2494.01 Attachment 2

ATTACHMENT 2
Public Consultations

Consultation Request for December 2013 Federal Register Notice

Date:

December 12, 2013

From:

US EPA

To:

[Addressees as selected]

Subject:

Consultation for Public and Commercial Building Survey ICR

EPA’s Office of Pollution Prevention and Toxics has initiated a proceeding to investigate whether and
what type of regulatory action might be appropriate to control exposures to lead resulting from
renovation, repair and painting activities in public and commercial buildings. On December 6, the U.S.
Environmental Protection Agency (EPA) published a Notice in the Federal Register (78 FR 73520) titled
“Agency Information Collection Activities; Proposed Collection; Comment Request.” The Notice refers
to EPA's intention to request Office of Management and Budget (OMB) clearance for an Information
Collection Request (ICR) related to reporting and recordkeeping requirements for a survey of construction
contractors, property managers and lessors, and building occupants about renovation, repair, and painting
activities in public and commercial buildings.
The Notice and the draft ICR are attached. You can also access the Federal Register Notice, the ICR
supporting document, and any public comments received to date by searching on docket ID number EPAHQ-OPPT-2013-0715 at www.regulations.gov, or using the link
http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPPT-2013-0715
In addition to public notice and comment requirement initiated by the Notice, OMB regulations at 5 CFR
1320.8(d)(1) require agencies to consult with members of the public about specific aspects of an ICR
before submitting it to OMB for review and approval.
As part of this required consultation, EPA is contacting you to solicit your input. Note that if you take
this opportunity to provide input, your name, affiliation, e-mail address, phone number and any
information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR supporting
statement, which will be a public document. In addition, the OMB Desk Examiner for the ICR in
question may contact you to verify the accuracy of any comments EPA identifies in the ICR. EPA solicits
your input on the following questions:


Are there other questions that EPA should ask in order to understand the baseline incidence of
different types of renovation, repair, and painting activities that disturb lead-based paint in public and
commercial buildings, the methods that are used to conduct these activities, the work practices that
are used to contain and clean the resulting dust, and the characteristics of the buildings?



Is it clear what information the questions are asking respondents for? Are there any suggestions for
rewording the questions or providing clarifying instructions?



How accurate are EPA’s assumptions in the ICR, such as the percentage of respondents that will

perform renovation, repair, and painting activities in public and commercial buildings; the average
number of jobs per year they perform; and the average number of employees engaged in these
activities?


Do you agree with EPA's estimates of the burden and cost of responding to the survey? Are the Bureau
of Labor Statistics (BLS) labor rates accurate? If you have any reason to consider the BLS labor rates
as used by EPA inaccurate or inappropriate, explain your rationale.

Your timely response will be greatly appreciated. If you have any comments in response to the above
questions, or with respect to any other part of the information collection, please respond by return e-mail to
[email protected] or via http://www.regulations.gov by February 4, 2014. EPA will consider your
comments, as well as any other public comment received in response to the Federal Register Notice
identified above, in preparing a final document for OMB review.
Sincerely,
William Silagi
Economic and Policy Analysis Branch
U.S. EPA Office of Pollution Prevention and Toxics