hazard information pamphlet and postrenovation and post-renovation checklists documenting lead-safe work practices

Respondents NAICS Codes

236115 Single Family Housing Construction

236116 Multifamily Housing Construction

236210 Manufacturing and Industrial Building Construction

236220 Commercial and Institutional Building Construction

238220 Plumbing, Heating, and Air-Conditioning Contractors

238320 Painting and Wallpapering

238210 Electrical Contractors

238140 Masonry and Stone Contractors

238310 Drywall, Plastering, Acoustical, and Insulation Contractors

238340 Tile (except resilient) Contractors

238350 Carpentry Contractors

238330 Floor Laying and Other Floor Contractors

238160 Roofing, Siding, and Sheet Metal Contractors

238110 Concrete Contractors

213111 Water Well Drilling Contractors

238120 Structural Steel Erection Contractors

238210 Electrical Contractors and Other Wiring Installation Contractors

238910 Excavation Contractors

238910 Wrecking and Demolition Contractors

238290 Other Building Equipment Contractors

238390 Building Fixture and Fitting (except mechanical equipment) Installation

236118 Residential Remodelers

238150 Glass and Glazing Contractors

238170 Siding Contractors

238210 Electrical Contractors

238220 Plumbing, Heating, and Air-Conditioning Contractors

238290 Other Building Equipment Contractors

238310 Drywall and Insulation Contractors

238340 Tile and Terrazzo Contractors

238350 Finish Carpentry Contractors
Page 23 of 28

238390 Other Building Finishing Contractors

531110 Lessors of Residential Buildings and Dwellings

531190 Lessors of Other Real Estate Property

531311 Residential Property Managers

531390 Other Activities Related to Real Estate

541330 Engineering Services

541350 Building Inspection Services

562910 Remediation Services

611110 Elementary and Secondary Schools

611699 All Other Miscellaneous Schools and Instruction

624410 Child Day Care Services

Information Collection Activities

No more than 60 days before beginning renovation activities in any residential dwelling unit of 

target housing or COF, the firm performing renovations must provide the owner and or 

occupant(s) of the building with the pre-renovation lead hazard information pamphlet and 

comply with recordkeeping procedures. If the owner does not occupy the dwelling unit, the firm 

performing renovations must provide an adult occupant of the unit with the pamphlet. The firm 

must keep documentation providing proof that the pamphlet was provided to the owner and 

occupant or that an attempt was made to provide the pamphlet to the owner and occupant of 

the target housing (e.g., collect signed acknowledgment form, provide self-certification for 

failed deliveries, and document mailing the information). No more than 60 days before 

beginning renovation activities in common areas, the firm must provide the owner of the multiunit housing or COF with a lead hazard information pamphlet, and comply with recordkeeping 

procedures. In addition, the firm performing renovations must notify in writing, or ensure written 

notification of, occupant of each affected unit and make the pamphlet available upon request 

prior to the start of the renovation. Finally, the firm performing renovations must prepare, sign, 

and date a statement describing the steps performed to notify all occupants of the intended 

renovation activities and to provide the pamphlet.

Firms performing renovations must retain and, if requested, make available to EPA all records 

necessary to demonstrate compliance with the requirements of 40 CFR part 745, subpart E, 

for a period of three years following completion of the renovation activities in target housing.

These requirements include the retention of the acknowledgement of receipt of the lead hazard 

information pamphlet, certifications of attempted delivery, and certifications of mailing.

In the performance of renovation activities, firms are required to maintain records 

demonstrating compliance with the final rule requirements for using certified renovators and 

properly trained workers, posting signs, containing and cleaning the renovation work area, and 

performing a post-renovation cleaning verification or dust clearance testing after renovation 

activity is finished.
Page 24 of 28

IC# 7. Distribution of pre-renovation lead hazard information pamphlet and post-renovation and 

post-renovation checklists documenting lead-safe work practices

Citation: 40 CFR 745 Subpart E

Data Element (w/ hyperlinks) Form Responses Burden Cost

Pre-Renovation Information Dissemination 

by Contractors Working in Occupied Target 

Housing Rental Units

None 

1,621,277 

 

455,579 22,677,042 

Pre-Renovation Information Dissemination 

by Contractors Working in Owner-Occupied 

Target Housing

None 

4,937,525 

 

898,630 46,991,905 

Pre-Renovation Information Dissemination 

by Contractors Working in Vacant Target 

Housing Rental Units and Common Areas

None 

4,912,960 

 

1,301,934 65,169,186 

Pre-Renovation Information Dissemination 

by Contractors Working in Owner-Occupied 

Child-Occupied Facilities and by Landlords 

Working in Rental Child-Occupied Facilities

None 

114,569 

 

30,361 1,519,729 

Pre-Renovation Information Dissemination 

by Contractors Working in Rental ChildOccupied Facilities

None 6,138 2,271 118,497 

Pre-Renovation Information Dissemination 

by Private Schools and Daycare Centers for 

In-House Renovation Activities

None 25,530 5,106 $263,729 

RRP firm checklist / owner-occupied target 

housing / third party disclosure

Sample Renovation 

Recordkeeping 

Checklist

 

6,869,604 

 

343,480 16,195,091 

RRP firm checklist / renter-occupied target 

housing / third party disclosure

Sample Renovation 

Recordkeeping 

Checklist

 

7,360,290 

 

368,015 18,087,913 

RRP firm checklist / in-house or landlord / 

third party disclosure

Sample Renovation 

Recordkeeping 

Checklist

 29,441 1,472 69,407 

RRP firm checklist / owner-occupied childoccupied facility (COF), contractor / third 

party disclosure

Sample Renovation 

Recordkeeping 

Checklist

 

208,542 

 

10,427 491,638 

RRP firm checklist / renter-occupied childoccupied facility (COF), contractor / third 

party disclosure

None 9,814 491 25,099 

RRP Firms / recordkeeping / recordkeeping

Sample Renovation 

Recordkeeping 

Checklist

 

245,343 

 

1,177,646 53,173,188 

Total

 

26,341,033 

 

4,595,411 

 

$ 224,782,425 
Page 25 of 28

IC# 8: Government-employed RRP professional certification activities, distribution of lead 

hazard information pamphlet prior to renovation activities, post-renovation checklists 

documenting lead-safe work practices, and recordkeeping

Respondents NAICS Codes

611110 Elementary and Secondary Schools

611699 All Other Miscellaneous Schools and Instruction

923120 Administration of Public Health Programs

924110 Administration of Air and Water Resource and Solid Waste Management 

Programs

925110 Administration of Housing Programs

Information Collection Activities

No more than 60 days before beginning renovation activities in any residential dwelling unit of 

target housing or COF, the government entity performing renovations must provide the owner 

and or occupant(s) of the building with the pre-renovation lead hazard information pamphlet 

and comply with recordkeeping procedures. If the owner does not occupy the dwelling unit, the 

government entity performing renovations must provide an adult occupant of the unit with the 

pamphlet. The government entity must keep documentation providing proof that the pamphlet 

was provided to the owner and occupant or that an attempt was made to provide the pamphlet 

to the owner and occupant of the target housing (e.g., collect signed acknowledgment form, 

provide self-certification for failed deliveries, and document mailing the information). No more 

than 60 days before beginning renovation activities in common areas, the government entity 

must provide the owner of the multi-unit housing or COF with a lead hazard information 

pamphlet, and comply with recordkeeping procedures. In addition, the government entity 

performing renovations must notify in writing, or ensure written notification of, each affected 

unit and make the pamphlet available upon request prior to the start of the renovation. Finally, 

the government entity performing renovations must prepare, sign, and date a statement 

describing the steps performed to notify all occupants of the intended renovation activities and 

to provide the pamphlet.

Government entities performing renovations must retain and, if requested, make available to 

EPA all records necessary to demonstrate compliance with the requirements of 40 CFR part 

745, subpart E, for a period of three years following completion of the renovation activities in 

target housing. These requirements include the retention of the acknowledgement of receipt of 

the lead hazard information pamphlet, certifications of attempted delivery, and certifications of 

mailing.

Government entities that wish to engage in renovations in target housing or child-occupied 

facilities must obtain certification from EPA/States. This includes government entities

consisting only of one self-employed individual. To receive certification, a government entity

must submit a letter to EPA/States certifying that it will employ certified renovators and conduct 

renovations in target housing in accordance with the work practice standards. Government 

entities must re-certify every five years. The rule also requires government entities to develop 

and retain records of the renovation activities they undertake to demonstrate compliance with 

standards and provide a written record for future reference.
Page 26 of 28

5(c). Total Estimated Respondent Burden and Costs

IC Summary Table

IC Category Responses Burden Cost

IC 1: LBP Training Providers 

29,722 

 

33,273 

 

1,231,734 

IC 2: LBP firm activities 

18,234 

 

38,858 

 

2,081,329 

IC 3: LBP individual activities 

31,168 

 

24,906 

 

920,078 

IC 4: LBP Reports, Plans, 

Notifications and Recordkeeping

 

520,736 

 

451,547 

 

24,138,096 

IC 5: RRP Training Providers 

30,406 

 

37,429 

 

1,168,903 

IC 6: RRP Firm Activities 

305,886 

 

348,365 

 

15,755,459 

IC 7: RRP Pamphlet and 

Checklists

 

26,341,033 

 

4,595,411 

 

224,782,425 

IC 8: RRP Government Firms 

99,291 

 

55,424 

 

3,478,631 

Total 

27,376,476 

 

5,585,213 

 

273,556,655 

6. Changes in Burden and Cost Estimates

This information collection combines the burdens from three previously approved ICRs, EPA 

ICR No. 2381.02, EPA ICR No. 1669.06, and EPA ICR No. 1715.13. The total combined 

burden from these three previously approved ICRs was 6,029,302 hours. The total burden 

IC# 8. Government-employed RRP professional certification activities, distribution of lead 

hazard information pamphlet prior to renovation activities, post-renovation checklists 

documenting lead-safe work practices, and recordkeeping

Citation: 40 CFR 745 subpart E

Data Element (w/ hyperlinks) Form Responses Burden Cost

Initial Certification 1,389 

4,862 261,354 

Renewal Certification 1,597 

8,624 463,069 

Government entities / recordkeeping None 6,670 

32,016 2,106,012 

Government entities / in-house or landlord / third 

party disclosure None 53,360 

2,668 212,319 

Pre-Renovation Information Dissemination by 

Schools for In-House Renovation Activities None 36,275 

7,255 435,876 

Total 99,291 

 

55,424 

 

$3,478,631 
Page 27 of 28

requested for this ICR is 5,585,213 hours, or a decrease of 444,089 hours from the previous 

total burden. The difference between the current burden request and the previously approved 

requests are due to adjustments in EPA’s estimates of the burden. Several adjustments to the 

estimates were made, including:

 Revisions to the estimated number of respondents based on the number of respondents 

reporting to EPA for the prior information collection;

 The housing market and related industries including housing rentals, property managers 

and the building renovation industry have yet to recover from the drop in the housing 

market; and

 The 2008 RRP Rule and the 2010 Opt-Rule have been in place for a few years and the 

ICR estimates can use actual certification data instead of having to make broader 

assumptions about industry behavior and compliance rates.

The total combined cost burden from these three previously approved ICRs was 

$291,575,709. The total cost burden requested for this ICR is $277,147,047. The difference 

between the current cost burden request and the previously approved requests are due only to 

adjustments in EPA’s estimates of the burden. In addition to the adjustments listed above, the 

wage rates and material costs were revised to reflect 2013 dollars for this information 

collection request. In certain disciplines, wage rates have actually decreased, likely due to the 

depressed housing market and overall economy. This combined with reduced burden caused 

the lower cost of this combined ICR.

7. PRA BURDEN STATEMENT

Under the PRA, burden is defined at 5 CFR 1320.3(b).

The response burden for this ICR is estimated to range between 1.2 and 10.2 hours per 

response, depending on the particulars associated with the individual DCI. The total 

annualized burden for this ICR is estimated to be 5,585,213 hours (per year). The response 

cost is estimated to range between $14 and $657 per response, depending on the particulars 

associated with the individual DCI. The total annualized cost for this ICR is estimated to be 

$277,147,047 per year. This estimated total annualized cost includes $55,616,019 for nonburden costs related to mailing and special deliveries for the submissions. Delivery of paper 

submissions will be eliminated with the full implementation of the electronic system that is 

under development.
Page 28 of 28

8. 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-2014-0486. These attachments are 

available for online viewing at www.regulations.gov or otherwise accessed as described in the 

following listing.

Attachment 1: Toxic Substances Control Act (TSCA), 15 U.S.C. 2601 et seq.

Attachment 2: 40 CFR 745, Subparts E, L and Q

Attachment 3: EPA Form 8500-25: Application and Instructions for Training 

Providers Applying for Accreditation of Lead-Based Paint Activity and 

Renovation Training Programs

Attachment 4: EPA Form 8500-27: Application and Instructions for Firms Applying 

for Certification to Conduct Lead-Based Paint Activities and/or

Renovations

Attachment 5: EPA Form 747-B-99-002: Application and Instructions for Individuals 

Applying for Certification to Conduct Lead-Based Paint Activities

Attachment 6: Lead-Based Paint Activities and Renovation Training Notification

Attachment 7: Lead-Based Paint Activities and Renovation Post-Training Notification

Attachment 8: Notification of Lead-Based Paint Abatement Activities

Attachment 9: Sample Renovation Recordkeeping Checklist

Attachment 10: The Lead-Safe Certified Guide to Renovate Right