EPA ICR No. 1669.05; OMB Control No. 2070-0158
ATTACHMENT 5
Copy of Consultations Message Sent by EPA to Potential Respondents;
Summary of Comments Received during Consultation
EPA Information Request
Questionnaire Follows
Information Collection Request
Public Consultations
US Environmental Protection Agency (EPA) is seeking your assistance with collecting data and information which impacts you and the members of your organization. This information also has a direct impact on government efficiency. Please complete the attached questionnaire as thoroughly as possible to represent your organizations' viewpoint about a regulation that directly affects your members, or please provide the appropriate contact within your organization.
The regulation of interest is titled "Pre Renovation Lead Education Rule." The EPA published a notice in the Federal Register titled Agency Information Collection Activities; Proposed Collection; Comment Request; Lead-Based Paint Pre-Renovation Information Dissemination Toxic Substances Control Act Section 406(b); EPA ICR No. 1669.05, OMB Control No. 2070-0158 and can be accessed on the internet at http://www.epa.gov/fedrgstr/EPA-TOX/2007/June/Day-13/t11293.htm. The docket identification (ID) number is EPA-HQ-OPPT-2007-0271.
This regulation requires renovators, which sometimes include property managers and owners, to hand out the pamphlet "Protect Your Family From Lead in Your Home" to housing owners and occupants of pre-1978 housing. Also, the renovator must obtain, from the owner, a written acknowledgment that the owner has received the pamphlet and the renovator must keep all records necessary to demonstrate compliance with this subpart for a period of 3 years following completion of the renovation activities in target housing. Please provide answers to EPA by August 13, 2007. Thanks again for your assistance.
Sincerely,
Environmental Protection Specialist
Is the 60-day time period appropriate? Could EPA change the time period and still produce the same outcome?
Is it clear to you, based on the regulations, that you are required to distribute the pamphlet no more than 60 days prior to renovation activities, obtain written acknowledgement from the owner and occupant.
Are you interested in using an electronic notification/record keeping option.
If the option were available would you do it and satisfy the requirements by keeping electronic files.
Record Keeping
Do you understand that you are required to maintain copies of the acknowledgment form or certification in your records for 3 years?
If not, what suggestions do you have for clarifying the instructions?
General
Are the labor rates accurate?
Are there other costs that should be accounted for that may have been missed?
Be sure that you provide an explanation of how you arrived at your estimate of burden and cost if substantially different than EPA=s estimate.
Do you have any other comments on the ICR?
Response received from: Janssen Tanner
Picern Real Estate Group
August 2, 2007
Is the 60-day time period appropriate? Could EPA change the time period and still produce the same outcome?
Yes. Changing to a shorter period of time would not produce the same outcome.
Is it clear to you, based on the regulations, that you are required to distribute the pamphlet no more than 60 days prior to renovation activities, obtain written acknowledgement from the owner and occupant.
Yes.
Are you interested in using an electronic notification/record keeping option.
Yes
If the option were available would you do it and satisfy the requirements by keeping electronic files.
That could be a higher level corporate decision.
Record Keeping
Do you understand that you are required to maintain copies of the acknowledgment form or certification in your records for 3 years?
Yes
If not, what suggestions do you have for clarifying the instructions?
General
Are the labor rates accurate?
Unaware of specific rates.
Are there other costs that should be accounted for that may have been missed?
N/A
Be sure that you provide a explanation of how you arrived at your estimate of burden and cost if substantially different than EPA=s estimate.
Do you have any other comments on the ICR?
No
| File Type | application/msword |
| File Title | EPA ICR No |
| Author | OPPT |
| Last Modified By | OPPT |
| File Modified | 2008-02-07 |
| File Created | 2008-02-07 |