Page 1 of 28

**Supporting Statement for an Information Collection Request (ICR)** 

**Under the Paperwork Reduction A ct**  **(PRA )**  

### 1. **EXECUTIVE SUMMA RY**  **1(a). Identification of the**  **Information Collection –**  **Title and Numbers**  **Title:** Lead Training, Certification, Accreditation and Authorization Activities
**ICR Number**  **s :**  EPA ICR No.: 2507.01 ; OMB Control No.: 2070
- New

. **EPA Form N**  **umber s:**  EPA Form 8500
- 25 : Application and Instructions for Training Providers Applying for Accreditation of Lead
- Based Paint Activity a nd Renovation Training Programs; EPA Form 8500
- 27 : Application for Firms to Conduct Lead
- based Paint Activities or Renovations ; E PA Form 747
- B
- 99
- 002 : Application and Instructions for Individuals Applying for Certification to Conduct Lead
- Based Pa int Activities

. **Docket ID Number:** EPA
- HQ
- OPPT
- 20 14
- 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. EPA
HQ
- OPPT
- 2014
- 0486 , can be viewed online at http://www.regulations.gov or in person at the EPA Docket Center, William Jefferson Clinton We st Bldg., Rm. 3334, 1301 Constitution Ave., NW ., Wa shington, 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 n umber 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 o f 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, C ertification, 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 Pre
Renovation Information Disse mination

– 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; Fi nal Rule” (RIN 2070

–AJ57) ; approved through April 30, 2015

. EPA is curr ently 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 PR A 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
- HQ
OPPT
- 2014 **-** 04 8 6 and OMB control number 2070
- N ew; in any correspondence but do not submit any other related information (e.g., forms, reports, etc.) to these addresses. **1(d). Ab**  **stract** 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 child
occupied facilities; training providers; and states/territories/tribes /Alaskan native villages. Legal a uthority: The Toxic Substances Control Act (TSCA), 15 U. S. C. 2601 et seq. I n particular, sections 40 1, 40 2, 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/

a ffected e ntities : 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 oper ate 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 mandat ory 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 b y, 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 : $ 2 77,147,047 , 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 bur den 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 inst ead 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 INFORM AT**  **ION COLLECTION 2(a).**  **Related Legal and/or A dministrative**  **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 he re 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 40 2(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 hazardPage 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 stat e 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 h ousing 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 t o 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. To receive certification, a firm must submit a letter to EPA/States certi fy ing 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 a ctivities 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 re novation 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 add ition, 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 (develope d 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 oc cupants 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 thePage 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 t hree 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. I ndividuals 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 nece ssary 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 pro viders 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. Traini ng 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 prov ide 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 a nd 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
- bas ed 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 prog ram and whether it provides adequate enforcement. Authorized states need to provide a report to EPA on their activities. The final Clearance rulePage 6 of 28

modified the minimum elements required for State programs in order to demonstrate that they are at least as pr otective 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
- ba sed paint activities or renovations in target housing and child
occupied facilities; individuals who perform lead
- based paint activities in target housing and child
- occupied facilities; training providers; and states/territories/tribes/Alaskan native villa ges (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. U nder 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 enga ged in such activities are certified. Such regulations shall contain standards for performing lead
- based paint activities, taking into account reliabil ity, 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 require ments;

- 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 re gulations 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 e nforcement.” 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 effe ctive 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 p rior 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 lead
based paint exposure before certain re novations 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 le ad. **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 b e 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 cruci al 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 sta tes 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 t o 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 Ag ency/state requires for these activities are central to the activity. In addition, EPA will be relying on training providerPage 8 of 28

notifications to keep track of which individuals have received accredited renovator training. This information will be a critical pa rt 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 co urses 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 comp ile 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**  **- DUPLICA** **TION, CONSULTA TIONS, 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 inform ation distribution requirements for renovations in target housing or child
occupied 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 dev elopment 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 eac h 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 th e 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 compl ete, 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. Wh ile 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 dist ribution 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 ) inf ormation distribution requirements at 40 CFR part 745, subpart E involve only recordkeeping and 3rd
- party notificat ions, 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 co nfidential, 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 sensit ive nature.
**4.** 

### AG **ENCY ACTIVITIES, COLLECTION METHODOLOGY, AND**  **INFORM AT**  **ION MANA GEMENT**  **4(a). Ag**  **ency A**  **ctiv ities**  EPA will perform the following activities in response to the submittals related to renovation and lead
- based paint activity submissions:

• Receive, revie w, 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 fil e 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 renova tions for compensation. **4(b). Estimated A**  **gency 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 numb ers 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 th e 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 foll owed 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 ind ividuals, 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 tw o digits and burdens less than 0.01 w ere rounded up to 0.01.Page 11 of 28

commencing renova tions 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 Schedul**  **e** 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 cha nges, 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 in tervals 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 y ears, 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 co urses 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 c hange 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 perso nnel 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 Tec**  **hnology to Facilitate Collection A**  **ctiv ities**  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, commercialPage 12 of 28

delivery service, or hand deli very), 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 noti ce 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 A ND**  **INFORM AT**  **ION COLLECTION (IC) A CTIVITIES**  For each respondent category , this section of the ICR describes t he 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 W allpapering 238210 Electrical Contractors 238140 Masonry and Stone Contractors 238310 Drywall, Plastering, Acoustical, and Insulation Contractors 238340 Tile (except resilient) C ontractors 238350 Carpentry Contractors 238330 Floor Laying and Other Floor Contractors 238160 Roofing, Siding, and Sheet Metal Contractors 23811 0 Concrete Contractors 213111 Wa ter We ll Drilling Contractors 238120 Structural Steel Erection Contractors 238210 Electrical Contractors and Other W iring Installation Contractors 238910 Excavation Contractors 238910 Wr ecking and Demolition Contractors 2382 90 Other Building Equipment Contractors 238390 Building fixture and fitting (except mechanical equipment) installation 236118 Residential Remodelers 238150 Glass and Glazing ContractorsPage 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 5 31110 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 Schoo ls and Instruction 624410 Child Day Care Services 923120 Administration of Public Health Programs 924110 Administration of Air and Wa ter Resource and Solid Wa ste 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 fo r Train ing 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 providersPage 14 of 28

wish to use course mater ials 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 tr aining 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 Renov ation Training Notification” (see Attachment 6) or a similar form containing the required information. Training providers may provide electronic submissions using the Agency’s secure, Internet
based Central Data Exchange (CDX). (The paperwork activities, r elated 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 chang es 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 sim ilar 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 pla n, results of hands
- on assessment s 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 log
ins, 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/ hy**  **perlinks) 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 r equiring the same information. Firms may later amend their applications to add or modify information. Lead
- based paint activities firms must b e 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 Record s of i ndividuals 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/ hy**  **perlinks) 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 a**  **ccreditation / 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 certific ate, 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 lead
based paint activities and renovations they undertake to demonstrate compliance with standar ds 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 i nspections. **IC# 3. Individuals performing LBP abatement activities; certification and accreditation/reporting and recordkeeping**  **Citation: 40 CFR 745 , subpart L**  **Data Element (w/ hy perlinks)**  **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 a n 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 protec tion 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 submi t 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 maintai n 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 t he 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 **Citation: 40 CFR 745, subpart L Data Element (w/ hy**  **perlinks) 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 Lead
Based Paint Abatement Activities 13,676 6,359 347,699

LBP firms / reports / recordkeeping Notification of Lead
Based Paint Abatement Activities, Sample Renovation Recordkeeping Checklist 259,844 2,598 2,598
LBP activity firms / pre

- abatement re - notifications / reporting Notification of Lead
Based Paint Abatement Activities 524 112 6,248 LBP Firms / re

- notifications / recordkeeping Notification of Lead
Based 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 r e - 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 W allpapering 238210 Electrical Contractors 238140 Masonry and Stone Contractors 238310 Drywall, Plastering, Acoustical, and Insulation Contractors 238340 Tile (except resilient) C ontractors 2383 50 Carpentry Contractors 238330 Floor Laying and Other Floor Contractors 238160 Roofing, Siding, and Sheet Metal Contractors 238110 Concrete Contractors 213111 Wa ter We ll Drilling Contractors 238120 Structural Steel Erection Contractors 238210 Electrical C ontractors and Other W iring Installation Contractors **C# 5. RRP training provider accreditation applications, training notifications, and recordkeeping Citation: 40 CFR 745**  **, subpart E**  **Data Element (w/ hy perlinks)**  **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 re

notification / 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 Wr ecking and Demolition Contractors 238290 Other Building Equipment Contractors 238390 Building Fixture a nd Fitting (except mechanical equipment) I nstallation 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 Contrac tors 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 , an d 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 re
certify every five years and maintain a record of their certification

. To obtain firm certification to perform lead
- based paint activities or renovations i n 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 s imilar 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/ hy**  **perlinks) 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 post**   ** renovation and post** **- renovation checklists document**  **ing lead -**  **safe work practices** Respondents NAICS Codes 236115 Sing le 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 W allpapering 238210 Electrical Contractors 238140 Masonry and Stone Contractors 238310 Drywall, Plastering, Acoustical, and Insulation Contractors 238340 Tile (except resilient) C ontractors 238350 Carpentry Contractors 238330 Floor Laying and Other Floor Contractors 238160 Roofing, Siding, and Sheet Metal Contractors 238110 Concrete Contractors 213111 Wa ter We ll Drilling Contractors 238120 Structural Steel Erection Contractors 238210 Electrical Contractors and Other W iring Installation Contract ors 238910 Excavation Contractors 238910 Wr ecking and Demolition Contractors 238290 Other Building Equipment Contractors 238390 Building Fixture and F itting (except mechanical equipment) I nstallation 236118 Residential Remodelers 238150 Glass and Glazing C ontractors 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 ContractorsPage 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 N o more than 60 days before beginning renovation activities in any residential dwelling unit of tar get 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. I f 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 d ocumentation providing proof that the pamph let 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 multi
unit 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 prep are, sign, and date a statement describing the steps performed to notify all occupants of the intended renovation activities and to pro vide the pamphlet

. F irms performing renovations must retain and, if requested, make available to EPA all records necess ary 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 o f 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/ hy**  **perlinks) 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 C hild

- Occupied Facilities None 114,569 30,361 1,519,729

Pre
- Renovation Information Dissemination by Contractors Working in Rental Child

Occupied 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 l andlord / third party disclosure Sample Renovation Recordkeeping Checklist 29,441 1,472 69,407 RRP firm checklist / owner

- occupied child

occupied facility (COF), contractor / third party disclosure Sample Renovation Recordkeeping Checklist 208,542 10,427 491,638 RRP firm checklist / renter

- occupied child

occupied 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 E lementary and Secondary Schools 611699 All Othe r Miscellaneous Schools and Instruction 923120 Administration of Public Health Programs 924110 Administration of Air and Wa ter Resource and Solid Wa ste Management

Programs 925110 Administration of Housing Programs I nformation 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 i nformation 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 documen tation 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 fa iled 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 entitie s performing renova tions 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 hous ing 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 mus t re
- certify every five years. The rule also requires g overnment 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/ hy**  **perlinks) 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, 585,2 13 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 we re 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 b uilding 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 as sumptions 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 $2 77 , 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, b urden 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 fo r non burden 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. **AT TA**  **CHMENTS TO THE SUPPORTING STA TEMENT**  Attachments to the supporting statement are available in the public docket established for this ICR under docket identification number **EPA -**  **HQ -**  **OPP T**  **- 201**  **4 -**  **0486**
**.** These attachments are available for online viewing at www.regulations.gov or otherwise accessed as described in th e 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**  **:** E PA 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 Act ivities 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
- Tr aining 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