You are running out of runway if you want to take this opportunity to let the EPA know how the RRP paperwork requirements are working for you in the real world. The deadline to submit comments is this coming Monday, March 28.

This window of opportunity is in compliance with the Paperwork Reduction Act.  The comments submitted to the EPA will be passed on to the Office of Budget and Management as it seeks to renew with or without modification the Information Collection request (ICR) as originally set up in the RRP Final Rule.

In simple language, the ICR is the term the government uses to refer to the paperwork requirement that all Lead-Safe certified firms and certified renovators (as well as any sampling or testing) must complete and archive regarding all RRP related activities, and the requirement to make these records available to the residents and occupants of the Target Housing on which RRP activities have been performed.

The comments submitted may alter the current ICR (paperwork requirement) that expires on October 31, 2011.  When the EPA posted the request for comments in late January 26, it specified it was seeking comments in specific areas to enable it to:

1. Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency (EPA), including whether the information will have practical utility.

2. Evaluate the accuracy of the Agency's estimates of the burden of the proposed collection of information, including the validity of the methodology and assumptions used.

3. Enhance the quality, utility, and clarity of the information to be collected.

4. Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses.

In particular, EPA is requesting comments from very small businesses (those that employ less than 25) on examples of specific additional efforts that EPA could make to reduce the paperwork burden for very small businesses affected by this collection.

The EPA will consider the comments received and amend the ICR as appropriate. The final ICR package will then be submitted to OMB for review and approval. The EPA will issue another notice in the Federal Register to announce the submission of the ICR to OMB and the opportunity to submit additional comments to OMB.

While the contractors and businesses affected by the RRP have made record keeping among their biggest concerns, this request is not so much an opportunity to eliminate the need or complexities, but a chance to make comments or suggestions for changes that might indicate ways of streamlining the process and/or result in a reduction in needed time to comply.

The current OMB estimates of time for the covered record keeping to range between 0.8 and 9.9 hours per response, depending upon the category of the respondent. The OMB defines “burden” as the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.

Their definition of burden also includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements which have subsequently changed; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

Instruction on how to submit your comments can be found at:  http://www.federalregister.gov/articles/2011/01/26/2011-1474/agency-information-collection-activities-proposed-collection-comment-request-tsca-section-402-and

For technical information contact: Michelle Price, National Program Chemicals Division (7404T), Office of Pollution Prevention and Toxics, Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001; telephone number: (202) 566-0744; fax number: (202) 566-0470; e-mail address: price.michelle@epa.gov.
For general information contact: The TSCA-Hotline, ABVI-Goodwill, 422 South Clinton Ave., Rochester, NY 14620; telephone number: (202) 554-1404; e-mail address: TSCA-Hotline@epa.gov.