RRP PAPERWORK REQUIREMENTS UNDER REVIEW BY THE EPA

On January 26, 2011, in compliance with the Paperwork Reduction Act, the EPA posted a request for comments which it will pass 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. Read all the details in the Federal Register.

An Information Collection Request is the term used for the requirement that all Certified Firms and Certified Renovators (as well as any sampling or testing) fill out and maintain specific records of all RRP related activities, and to make these records available to the residents and occupants of the Target Housing on which RRP activities have been performed.

This ICR, entitled: ``TSCA Section 402 and Section 404 Training and Certification, Accreditation and Standards for Lead-Based Paint Activities and Renovation, Repair, and Painting'' combines information collection activities for lead-based paint activities, the addendum for the 2008 Renovation, Repair and Painting final rule, and the 2010 Renovation, Repair and recordkeeping final rule covering the reporting and recordkeeping requirements for individuals or firms conducting lead-based paint activities or renovation in or on houses, apartments, or child occupied facilities built before 1978.

The current ICR expires of October 31, 2011, and the EPA, in the January 26 edition of the Federal Register) has made the official announcement that they are 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, 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.

As each ICR expires, the EPA is required to submit information to the OBM combined with comment from those affected by the ICR in an attempt to reduce the paperwork load, yet maintain compliance with the activities required under the regulations.

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.