ICR Attachment 4: Record of Consultations with Potential ICR Respondents

1669-06-icr_attach4.doc

Lead-Based Paint Pre-Renovation Information Dissemination - TSCA Sec. 406(b)

ICR Attachment 4: Record of Consultations with Potential ICR Respondents

OMB: 2070-0158

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EPA ICR No.: 1669.06; OMB Control No.: 2070-0158

















Attachment 4


Record of Consultations with Potential ICR Respondents




























Date: February 14, 2011


From: Ryan Schmit

USEPA HQ/OPPT/NPCD


To: [Addressees]

Subject: Request for assistance; renewal of "TSCA Section 406(b) Lead-Based Paint Pre-Renovation Information Dissemination" ICR



The U.S. Environmental Protection Agency (EPA) seeks your comments on the regulation set forth in 40 CFR 745, Subpart E.

Section 406(b) of Title IV of the Toxic Substances Control Act (TSCA) requires renovators to provide the owner and occupant of any residential dwelling unit or multi-family housing with a lead hazard information pamphlet. After providing the pamphlet to the owner and occupant and obtaining written acknowledgment, the renovator must keep acknowledgment records on file for three years after completion of work.

Because the regulation involves the potential collection of information from a large number of individuals, EPA is required to submit an Information Collection Request (ICR) to the Office of Management and Budget (OMB) for approval, and to renew the ICR every three years. EPA is currently in the process of renewing the ICR for the above-described regulation. A draft copy of the ICR renewal is attached hereto, and will also be published in the Federal Register sometime in the near future.

The requirements under this regulation directly impact the members of your organization. As such, EPA requests that you complete the attached questionnaire as thoroughly as possible to represent your organization's viewpoint on what can be done to change or improve the process. The information you provide will have an impact on government efficiency.


If you have any comments in response to the attached questions, or with respect to any other part of the information collection, please respond by return e-mail by April 15, 2011. EPA will consider those responses, as well as any public comment received in response to the Federal Register Notice identified above, in preparing a final document for OMB review. Your timely response will be greatly appreciated.

Sincerely,


Ryan Schmit

U.S. Environmental Protection Agency

Office of Chemical Safety and Pollution Prevention

Office of Pollution Prevention and Toxics

Lead, Heavy Metals, and Inorganics Branch

202-564-0610









  1. Is the 60-day time period appropriate? Could EPA change the time period and still produce the same outcome?


  1. 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?


  1. Are you interested in or currently using an electronic recordkeeping option? Would you be able to satisfy the record keeping requirements electronically?


  1. Do you understand that you are required to maintain copies of the acknowledgment form or certification in your records for 3 years? If not, do you have suggestions to clarify instructions?


  1. Do you agree with EPA’s burden estimate and cost (ICR only addresses costs associated with paperwork)?


  1. Are there any other costs that should be accounted for? Please provide an explanation.


  1. Do you have any other comments on this Information Collection Request?


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