Office of Chemical Safety and Pollution Prevention

Fiscal Years 2023-2024

National Program Guidance
Final

August 2022
EPA- 741B22001


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Table of Contents

SECTION I. INTRODUCTION	3

SECTION II. PROGRAM PRIORITIES, STRATEGIES, AND ACTIVITIES	4

A.	Program Priority: Pesticide Cooperative Agreements with States and Tribes	4

B.	Program Priority: Pollinator Protection Efforts	6

C.	Program Priority: Revised Pesticides Worker Protection Standard Rule	8

D.	Program Priority: Revised Certification of Pesticide Applicators Rule	11

E.	Program Priority: Region-Specific Pesticide Priorities on Those Areas of Greatest Need
Nationally	15

F.	Program Priority: Toxics Release Inventory (TRI)	16

G.	Program Priority: Lead Risk Reduction	19

H.	Program Priority: Pollution Prevention (P2)	26

SECTION III. IMPLEMENTING TRIBAL WORK	31

SECTION IV. FLEXIBILITY AND GRANT PLANNING	32

SECTION V. FEDERAL CIVIL RIGHTS RESPONSIBILITIES, INCLUDING TITLE VI OF THE CIVIL
RIGHTS ACT OF 1964 	34

SECTION VI. FY 2023-2024 NATIONAL PROGRAM MEASURES	37

SECTION VII. CONTACTS	38

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SECTION I. INTRODUCTION

The National Program Guidances (NPG) set forth the strategies and actions the EPA and its state
and tribal partners will undertake to protect human health and the environment. This NPG for
FY 2023-2024 supports the Administration's priorities and provides the roadmap for achieving
its mission, which are reflected in EPA's FY2022-2026 Strategic Plan and the Agency's FY 2023
Congressional Justification.

Work in this NPG directly supports Goal 7, Ensure Safety of Chemicals for People and the
Environment, in the FY2022 - 2026 EPA Strategic Plan. The Office of Chemical Safety and
Pollution Prevention's (OCSPP's) NPG also integrates the Plan's goal to tackle climate change,
advance environmental justice and civil rights, and to consider the health of children and other
vulnerable populations in implementing our programs as detailed in the Plan's:

•	Goal 1: Tackle the Climate Crisis - Cut pollution that causes climate change and increase the
adaptive capacity of Tribes, states, territories, and communities.

•	Goal 2: Take Decisive Action to Advance Environmental Justice and Civil Rights - Achieve
tangible progress for historically overburdened and underserved communities and ensure
the fair treatment and meaningful involvement of all people regardless of race, color,
national origin, or income in developing and implementing environmental laws, regulations,
and policies.

•	Cross-Agency Strategy 2: Consider the Health of Children at All Life Stages and Other
Vulnerable Populations - Focus on protecting and improving the health of children at all life
stages and other vulnerable populations in implementing our programs.

EPA's FY2022-2026Strategic Plan can be found at:

https://www.epa.gov/planandbudeet/strategicplan.

In the development of this NPG, OCSPP engaged in early outreach with states and federally
recognized Indian tribes (tribes) and worked in collaboration and coordination with other
National Program Managers (e.g., Office of Enforcement and Compliance Assurance (OECA), the
Office of Water (OW)) and the regional offices to help identify the most important
environmental and human health protection areas of work to be conducted by the regional
offices in FY 2023-2024. During early stakeholder engagement, OCSPP provided copies of the FY
2020-2021 NPG and the draft FY2022-2026 Strategic Plan framework to states and tribes for
comment. State and tribal partners were asked to comment on the FY 2020-2021 NPG to
inform the development of the FY 2023-2024 Guidance. These comprehensive discussions took
place during a series of tribal and state conference calls, face-to-face meetings, and written
correspondence at the national and regional levels. OCSPP's FY 2023-2024 NPM Guidance takes
into consideration these external stakeholders and internal inputs on program-specific topics
and those requiring cross-program coordination. OCSPP and the regional offices will continue to

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communicate regularly with the states and tribes to better understand local, regional, and
national issues and priorities.

To complement the individual NPGs, the Office of Chief Financial Officer (OCFO) developed an
"Overview to the FY 2023-2024 NPM Guidances." The Overview to the NPG communicates
important Agency-wide information and should be reviewed in conjunction with each of the FY
2023-2024 NPGs, grant guidances and other applicable requirements. For additional
background, please refer to EPA's Overview of the FY 2023-2024 National Program Guidances
at: https://www.epa.eov/planandbudeet/national-proeram-euidances. Additionally, regional
offices can rely on established EPA-Tribal Environmental Plans (ETEPs) to assist in conducting
federal environmental program activities in Indian country, and with Alaskan Native Villages
including direct implementation and technical and financial assistance. The ETEPs factsheet can
be found at: https://www.epa.eov/tribal/epa-tribal-environmental-plans-eteps-fact-sheet.

The EPA will use the Budget Formulation System (BFS) to track regional performance
information and results. OCSPP's FY 2023 commitments are listed in Section 5 of this NPG. The
annual commitments in BFS will remain as draft until final performance agreements are
reached in November 2022. More information on the Agency's NPG development process,
public comment process, other NPG to the regional offices and the Agency's official
commenting template can be found on the EPA's Planning and Budgeting website at:
http://www2.epa.eov/planandbudeet/national-program-manaeer-euidances. Additional
information on the EPA performance measures, planning and budgeting can be found at:
http://www2.epa.eov/planandbudeet. OCSPP-specific information can be found at:
http://www2.epa.eov/aboutepa/about-office-chemical-safetv-and-pollution-prevention-ocspp.

SECTION II. PROGRAM PRIORITIES, STRATEGIES, AND ACTIVITIES

A. Program Priority: Pesticide Cooperative Agreements with States and
Tribes

Description

OCSPP's National Pesticide Program depends on cooperative agreements with states, tribes,
and territories to implement many of the requirements of the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) and to promote our regulatory decisions and programs for
achieving intended protections. This ensures OCSPP, OECA, and the EPA regional offices are
responsive to co-regulator and stakeholder needs while effectively managing cooperative
agreements.

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Strategy

Regional offices are responsible for negotiating, implementing, and managing state and tribal
cooperative agreements, and are uniquely positioned to provide technical assistance and
oversight given their proximity and working relationships with our co-regulators. Regional
project officers maintain ongoing communication with their grantees, providing oversight and
technical assistance, and facilitating knowledge transfer between the field, regional offices, and
EPA headquarter offices (HQ).

Activities

•	Negotiate state and tribal cooperative agreements and work plans consistent with the FIFRA
Cooperative Agreement Guidance. Ensure work with underserved populations has been
considered.

•	Issue grant funds to states and tribes in a timely manner once they become available.

Ensure resources are directed consistent with the current FIFRA Cooperative Agreement
Guidance to areas where they are most needed (https://www.epa.gov/compliance/fiscal-
year-2022-2025-fifra-cooperative-agreement-guidance).

•	Ensure workplans are created in the FIFRA Grant Database (FGD) and meet the
requirements of the current FIFRA Cooperative Agreement Guidance. All mid-year and end-
of-year reporting should also be consistent with the FIFRA guidance and entered in the FGD.

•	Foster prompt and accurate communication of EPA Pesticide Program regulations, policies,
and guidance to states and tribes.

•	Communicate with states and tribes regularly to ensure grantees conduct meaningful work
in priority areas and can meet their cooperative agreement responsibilities.

•	Provide effective technical assistance and policy support for states and tribes on national
pesticide priorities listed in the FIFRA Cooperative Agreement Guidance to help the
grantees be successful.

Measures

Although no measure was developed for this priority, EPA will review the workplan
accomplishments in the state and tribal end-of-year reports to evaluate the effectiveness of this
national priority focus area. Specifically, OCSPP will evaluate if all required program areas have
been addressed and assess the quality of these efforts.

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B. Program Priority: Pollinator Protection Efforts

Description

Through risk assessment, mitigation, education, and outreach, EPA's goal for pollinator
protection is to ensure all pollinators, including native and managed pollinators (e.g.,
honeybees; Apis mellifera) are protected from potential adverse effects from pesticide
exposure.

Strategy

Regional offices play a key role promoting pollinator protection activities through their frequent
communication with states and tribes. State lead agencies and tribes are encouraged to
develop pollinator protection plans that reflect local and regional stakeholder input/priorities.
Regional offices should assist states and tribes with their implementation efforts throughout FY
2023-2024 and work with co-regulators and stakeholders to develop measures to determine
the effectiveness of these plans in reducing pesticide risk to pollinators.

Activities

•	Assist with the development and implementation of Pollinator Protection Plans (P3s)
including Managed Pollinator Protection Plans (MP3), the appropriate revisions to such
plans, and outreach for state and tribal pollinator protection plans. Regional offices should
support states and tribes who are developing or revising the scope of their plans to include:
(1) reducing chronic exposure of pollinators to low levels of pesticides; (2) encouraging
agricultural practices that reduce the overall environmental loading of pesticides; (3)
reducing possible pesticide contamination of wild blooming host plants near treated
cropland; (4) increasing pollinator habitat; and (5) expanding outreach/education regarding
all of the factors influencing declines in pollinator health.

•	Use Association of American Pesticide Control Officials (AAPCO) surveys as a line of
evidence for determining the effectiveness of Pollinator Protection Plans. In 2019, based on
recommendations from the Pesticide Program Dialogue Committee (PPDC), AAPCO and
State FIFRA Issues Research and Evaluation Group (SFIREG) developed a survey for state and
tribal lead agencies regarding various aspects of P3s. AAPCO intends to conduct this survey
biennially. EPA will use the results of each survey as a line of evidence in determining the
effectiveness of MP3s in reducing pesticide exposure to pollinators over time. EPA regional
offices should encourage states and tribes to complete and submit the biennial surveys so
that AAPCO/SFIREG can provide a summary to EPA. Tribes have the option to complete the
biennial surveys as well and/or develop alternate means of assessing the effectiveness of
their Pollinator Protection Plans.

•	Conduct outreach and education on pollinator protection approaches and efforts as well as
the Monarch Butterfly Protection Strategy. Regional offices should disseminate existing

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outreach materials and assist in the development of new information, when possible (e.g.,
update study manuals for certification exams) to promote pollinator protection Best
Management Practices (BMPs), and Integrated Pest Management (IPM) in crops attractive
to bees. For a listing of bee-attractive crops, see the USDA publication at:
https://www.usda.gov/sites/default/files/documents/Attractiveness-of-Agriculture-Crops-
to-Pollinating-Bees-Report-FINAL-Web-Version-Jan-3-2018.pdf

Existing EPA-developed pollinator protection materials can be found on EPA's website at:

https://www.epa.eov/pollinator-protection/epa-actions-protect-pollinators.

New EPA-developed webinars on pollinator health and habitat include discussions on: Creating
Monarch Butterfly Habitats in Schools and Communities; Designing and Conducting Bee
Studies; Assessing Risks to Bees from Pesticides; Agricultural Stewardship and Best
Management Practices to Reduce Pollinator Risk; and Engaging Stakeholders: Development and
Implementation of Pollinator Protection Plans, and can be found on EPA's website at:

https://www.epa.eov/pollinator-protection/epa-offers-webinars-pollinator-health-and-habitat

In addition, an extensive amount of outreach and educational materials are available through
the USDA Cooperative Extension Service: (https://www.usda.gov/topics/rural/cooperative-
research-and-extension-services) and Natural Resources Conservation Service websites

(https://www.nrcs.usda.eov/wps/portal/nrcs/main/national/plantsanimals/pollinate/). and on
stakeholder websites, such as the Pollinator Partnership (https://pollinator.ore/). the Honey
Bee Health Coalition (https://honeybeehealthcoalition.ore/). Monarch Watch
(https://www.monarchwatch.ore/). and Xerces Society (https://xerces.ore/).

•	Support project ideas that promote Pollinator Protection to the Pesticide Educational
Resources Collaborative (PERC), a cooperative agreement between the Office of Pesticide
Programs and University of California Davis Extension, in collaboration with Oregon State
University. Projects could include the development or revision of manuals, exam banks or
other materials. Proposed project ideas can be submitted on PERC's website:
http://pesticideresources.ore/.

•	Identify opportunities to partner with other agencies and organizations interested in
promoting pollinator protection. The National Strategy to Promote the Health of Honey
Bees and Other Pollinators includes ideas for partnerships. Regional offices should consider:

o Partnering with USDA regional IPM Centers to leverage opportunities for outreach on
pollinator protection BMPs. (https://nifa.usda.eov/reeional-inteerated-pest-
manaeement-ipm-centers).

o Linking to the Pollinator Partnership Action Plan.

(https://obamawhitehouse.archives.gov/sites/whitehouse.gov/files/images/Blog/PPAP
2016.pdf).

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o Reviewing the Pollinator Research Action Plan of the National Strategy, which has
sections on "Research to Application" and Partnerships.

(https://obamawhitehouse.archives.gov/sites/default/files/microsites/ostp/Pollinator%
20Research%20Action%20Plan%202015.pdf).

o Reference EPA's memorandum of understanding with the Pollinator Partnership.
(https://www.epa.gov/pollinator-protection/memorandum-understanding-between-
epa-and-pollinator-partnership).

Measures

Although no measure was developed for this priority, EPA will review the data provided by the
AAPCO/SFIREG biennial surveys referenced above along with other lines of evidence to gauge
the effectiveness of the state's MP3s. While the first year's data serves as a baseline, they
provide a means for EPA and states/tribes to track specific indicators of success in the coming
years and to identify potential opportunities for enhancing the direction and effectiveness of
P3s. State lead agency and Tribal Nation interests identified through the initial survey have
been incorporated in the 2022-2025 FIFRA Cooperative Agreement Guidance.

EPA's strategy to evaluate the effectiveness of MPs toward this national priority utilizes a broad
range of survey data, not just the AAPCO surveys, as lines of evidence with which to assess the
national impact of efforts to mitigate potential exposure of pollinators to pesticides. Other lines
of evidence include data from the Bee Informed Partnership Loss and Management Survey
(https://beeinformed.org/citizen-science/loss-and-management-survey/); the USDA National
Agricultural Statistics Service (NASS) surveys

(https://usda.library.cornell.edu/concern/publications/rn301137d?locale=en): and the USDA
Animal and Plant Health Inspection Survey (APHIS) Honey Bee Pest and Disease survey
(https://research.beeinformed.org/state reports/), along with bee kill incident data reported
to EPA.

C. Program Priority: Revised Pesticides Worker Protection Standard Rule

Description

On November 2, 2015, EPA published final revisions to the Worker Protection Standard (WPS)
rule (40 CFR Part 170: https://www.ecfr.gov/current/title-40/chapter-l/subchapter-E/part-170).
The WPS revisions address important occupational protections for pesticide workers and
handlers such as pesticide safety training, notification, communication materials, use of
personal protective equipment (PPE), and decontamination supplies. In line with the Agency's
FY 2022-2026 Strategic Plan's Goal 2, Take Decisive Action to Advance Environmental Justice
and Civil Rights and Cross-Agency Strategy 2, Consider the Health of Children at All Life Stages
and Other Vulnerable Populations, these revisions are intended to reduce the number and
severity of pesticide exposure incidents and prevent unreasonable adverse effects among
agricultural workers, pesticide handlers and vulnerable groups, including communities of color

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and low-income populations, farmworker children, farmworker families and the general
population. It is estimated that more than two million farmworkers nationwide receive
protections under the WPS regulation.

Strategy

Most provisions of the 2015 WPS rule became effective January 2, 2017; however, a few
provisions were delayed and did not become effective until January 2, 2018. The provisions
requiring employers to provide the WPS training that meets the new training content
requirements of the rule were further delayed until EPA produced and released new training
materials that met the new content requirements. EPA published the required Notice of
Availability of the WPS training materials on June 22, 2018. Therefore, all the requirements of
the revised 2015 WPS rule have been in effect since December 19, 2018, and regional offices
should focus their activities for FY 2023-2024 on ensuring effective implementation of the
revised 2015 WPS requirements.

In addition to these changes, EPA published targeted revisions to the application exclusion zone
(AEZ) requirements of the 2015 WPS (85 FR 68760;

https://www.federalreeister.eov/documents/2020/10/30/2020-23411/pesticides-aericultural-
worker-protection-standard-revision-of-the-application-exclusion-zone). At this time, there is
no implementation of the 2020 Rule as a preliminary injunction has stayed the effective date of
the 2020 Rule and enjoined EPA from implementing the 2020 revisions. EPA is reconsidering
the 2020 final rule in accordance with the Executive Order 13990, Protecting Public Health and
the Environment and Restoring Science to Tackle the Climate Crisis (86 FR 7037;
https://www.federalreeister.eov/documents/2021/01/25/2021~01765/protectine~Public~
health-and-the-environment-and-restoring-science-to-tackle-the-clfmate-crisis). EPA will solicit
public comment on revisions to the AEZ requirements through a notice of proposed rulemaking
in early FY 2023 and anticipates issuing a final rule amending the AEZ requirements in early FY
2024. Therefore, the AEZ requirements as written in the 2015 WPS remains the operative
regulatory language during the current and any future extensions of the stay and until any new
rulemaking goes into effect.

Activities

The principal activities for all regional offices in the WPS program area for FY 2023-2024
support the states and tribes in their implementation of the WPS. Regional offices should also
support any additional WPS implementation activities that may be identified in subsequent
Agency guidance documents or directives due to potential rule modifications or policy decisions
that may occur after this guidance is issued.

Specific regional activities include:

• Provide training, outreach, and technical assistance to states and tribes, other co-

regulators, and State Land Grant Universities/Extension educators on the key requirements

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and impacts of the revised WPS rule, including Agency action on the WPS-AEZ. This includes
organizing training for states, tribes and other co-regulators as needed (in-person or via
webinar) and coordinating the communication and resolution of issues and concerns
between states, tribes and OCSPP or OECA, when necessary.

•	Support state and tribal WPS rule and program implementation efforts and provide
effective oversight of state and tribal WPS programs so that Agency resources are directed
to areas where they are most needed and best support the WPS program goals. Allocate
resources as available to support travel for regional staff to attend and participate in
national WPS Pesticide Regulatory Education Program (PREP) and Pesticide Inspector
Regulatory Training (PIRT) courses, as well as other national WPS training courses or
programs that may be held to train regional staff and inspectors and build regional
infrastructure and/or capacity for supporting WPS program implementation.

•	Support national efforts designed to address field implementation issues that may arise
(e.g., developing WPS fact sheets, "Q&A's," addressing equivalency requests, developing
region-specific training and/or compliance assistance materials, etc.).

•	Seek opportunities to address two or more priorities in one activity, such as the WPS and
the Certification of Pesticide Applicators (CPA) rule, pollinator protection, climate change,
and/or environmental justice. Examples of environmental justice considerations for WPS
include development and delivery of outreach, educational materials with consideration of
the language and cultural context of the target audience. This includes farmworkers and
their families, pesticide applicators, and the small business farmer.

•	Assist with the development and distribution of EPA-approved WPS training materials and
review new or updated training materials submitted to EPA for approval, as applicable and
appropriate.

•	Work with states and tribes in the region to ensure mechanisms and procedures are in place
to enable coordination and follow-up on reports of occupational pesticide exposure,
incidents or illnesses that may be related to pesticide use or misuse, or WPS violations, and
facilitate any efforts to establish or enhance such efforts.

Regional offices with more WPS-affected establishments, large farmworker populations or

specific/special WPS implementation issues should also consider undertaking supplemental

special initiatives or activities in the following areas:

•	Facilitate development and adoption of EPA-approved WPS train-the-trainer (ill) programs
and materials. OCSPP encourages regional offices to support the establishment of state and
tribal WPS TTT programs that will improve the quality of WPS trainers and WPS training
programs.

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•	Support programs and provide resources to facilitate employer compliance with the new
WPS requirements related to respirator use (i.e., medical evaluation, fit-testing and
respirator training). This may include developing partnerships with medical providers,
regulatory partners, grower and commodity groups, and/or nongovernmental organizations
to support understanding and adoption of the requirements as well as providing resources
and mechanisms for fulfilling the requirements.

•	Work with regional community-based WPS training providers. When possible, regional
offices should work with community-based training providers, such as Association of
Farmworker Opportunity Programs, Telamon, and other farmworker assistance groups, to
support WPS training efforts and ensure training providers are meeting WPS requirements.
Regional offices should facilitate linkages between training providers and state and tribal
contacts and members of the agricultural community, so their services can be utilized more
effectively.

•	Develop cooperative relationships with farmworker service organizations. Regional offices
should identify and work with groups in the region that provide services to farmworkers to
establish cooperative relationships, better communication, and linkages.

Measures

Although no measure was developed for this priority, EPA will review regional information on
WPS efforts, and any other qualitative data available, to evaluate the effectiveness of regional
progress towards this national priority focus.

D. Program Priority: Revised Certification of Pesticide Applicators Rule

Description

The Certification and Training (C&T) Program is critical to ensuring that persons using or
supervising the use of Restricted Use Pesticides (RUPs) are competent to use these products
without causing unreasonable adverse effects to human health or the environment and to
provide a mechanism by which states, tribes, and federal agencies can administer their own
programs for certifying applicators of RUPs as competent. The C&T Program also plays a vital
role in ensuring that important pesticide tools remain available to pest control officials and
users to address critical pest management needs.

On January 4, 2017, EPA published final rule revisions to the Certification of Pesticide
Applicators rule (40 CFR Part 171;

https://www.federalreeister.eov/documents/2017/01/04/2016-30332/pesticides-certification-
of-pesticide-applicators). The revisions address private applicator competency, standards for
recertification programs, standards for supervision of noncertified applicators, competency
requirements for noncertified applicators applying RUPs under the supervision of a certified
applicator, minimum age for certified and noncertified applicators, application-method specific

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categories, requirements for state, tribal, and federal Agency certification plans, and
implementation requirements. These revisions are intended to reduce the number and severity
of pesticide exposure incidents associated with the use of RUPs, and prevent unreasonable
adverse effects among certified applicators, noncertified persons applying under the
supervision of a certified applicator, vulnerable groups, including communities of color and low-
income populations, and the general population.

The revised Certification of Pesticide Applicators (CPA) final rule became effective March 6,
2017. All implementation dates established for the final rule are in effect. States and other
certifying authorities have until March 4, 2020, to submit modified certification plans. The
revised plans must demonstrate compliance with the new standards in the rule or provide a
detailed schedule in the plan for how and when the state or certifying authority will complete
the required legislative and/or regulatory actions and other program changes needed to
implement the revised rule's requirements. Existing plans remain in effect until EPA approves or
rejects the revised plan. Initially, EPA had until March 4, 2022, to make its approval decisions
for the revised plans.

Due to the impact of the COVID-19 public health emergency and the need for careful review of
program-specific issues and questions, EPA issued a short-term extension to the original
expiration deadline of March 4, 2022 https://www.epa.gov/pesticides/epa~issues-notice~
proposed-rulemakine-further~extend~certification~pesticide~applicators), and requested
comment on a proposal to further extend the deadline for expiration. EPA then issued a final
rule extending the deadline to November 4, 2023, for certifying authorities with existing
certification plans to comply with the updated federal standards under the 2017 CPA rule. After
that date, only authorities with EPA-approved modified certification plans can continue to
certify applicators of RUPs. The timeframe for implementation of the revised certification plans
will be decided on a case-by-case basis as part of EPA's review and approval process.

Strategy

Related to the Agency's Strategic Plan's Goal 2, the principal activities for all regional offices in the
Certification of Pesticide Applicators (CPA Rule) Program area for FY 2023-2024 will be to
support the states and tribes addressing EPA's feedback to certifying authority plans and in the
states' and tribes' revision and implementation of their revised plans for ensuring that states
and tribes have amended their certification plans for EPA to approve by the November 4, 2022,
regulatory date. This includes coordinating with their states and tribes and addressing rule and
plan questions and raising issues or concerns to the National CPA Rule Plan Review Workgroup.
Regional offices must also ensure state and tribal pesticide applicator certification programs are
being implemented and maintained in accordance with their EPA-approved certification plans,
and that annual C&T program reporting requirements are met. Regional offices should also
support any CPA Rule implementation activities identified in the revised plans, subsequent
Agency guidance documents or directives due to potential rule modifications or policy decisions
that may occur after this guidance is issued.

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Additionally, regional offices should support the Agency's implementation of the January 4,

2017, revisions to Part 171 Certification of Pesticide Applicators rule and carry out regional C&T

program implementation activities in accordance with this and any other applicable EPA

guidance.

Activities

•	Support the states and tribes in addressing EPA feedback to certifying authority plans and in
implementation of the revised Certification of Pesticide Applicators rule. This includes
addressing rule and plan questions and raising potential sticking points to the National CPA
Rule Plan Review Workgroup.

•	Ensure state and tribal pesticide applicator certification programs are being implemented
and maintained in accordance with their EPA-approved certification plans. Regional offices
should ensure states and tribes continue implementing pesticide applicator certification
programs in accordance with current EPA-approved certification plans and Part 171
requirements until such time that revised plans have been submitted to EPA and the new,
EPA-approved revised certification plans complying with the new revised Part 171 rule
requirements are fully implemented.

•	Offer technical support and outreach to tribes with an interest in developing a tribe-specific
certification plan (i.e., tribes that are interested in moving beyond coverage under the EPA
Plan for Indian Country).

•	Seek opportunities to address two or more priorities in one activity, such as the CPA rule
and the WPS, pollinator protection, climate change, and/or environmental justice. Examples
of environmental justice considerations for CPA implementation may include development
and delivery of outreach and educational materials with consideration of the language and
cultural context of the target audience. This may include communicating pesticide safety
practices to protect vulnerable communities in spaces such as cultural centers, schools,
churches, and playgrounds.

•	Provide effective input to of state and tribal CPA rule programs so that Agency resources
are directed to areas where they are most needed and best support the CPA rule program
goals.

•	Allocate resources as available to support travel for regional staff to attend and participate
in national CPA PREP and PIRT courses, as well as other national CPA rule training courses or
programs that may be held to train regional staff and inspectors and build regional
infrastructure and capacity for supporting certification program implementation.

•	Support and participate in the "National HQ-Regional C&T Plan Review Workgroup" as
appropriate. The workgroup will be designed to ensure nationally consistent certification
plan reviews and address any C&T field implementation issues that may arise.

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•	As needed, assist states and tribes with CPA rule-related outreach, education, and technical
assistance on the revised rule to the regulated and affected communities, and key
stakeholder groups (e.g., groups representing certified applicators, non-certified
applicators, and pesticide handlers) in the region.

•	Ensure states and tribes meet Part 171 requirements for certification plan maintenance and
annual reporting using the Certification Plan and Reporting Database (CPARD). Regional
offices must ensure that existing state and tribal certification plans are maintained and kept
current within the CPARD in accordance with the requirements in 40 CFR Part 171 and
associated EPA guidances. Regional offices must ensure existing certification plans are
updated in CPARD annually, making any necessary updates, and all pertinent information to
reflect any changes to their certification programs and plans made during the year.

•	Ensure states and tribes use the CPARD database system for submitting their required
annual certification program accomplishment reporting information. The annual
certification program accomplishment reporting information required by Part 171 must be
entered into CPARD annually by December 31st of each calendar year regardless of the
actual grant project period. By properly and completely filling out the reporting section of
the CPARD system, states and tribes will provide the annual C&T accomplishment reporting
information to EPA that contains all the information required by Part 171. Regional offices
should work with their states and tribes if any technical assistance is needed for using
CPARD.

Regional offices with large numbers of certified applicators, noncertified applicators applying
RUPs under the supervision of a certified applicator, or with unique pesticide applicator
certification issues should consider undertaking supplemental special initiatives or activities in
the following areas described below.

•	Suggest project ideas that would support the implementation of the revised Certification
rule to the Pesticide Educational Resources Collaborative (PERC), the second project period
(2021-2026) of a cooperative agreement between the Office of Pesticide Programs and
University of California Davis Extension, in collaboration with Oregon State University.
Projects could include the development or revision of manuals, exam banks or other
materials. Proposed project ideas can be submitted on PERC's website:
http://pesticideresources.org/.

•	Encourage State Lead Agencies (SLAs) to work with their university partners for ensuring
that exam revisions are made using established exam development and validation
principles. Where resources permit, regional offices should encourage states and tribes to
use exam development and validation principles for revising their applicator exams and for
improving competency of applicators.

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Measures

EPA will review regional information on CPA Rule efforts, and any other qualitative data
available, to evaluate the effectiveness of regional progress towards this national priority focus.
OCSPP developed a tracking dashboard to track and evaluate the regional and headquarters'
progress towards reviewing and approving revised state and tribal applicator certification plans.
The tracking dashboard (available as an EPA internal tool) includes details through the plan
approval and Federal Register publication and is based off plan review details entered by the
regional offices in CPARD.

E. Program Priority: Region-Specific Pesticide Priorities on Those Areas of
Greatest Need Nationally

Description

In direct support of the Agency's Strategic Plan's Goal 2, Take Decisive Action to Advance
Environmental Justice and Civil Rights, region-specific projects will focus on addressing
environmental justice communities and vulnerable populations. The Region-Specific Pesticide
Projects address national priorities at the regional level often tailored to a geographical area
and audience.

Strategy

Regional offices are to select and implement one project annually with an environmental justice
component such as developing and delivering outreach and educational materials to
underserved communities. Environmental justice-related projects can target a specific
community or sector and can be multi-year. Regional offices are encouraged to work together
on projects to leverage resources.

Activities

The following should be considered to ensure robust and substantive regional projects:

•	Consider a project related to one of the priorities already listed in this document including
pollinator protection, worker protection, or applicator certification, as long as it can be
demonstrated that the project has an environmental justice component as described above
and is in addition to regular regional work.

•	All project proposals must be submitted for review and approved by the
OCSPP/OPS/lntergovernmental and Community Relations Branch Supervisor before the
project is initiated.

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•	Proposals for projects should be submitted on the template provided, and include: a clear
statement of work, project accomplishments/outputs, and how the project supports the
program area goals.

•	Projects may entail outreach, education, training, stakeholder coordination, state or tribal
program capacity building and support, or other similar projects or initiatives that support
program improvements.

•	Projects (or one phase of a multi-year project) must be completed by the end of the fiscal
year. Regional offices must submit project reports to the OCSPP/OPS/lntergovernmental
and Community Relations Branch within 60 days of the end of the federal fiscal year. Multi-
year projects are also required to provide an annual report.

•	The results of each project will be reviewed by the OCSPP/OPS/lntergovernmental and
Community Relations Branch and regional offices at the end of the fiscal year and circulated
so that innovations and lessons learned may be shared across the regional offices and OPP.

Measures

Although no measure was developed for this priority, EPA headquarters will meet with each
regional office to discuss their region-specific pesticide projects to ensure progress is being
made on environmental justice efforts as described above and will review their final reports
annually. EPA will also review any other qualitative data available to evaluate the effectiveness
of regional progress towards this national priority focus.

F. Program Priority: Toxics Release Inventory (TRI)

Description

EPA will focus on the collection of the chemical release and other associated data and making
the data available to governments and the public. EPA's success in carrying out its mission to
protect human health and the environment is contingent on collecting timely, accurate, and
relevant information. The TRI program supports the EPA's mission by annually publishing, for
the public, chemical release data, other waste management data (e.g., recycling), and pollution
prevention information on over 770 toxic chemicals from more than 21,000 industrial and
federal facilities. The TRI program is a premiere, multimedia source of toxic chemical release
and other waste management data for communities, non-governmental organizations,
industrial facilities, academia, and government agencies.

EPA's Office of Mission Support (OMS) will continue to provide reporting facilities with an
online reporting application, TRI-MEweb, to facilitate the electronic preparation and submission
of TRI reports through the EPA's Central Data Exchange (CDX). In addition, the TRI data
collected by the EPA are shared with states, tribes, and territories that have an active node on
CDX and are partners of the TRI Data Exchange (TDX). OCSPP will continue to maintain the TDX

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used by states, tribes, and territories. OMS will also continue the TRIPS database, which is the
repository for TRI data. Maintaining the TRI data includes data quality activities and
transmitting the data to the Envirofacts database in support of the public's access to TRI data.

Strategy

Each year, the TRI Program implements two types of TRI data quality activities for the regional
offices to pursue. One of the activities is the National Analysis data quality check, and the other
is the ad hoc data quality check. A list consisting of no less than 300 targets is developed by the
TRI Program for each activity.

The TRI National Analysis data quality activity involves an examination of the TRI data
submitted by July 1 by more than 21,000 TRI facilities across the U.S. and its territories and
applies a series of analyses that identify facilities whose reporting has changed significantly
from the previous reporting year and facilities whose data for all releases and for specific
chemicals (e.g., PBTs) are outliers. No less than 300 total data targets are identified and
pursued collectively by all 10 regional offices from August through September.

The ad hoc data quality activity identifies inherent/systemic TRI reporting issues such as:
receiving facilities that did not report for chemicals in excess of reporting threshold quantities,
invalid RCRA IDs, and invalid Dunn and Bradstreet numbers; facilities whose data seem to have
data quality issues based on comparative analyses to other TRI reporters, other data reported
to EPA such as those data required to be reported under the TSCA, the CAA or the CWA; and
results of other data analyses. No less than 300 ad hoc data quality targets are identified and
pursued collectively by all 10 regional offices following publication of the TRI National Analysis,
i.e., over the February-April timeframe.

Activities

Once the TRI National Analysis and ad hoc data quality target lists are developed they are sent
to the regional offices so that the regional offices can send out an email to each facility to
determine whether the questionable TRI reported information is correct and requires no
further action or if the information is erroneous and requires a revision, withdrawal, or new
submission of a TRI report from a facility. This is done to optimize the quality of the TRI data set
used for the development of the next annual TRI National Analysis and used by the public and
other TRI users. Accordingly, the total number of annual data quality targets pursued is no less
than 600.

In addition to identifying the data quality target lists, distributing them to the regional offices
and overseeing the regional activities described above, the TRI Program assists OECA in
identifying potential TRI non-reporters by supplying OECA with information about TRI facilities
that did not file their TRI reports by July 1. This information helps OECA and the regional offices
prioritize compliance monitoring activities that may lead to enforcement actions. The OECA
NPG can be found at: https://www.epa.gov/planandbudget/national-program-guidances.

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Specific regional activities include:

•	Conduct National Analysis and ad hoc: data quality checks, primarily through data quality
emails and follow-up phone calls if needed. The National Analysis data quality checks
provide valuable information and ensure a high-quality TRI National Analysis dataset.

•	Work with facilities to determine if chemical release and threshold calculations are
consistent with national TRI guidance.

•	Tailor the ad hoc data quality checks to the region's specific interests or priorities.

•	Assist state, tribal, and local governments with TRI data access and understanding, for the
purposes of addressing toxic chemicals in their communities under their own authorities,
particularly for community waste reduction and clean-up actions.

•	Hold press events and ask regional offices to participate in the release of information.

Measures

(BFS Code: N-TRI) Completed TRI data quality checks.

•	This measure captures the performance of the TRI program's regional offices contributions
to improving the accuracy and reliability of the program's environmental data.

•	Each regional office will conduct and complete, at a minimum, the regional office's share of
the 600-annual program total data quality checks that each region commits to in BFS.

•	A data quality check is complete when a regional office sends out emails to the identified
facilities and:

o The facility responds with a confirmation of receipt email which includes a statement of
no change (or similar language); or

o The facility responds with a confirmation of receipt email and a statement that it will be
submitting a revision, will provide an update, or has a question. The regional office is
expected to follow up with the facility to determine the revision, update, or answer
questions.

•	The region office will not count the data quality check as complete if the region receives a
bounce back/return to sender email. A confirmed receipt and acknowledgement response
of how the facility will address the check is required for the region to count the effort as a
completed data quality check.

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G. Program Priority: Lead Risk Reduction
Description

The Lead Risk Reduction Program under TSCA Title IV, as enacted by Congress in 1992 is an
important contributor to the Agency's Strategic Plan Goal 2 and Cross-Agency Strategy 2: to
protect children's health, advance environmental justice, and reduce risks to tribes and
vulnerable populations who live in disproportionately impacted communities. The Lead Risk
Reduction Program, including its Categorical Grants component, contributes to the elimination
of childhood lead poisoning by: establishing science based standards governing lead hazard
identification and abatement practices and maintaining a national pool of professionals trained
and certified to implement those standards; providing information to housing occupants so
they can make informed decisions and take actions about lead hazards in their homes; and
establishing and maintaining a national pool of certified firms and individuals who are trained
to carry-out renovation, repair and painting projects while adhering to the lead-safe work
practice standards and to minimize lead dust hazards created in the course of such projects.

Goal 2 of the Strategic Plan sets targets that align closely with Administration priorities set forth
in Executive Order (E.O.) 13985, "Advancing Racial Equity and Support for Underserved
Communities Through the Federal Government" and E.O. 14008, "Tackling the Climate Crisis at
Home and Abroad." Both Executive Orders require EPA to develop implementation plans to
ensure that underserved communities and individuals have full, fair, and equitable access to the
benefits of the Agency's programs. Because low-income, and communities of color are
disproportionally vulnerable to lead exposure, the Lead Risk Reduction Program, which focuses
on reducing environmental lead levels, has the potential to create significant environmental
justice gains.

Goal 7, Objective 7.1 of the FY 2022-2026 EPA Strategic Plan ensures that EPA will continue to
have as much chemical safety information as allowed by law to increase transparency and
support stakeholder engagement activities on chemical risks. In addition, EPA will also continue
to reduce exposures to lead in paint by establishing standards for inspection, risk assessment,
and abatement of lead-based paint hazards, along with training and certification programs,
among other efforts. In addition, Goal 7 will support Goal 2 mentioned above.

The Strategic Plan's Cross-Agency Strategy 2 focuses on protecting and improving the health of
children at all life stages and other vulnerable populations. It aligns with activities from the
December 2018 Federal Acton Plan to Reduce Childhood Lead Exposures and Associated Health
Impacts (Action Plan). The Action Plan is a blueprint for reducing lead exposure and associated
harms through collaboration among federal agencies and with a range of stakeholders,
including states, tribes, and local communities, along with businesses, property owners and
parents.

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The Action Plan has four goals with key priorities and objectives that seek to reduce harm to
children from exposure to lead and includes actions for federal agencies to prioritize their
efforts and monitor progress. The four goals are:

•	Goal 1: Reduce children's exposure to lead sources

•	Goal 2: Identify lead-exposed children and improve their health outcomes

•	Goal 3: Communicate more effectively with stakeholders

•	Goal 4: Support and conduct critical research to inform efforts to reduce lead exposures and
related health risks

EPA's work under the Lead Risk Reduction Program supports the core goals of the Federal lead
Action Plan to further decrease lead exposure to children in the United States and thereby
mitigate adverse health impacts of lead. Specific to the Lead Risk Reduction Program are
objectives and actions corresponding to Goals 1 and 3. Achieving these objectives involves
some level of regional coordination with Headquarters, as follows:

•	Objective 1.1. Reduce Children's Exposure in Homes and Child-Occupied Facilities with Lead-
Based Paint Hazards

o Action: Continue to implement regulations and other relevant authorities that require
individuals and firms conducting lead-based paint abatement, risk assessment or
inspection to be properly trained and certified, training programs to be accredited, and
these activities to be conducted according to reliable, effective, and safe work practice
standards.

o Action: Increase the number (or percentage) of certified renovation firms capable of
providing lead-safe renovation, repair, and painting services through targeted outreach
campaigns to contractors, and continue to provide a nationwide list of certified
renovation firms on the EPA's website.

•	Objective 3.2. Improve Awareness of Lead Hazards, Prevention, and Remediation among
Diverse Populations, Especially Those Most at Risk

o Action: Enhance partnerships with state, tribal and local governments, and key
stakeholders (e.g., media, community groups, faith-based groups, advocacy groups,
departments of health, departments of environmental quality, medical providers,
philanthropies, federal grantees, and others) that represent or serve communities at risk
for childhood lead exposure.

o Action: Increase outreach events and engagement processes in collaboration with at-
risk communities and lead-safe coalitions to provide education on the dangers of lead

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exposures, strategies for reducing exposures in children, and actions to support exposed
children and their families.

In June 2019, EPA announced new, tighter standards for lead in dust on floors and windowsills
to protect children from the harmful effects of lead exposure which resulted in the Dust Lead
Hazard Standards (DLHS) being lowered from 40 |-ig/ft2 and 250 |-ig/ft2 for floors and sills to 10
Hg/ft2 and 100 |-ig/ft2. The standards were revised in 2019 because new data, indicating that
health risks exist at lower blood lead levels than previously recognized, had become available
since the DLHS were originally established in 2001. In addition, on January 2021, EPA lowered
the Dust Lead Clearance Levels (DLCL) for floors and windowsills, that were originally
established in 2001 from 40 |-ig/ft2 and 250 |-ig/ft2 for floors and sills to 10 |-ig/ft2 and 100
Hg/ft2. EPA's 2019 hazard standards and 2020 clearance levels reflect the best available science
on potential human health effects that result from exposure to lead. These actions directly
support the December 2018 Federal lead Action Plan.

In January 2021, the Biden-Harris Administration signed E.O. 13990, "Protecting Public Health
and the Environment and Restoring Science to Tackle the Climate Crisis." The order required an
immediate review of each federal agency's recent actions, including regulations, orders,
guidance documents and policies. EPA's actions for review in accordance with E.O. 13990
included both the 2019 DLHS and 2021 DLCL final rules. As a result, OCSPP is reconsidering the
2019 DLHS and the 2021 DLCL final rules. This is an Administration priority and is being done in
accordance with the May 14, 2021, court opinion and E.O. 13990. The May 14, 2021 court
opinion was a result of the lawsuit filed for the August 2019 DLHS/LBP case where public health
advocates in the Ninth Circuit Court of Appeals were seeking judicial review of the 2019 DLHS
and LBP final rule (including DLCL and soil-hazard standards (SLHS). The court opinion was
averse to EPA's rule on all issues (DLHS, LBP, DLCL, and SLHS) stating that the DLHS were not
lowered to "a level sufficient to protect health as Congress directed, because EPA has looked to
factors in addition to health". EPA policy and guidance documents relating to Lead program can
be found at: https://www.epa.eov/lead/lead-policy-and-euidance.

Strategy

EPA's Lead Risk Reduction Program will pursue a range of activities aimed at addressing and
reducing childhood lead exposure, in accordance with the Agency's Strategic Plan, the Federal
Lead Action Plan, regulations and grant guidance, by continuing to:

•	Establish a national pool of certified firms and individuals who are trained to carry out
renovation and repair and painting projects while adhering to the lead-safe work practice
standards, and to minimize lead dust hazards created in the course of such projects.

•	Establish standards governing lead hazard identification and abatement practices and
maintain a national pool of professionals trained and certified to implement those
standards.

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•	Provide information and outreach to housing occupants and the public so they can make
informed decisions and take actions about lead hazards in their homes.

Activities

Given the importance of meeting EPA's objectives of reducing lead exposure to children and
vulnerable populations in underserved communities, regional offices should fully implement
the first nine Lead Risk Reduction Program activities outlined below and may choose to
implement one or more of the five optional activities. All regional offices should inform the
Director of Office of Pollution Prevention and Toxics (OPPT) Existing Chemicals Risk
Management Division, of their selections among the five optional activities by the end of the
second quarter of FY 2023. Implementation of these activities is contingent upon EPA receiving
Congressionally appropriated funds for the Lead Risk Reduction Program.

•	Section 404(g) Grant Program Management: Manage the section 404(g) grant program in
accordance with the section 404(g) grant guidance document. Funds are to be used for
authorizing and developing state or tribal lead abatement and renovation programs, for
direct implementation in non-authorized states or tribes, or to support the certification of
renovation and abatement professionals and the accreditation of training providers.

•	Outreach for Lead Rules: Provide outreach for Pre-Renovation Education Rule section 406 of
Title IV (406), the Lead Abatement Rule section (402(a)), the Renovation, Repair and
Painting Rule section (402(c)) and, to a limited extent, the Disclosure Rule section (1018).

•	Renovation, Repair, and Paint (RRP) Rule section (402(c)) Implementation: Assist in the
implementation of the RRP Rule by accrediting qualified training providers and providing
information and compliance assistance to the regulated community.

•	Lead-based Paint Activities Rule section (402(a)) (Abatement, Risk Assessment and
Inspection) Implementation: Assist in the implementation of the Lead-based Paint Activities
(Abatement, Risk Assessment and Inspection) Rule by accrediting qualified training
providers, certifying individuals (Regions 2 and 9) and by providing information and
compliance assistance to the regulated community.

•	Dust-Lead Hazard Standards Rule (DLHS) section (403) and Dust-Lead Clearance Levels rule
(DLCL) section (402) Implementation: Provide outreach for the DLHS and DLCL rules in
states, tribes, and territories where EPA directly implements the LBP Activities Program. The
effective date for DLHS and DLCL in these states, tribes and territories was January 6, 2020,
and March 8, 2021, respectively. In addition, regional offices should continue collaboration
with their authorized states and/or tribes to assist them in revising their regulations to be at
least as protective as the federal program for DLHS by March 8, 2023, similarly to assistance
provided for DLCL which was completed in January 2022. These final rules will help ensure
environmental justice concerns are addressed in communities impacted by hazards from
lead-based paint.

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•	Encourage State and Tribal RRP Program Authorization: Collaborate with their states and/or
tribes to encourage them to become authorized to run the RRP program. Regional offices
should work with states or tribes to provide information regarding the benefits of the
program, identify roadblocks to RRP program authorization, identify and educate
appropriate stakeholders, and facilitate discussions amongst states and tribes that have
received authorization and/or those seeking authorization.

•	Lead Risk Reduction Program Coordination with OECA: Coordinate implementation of the
full suite of Lead Program regulations and activities as expressed here and in the
complementing document Final FY 2023-2024 OECA National Program Guidance including
compliance assistance, monitoring and enforcement strategies that can be found at:

https://www.epa.gOv/planandbudget/national~program~guidances#fy20232024.

•	Outreach to Renovators, Homeowners, Property Management Companies, and Owners of
Child-Occupied Facilities; Provide information on the hazards of renovation activities in
homes and child-occupied facilities with lead-based paint. This outreach should stress the
importance of using an EPA Lead-Safe Certified firm and the benefits of following lead safe
work practices. Outreach should target renovation firms, owners of child-occupied facilities,
homeowners, and renters in areas with older housing, vulnerable populations in
underserved communities. Initiatives such as the Enhancing Lead-Safe Work Practices
through Education and Outreach (ELSWPEO) are strongly encouraged. ELSWPEO focused on
underrepresented and underserved communities with environmental justice concerns
whose populations are disproportionately affected by lead exposure. The initiative's goal is
to increase the number of lead-safe certified contractors and community awareness of the
hazards from lead-based paint.

•	Engagement with State/City Permitting and Licensing Officials: Work with permitting and
licensing offices to require that firms have shown proof of Lead RRP certification prior to
permits being issued. Because of the strong and direct connection between licensing and
permitting offices and the construction industry, this is especially valuable in supporting
implementation of the Lead RRP Rule. As resources permit, regional offices are also
encouraged to engage code enforcement programs to raise awareness of Lead RRP
requirements and to advance the capacity of code enforcement officers to address lead-
based paint hazards.

The experience of regional offices partnering with key stakeholders has provided additional
opportunities to further leverage EPA resources to accomplish the goals of the Lead Risk
Reduction Program. In the course of partnering and coordination efforts by regional offices,
they may also choose to enhance implementation of one or more of the following Lead Risk
Reduction Program activities:

•	Partner with Tribes: Continue building relationships with tribes by establishing and
nurturing capacity building, technical assistance and research partnerships and conducting
outreach and consultation. Regional offices could create opportunities for partnerships with

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their Tribes to address lead-based paint hazards and exposure reduction including Direct
Implementation Tribal Cooperative Agreements (DITCAs) and Memoranda of
Understandings. Regional offices could partner with Tribes to identify projects, DITCA-
related activities, or ongoing projects to reach the national goal of eliminating childhood
lead poisonings.

•	Partner with Child-focused Stakeholders to Educate about Lead RRP: Partner with federal,
state, local organizations, childcare providers, and child-focused entities to develop
outreach strategies that stress the importance of using an EPA Lead-Safe Certified firm and
the benefits of following lead safe work practices. Outreach should target areas with older
housing or vulnerable populations in underserved communities and renovation firms. These
partnerships can also focus on increasing public awareness about preventing childhood lead
poisoning, particularly among low-income and other vulnerable populations in underserved
communities who may suffer disproportionately.

•	Partner with Public Health Community to Educate about Lead RRP; Perform outreach to the
public health community, including pediatric organizations, doctor offices, hospitals, and
other medical facilities to increase public awareness about the hazards and prevention of
childhood lead poisoning. Regional offices could provide information on the importance of
using an EPA Lead-Safe Certified firm.

•	Partner with States for Lead Education and Outreach; Partner with their states to conduct
lead-based paint risk reduction education and outreach in areas with high concentrations
of children with elevated blood levels.

•	Collaborate with other Federal Agencies: Create opportunities for partnerships with other
Federal agencies and work with them to gain access or knowledge about activities other
Federal agencies are conducting in tribal or underserved communities and reach the
national goal of eliminating childhood lead poisonings.

Measures

To track progress against the important agency objectives from the Action Plan, OCSPP
developed one measure for region-specific activities. The OCSPP Agency Action Plan measures
will be tracked via the Federal Action Plan process, with the following measures reported by
each region: Objective 1.1 Reduce Children's Exposure in Homes and Child-Occupied Facilities
with Lead-Based Paint Hazards (measure: Report the number of compliance assistance and
outreach activities that support the abatement, risk assessment and inspection components of
the Lead-Based Paint Program).

Additional measures to track regional activities in the BFS include:

(BFS Code: N-RRPday) Average number of days to complete reviews for Lead RRP Training
Provider Reaccreditations

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•	This measure tracks the number of days it takes the regional offices to process Lead-Based
Paint RRP Training Provider Reaccreditations.

•	The measure is calculated by taking the number of total regional processing days divided by
reaccreditations that were processed.

•	Reaccreditations are tracked in the Federal Lead-Based Paint tracking system and reported
by the sub-lead regional coordinator to the region for confirmation.

(BFS Code: N-RRPfr) Increase the rate of Lead RRP firm recertifications.

•	This Strategic plan long-term performance goal tracks the percentage of Lead RRP firms
whose certification are scheduled to expire that are recertified before the expiration date.

•	This measure is calculated by taking the number of firms that get recertified divided by the
number of expiring firm certifications.

•	Recertifications are tracked in the Federal Lead-Based Paint tracking system and reported
by the Lead Program.

(BFS Code: N-RRPapp) Annual percentage of viable lead-based paint abatement certification

applications that require less than grantee state-established timeframes to process.

•	This measure examines the efficiency of authorized Grantee-States as they process viable
abatement certification applications within the Grantee-State established timeframes.

•	Each regional office should ensure that states can achieve the minimum planning target.
The number agreed upon should be a reasonable determination that reflects the length of
time that it takes the Grantee-State to process an application, as identified by the Grantee-
State and represented to the public.

•	The regional offices should report the number of applications processed by Grantee-State,
Grantee-State timeframes (number of days taken to process a viable application) for each
shareholder (state or tribe) and the percentage of applications processed under the
Grantee-State established timeframe. The timeframe may vary by state, taking variables
such as regulations and contractor processing time into account.

(BFS Code: N-RRPab) Number of lead abatements performed by certified abatement

contractors occurring in the region.

•	This measure looks to measure the number of abatements that occur within each state. The
measure will provide valuable information on the number of abatements performed by
properly trained abatement contractors certified by the EPA and the authorized programs
as an indicator of risk reduction.

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•	Regional offices should only count the number of abatement notifications received in the
fiscal year in order to accurately assess the number of abatement activities being done in
the region.

(BFS Code: N-RRP2) Number of active lead-based paint renovation, repair and painting
certification training providers accredited by the regional office.

•	This measure captures the number of training providers for lead-based paint RRP Rule with
active accreditations processed by the regional office.

•	Regional offices should only count the Lead RRP trainers where EPA runs the program; they
should not count Lead RRP trainers in states where there is a state authorized program.
Regional offices should count the number of current accredited trainers whose
accreditations were processed by that regional office by September 30, the last working day
of the fiscal year.

•	This measure does not count the number of accredited training courses. It also does not
measure the nation's capacity for training, but rather the workload of the regional offices in
accrediting trainers.

(BFS Code: N-RRPtr) Number of tribal partnerships including projects addressing lead-based
paint hazards and exposure reduction in the region.

•	This measure tracks the number of tribal partnerships including other projects addressing
lead-based paint hazards and exposure reduction on tribal lands. Tribal partnerships are a
subset of overall lead projects or partnerships.

•	Examples of Tribal partnerships or projects include: Direct Implementation Tribal
Cooperative Agreements (DITCAs), on-going projects, outreach, DITCA related activities,
cooperative agreements, formal agreements, tribal grants, Memoranda of Understanding
(MOUs), etc.

H. Program Priority: Pollution Prevention (P2)

Description

The EPA P2 Program operates on a simple and powerful truth: that an ounce of prevention is
worth a pound of cure - it's often cheaper to prevent pollution from being created than to
clean it up afterwards or pay for control, treatment, and disposal of waste products. As
importantly, from a business perspective, all forms of waste represent inefficient expenditures.
If a business can reduce resource expenditures, reduce waste, or eliminate waste altogether,
that immediately translates to the bottom-line by reducing operating expenses and reducing
environmental, regulatory and liability costs. Those same actions that can save businesses

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money can also reduce risks to human health and the environment. The P2 philosophy supports
the efforts of Strategic Plan Goal 1, Tackle the Climate Crisis.

The EPA P2 Program is a non-regulatory program (there are no requirements imposed on a
regulated entity). As required by the Pollution Prevention Act of 1990 and the Infrastructure
Investment and Jobs Act of 2021, the EPA P2 Program works with, states, tribes, and others to
encourage businesses to facilitate adoption of P2 approaches through the development and
delivery of P2 information and tools, technical assistance, training, and funding innovations.
The P2 approaches from this work are documented and widely shared so that others may
amplify and replicate those approaches and outcomes elsewhere. The P2 Program also helps
markets function by providing information to manufacturers, suppliers, and purchasers on
environmental performance. These approaches help:

•	Protect human health and the environment.

•	American businesses compete economically through improved environmental performance.

•	American manufacturers reduce costs and adopt innovative practices.

•	Spur, leverage, and amplify innovation and reduce the costs of small/medium companies to
identify and test P2 innovation.

More information about EPA's P2 Program can be found at http://www.epa.gov/p2/.

Strategy

P2 National Emphasis Areas: To give the P2 Program a more coordinated and centralized focus
aimed at creating more impactful and measurable results, the P2 Program will continue to
prioritize efforts on the following five industrial sector National Emphasis Areas (NEAs), plus a
newly added NEA aimed at supporting P2 in Indian country and Alaskan Native Village:

•	NEA #1: Food and Beverage Manufacturing and Processing.

•	NEA #2: Chemical Manufacturing, Processing and Formulation.

•	NEA #3: Automotive Manufacturing and Maintenance.

•	NEA #4: Aerospace Product and Parts Manufacturing and Maintenance.

•	NEA #5: Metal Manufacturing and Fabrication.

•	NEA #6: Supporting Pollution Prevention in Indian Country and Alaskan Native Villages

In addition, the P2 Program will support the Biden Administration priorities related to
environmental justice (EJ) and climate change.

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New P2 Grants Funded by the Infrastructure Investment and Jobs Act: The Bipartisan Instructure
Law, also called the Infrastructure Investment and Jobs Act of 2021, provided EPA $100 million
dollars over five years for additional grants to states and tribes to provide P2 technical
assistance to businesses under section 6605 of the P2 Act. As a result of this additional funding,
the P2 Program is establishing new P2 Grant Programs in addition to continuing to administer
the P2 STAG grant program funded with regular appropriations. The regional offices and OPPT
will work together in the development and implementation of these new grant programs,
which will provide a greater emphasis on using a variety of P2 approaches to address EJ and
climate change.

Activities

Working in collaboration with HQ, regional offices will help develop and implement the P2
STAG grant programs, implement, and support the NEAs, integrate environmental justice and
climate change considerations, facilitate cross regional coordination, and leverage and amplify
P2 innovations and case studies. In this regard, regional offices are encouraged to engage P2
stakeholders to develop options, initiatives, informational materials, and training to meet the
needs of the national P2 program and their region, states, tribes, and communities. Regional
offices also have flexibility to engage in P2 activities outside of the P2 grants and those
described in the Guidance that respond to unique regional situations. Regional offices will
communicate those additional activities to the Branch Supervisor of the Sustainability and
Pollution Prevention Branch in OPPT's Data Gathering and Analysis Division (DGAD).

•	Administer Grant Programs and Enhance Accountability

o HQ and Regional offices should jointly administer P2 STAG grant programs per statutory
authorities, programmatic grants, and measurement policies. Additionally, offices
should actively promote the availability of grant programs to both existing and new
potential applicants and provide outreach information or training on grant solicitations
to potential applicants to maximize competition.

o Regional offices should ensure P2 grantee reporting conforms with the measures and
reporting described in the P2 Grant Request for Applications (RFA).

¦ Complete a quality assurance (QA) review of annual grantee reporting by April 15
(use the new P2 Grants Database when available).

o Regional offices should ensure grantees develop and submit to EPA P2 case studies as
described in the P2 Grant RFAs.

•	Integrate P2 within EPA

o Regional offices are encouraged to work with the HQ and regional media programs to
explore and assist with promoting and implementing pollution prevention and source
reduction opportunities in other EPA programs.

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•	Enhance P2 Communication and Amplification

o Regional offices should support the development, documentation, communication, and
amplification of P2 case studies so that others can replicate those approaches and
results across the country.

o Regional offices should plan and implement P2 outreach during P2 Week.

o Regional offices are encouraged to use the P2 Hub

(https://www.epa.gOv/p2/forms/contact~us~about~pollution~prevention#helpline) as a
resource and make other P2 stakeholders aware of the P2 Hub as a resource.

•	Nurture External Capacity to Achieve Results

o Regional offices are encouraged to support state, tribal, and local partnerships by
providing networking opportunities for P2 technical assistance providers (TAPs) and
businesses to ensure continued effectiveness and competence in source reduction
practices and in dealing with issues such as green chemistry, Environmentally
Preferrable and Safer Choice-certified products.

o Regional offices are also encouraged to find opportunities to emphasize P2 technical
assistance that can address environmental justice (EJ) concerns in underserved
communities and/or climate change impacts.

o Regional offices should participate in and provide support to the P2 Affinity Groups,
which meet regularly to provide an opportunity for P2 grantees working on similar
issues and NEAs to network, share information, and problem solve.

o Regional offices are encouraged to work with trade associations and other industry
groups to develop training that amplifies P2 innovations across sectors and industries
and to support networking and exchange of information among P2 stakeholders.

•	Transform the Marketplace with P2

o Regional offices are encouraged to promote awareness and purchasing of Safer Choice-
certified products (https://www.epa.eov/saferchoice) and products conforming to the
EPA Recommendations of Specifications. Standards, and Ecolabels (e.g., working with
state and local governments, tribes, schools, colleges, hospitals, daycare facilities, trade
associations, etc.) (https://www.epa.gov/greenerproducts/recommendations~
specif ications~sta nda rds~and~ecola be ls-federal~purchasing).

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Measures

HQ and regional offices should report P2 grant results as described in the P2 Grants Request for
Applications (RFAs). In addition, regional offices should annually report to OPPT/DGAD by
March 31:

•	(BFS Code: N-P2case) Number of P2 case studies developed and submitted to OPPT for
posting on the EPA P2 website in the P2 Resources Search Tool:

https://www.epa.eov/p2/p2-resources-search.

o This measure captures the number of P2 cases and other P2 documentation

products describing specific P2 best practices identified, developed, or implemented
through the grant.

•	(BFS Code: N-P2acts) Number of activities performed to amplify the lessons learned from
the P2 Grants and provide P2 information to businesses and others (e.g., webinars,
trainings, outreach materials developed, P2 roundtables).

o This measure captures the number of amplification activities (i.e., training, webinars,
videos, other outreach) that widely share P2 practices and P2 documentation products.

o Note: For each amplification activity, grantees will also be asked to report on:

¦	topic(s) covered,

¦	number of facilities attending training or webinars, or receiving outreach
materials,

¦	percentage of participants reporting increased understanding of topics covered,
and

¦	EJ: Number of amplification activities that target underserved communities.

•	(BFS Code: N-P2ej) Number of EJ communities, as identified from the EPA EJ demographic
index, and/or tribes engaged or provided P2 outreach.

o This measure captures the number of EJ communities that benefitted as a result of the
P2 outreach and/or technical assistance provided by the grantee.

•	(BFS Code: N-P2grnt) Number of P2 grants that fully reported the required output and
outcome measures described in the P2 Grant RFAs.

o This measure captures the number of P2 grants that fully comply with reporting on the
outputs and outcomes outlined in the P2 RFA. This number should equal the number of
P2 grants awarded in each region.

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• (BFS Code: P2mtc) Metric tons of carbon dioxide equivalent (MTC02e) reduced or offset
through pollution prevention in the region.

o This measure captures the reductions in metric tons of carbon dioxide equivalent
(MTCChe) resulting from implementing the P2 actions.

SECTION III. IMPLEMENTING TRIBAL WORK

The Pesticide Program will also continue to manage the Tribal Pesticide Program Council (TPPC)
cooperative agreement which provides support for this national partnership group. Formed in
1999, the TPPC provides a forum for tribes and Alaska Native Villages to work with EPA to
address pesticide issues and concerns specific to tribal communities. The TPPC also provides a
forum for tribes and Alaska Native Villages to provide input in developing policies that would
strengthen their pesticide programs, provide guidance for tribes that do not have such
programs, and provide networking opportunities and support for tribal pesticide regulators.

The TPPC has highlighted training as one of their top priorities. As a result, the TPPC and EPA
encourages tribes, where appropriate and feasible, to increase their communications and
coordination with state pesticide programs as a resource for tribes to build capacity for their
own pesticide programs. Increased communication and coordination between states and tribes,
which respect tribal sovereignty and jurisdiction, can improve tribal access to programmatic
and technical expertise, support, and training.

Examples of areas where state pesticide programs may be able to offer low cost support
include: offering a few seats to tribal pesticide program staff or managers when training is
conducted for state personnel; allowing tribal inspectors to accompany state inspectors on
inspections for training purposes; offering tribes access to or use of state tools, templates,
checklists or databases; sharing information on tips and complaints, violations or incidents that
may be relevant to Indian country; having states routinely inform tribes when they issue a
FIFRA section 24(c) or request a FIFRA section 18 from the EPA; sharing pesticide monitoring
data; establishing state technical and program expert contacts for tribal pesticide personnel;
and offering tribes access to state laboratories.

The EPA regional offices can help support tribal training and facilitate increased communication
and coordination between tribal and state pesticide programs by acting as an intermediary and
catalyst, where appropriate and feasible. For example, regional offices may be able to
encourage or help establish state and tribal agreements of support. In some cases, it may be
appropriate to include specific activities and goals in support of this priority in the state and
tribal FIFRA Cooperative agreements and workplans. All approaches must support and respect
tribal sovereignty.

Efforts to build tribal pesticide program capacity through this approach supports Goal 2 of the
agency's Strategic Plan by protecting human health and the environment in support of the

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agency's tribal and environmental justice goals. This approach is also consistent with Principle
#6 of the agency's 1984 Indian Policy (https://www.epa.gov/tribal/epa-policy-administration-
environmental-programs-indian-reservations-1984-indian-policy), which encourages
communication and cooperation between tribal, state, and local governments.

The Office of Pollution Prevention and Toxics will continue to support the National Tribal Toxics
Council's (NTTC) goal to improve tribal environmental health through EPA-tribal collaborative
integration and enhancement of tribal chemical risk management policies and programs. The
project objectives are to engage federally recognized tribes in 1) developing their informed
chemical management and P2 programs and practices, and 2) collaborating with EPA in
developing its federal program of rules, policies, and projects to best protect tribal peoples.

EPA and the NTTC will work cooperatively to fulfill the following objectives including:

•	Raise and assess tribal chemical risk management and P2 program development and
implementation issues with OPPT.

•	Assess national chemical risk management policy and P2 initiatives that affect tribes and
Alaska Native Villages.

•	Offer a network for tribal chemical risk management officials to share information and
represent tribal interests on chemical risk assessment, risk management policy and P2
initiatives that impact tribes.

•	Promote and enhance tribal chemical risk management and P2 program development.

The NTTC's expected outcomes of increased prioritization and understanding by tribes of their
own and EPA's chemical risk management and P2 programs; and increased participation and
engagement of tribal peoples in EPA's chemical risk management and P2 programs and
rulemaking support Goal 2 of the agency's Strategic Plan by protecting human health and the
environment and the agency's tribal and environmental justice goals.

SECTION IV. FLEXIBILITY AND GRANT PLANNING

Under traditional environmental program grants, sometimes called "categorical" grants, states
receive funds to implement the pesticides and toxic substances programs, and other agency
environmental programs. Environmental program grant funds can only be spent on activities
that fall within the statutory and regulatory boundaries of that program. By combining two or
more of their environmental program grants into a Performance Partnership Grants (PPG),
states and tribes are able to perform and report on the grant activities under one workplan. The
OCSPP eligible environmental program grants are listed below.

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•	CFDA 66.700: Federal llnsectic	igicide arid Rodertticide Act State arid Tribal Assistance
Grant Program

•	CFDA 66.707: II i II mile IV StcU' II 
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agreement responsibilities. Additional information regarding the FIFRA Cooperative Agreement
Guidance can be found at: https://www.epa.gov/compliance/fiscal-year-2018-2021-fifra-
cooperative-agreement-guidance. Additional information for the Lead Risk Reduction program
can found at: https://www.epa.gov/lead/lead~policy-and~guidance. Additional information

regarding the P2 grants can be found at: https://www.epa.gov/p2/erant-programs-pollution-
prevention.

Through the National Environmental Performance Partnership System (NEPPS), OCSPP
encourages the continued use of Performance Partnership Agreements (PPAs), and PPGs as
vehicles for continuous collaboration and for increasing administrative, financial, and
programmatic flexibilities for states, tribes, and territories. More information on NEPPS, PPAs,
and PPGs can be found at the FY2023-2024 Office of Congressional and Intergovernmental
Relations (OCIR) National Program Guidance: https://www.epa.gov/planandbudget/national-
program-guidances and https://www.epa.gov/ocir/national~environmental~performance~
partnership-system-nepps.

SECTION V. FEDERAL CIVIL RIGHTS RESPONSIBILITIES, INCLUDING
TITLE VI OF THE CIVIL RIGHTS ACT OF 1964

In 1994, Executive Order 128981 was issued to direct Federal agencies to incorporate achieving
environmental justice into their mission. The Presidential Memorandum2 accompanying that
Executive Order required in part, that consistent with Title VI, each Federal agency "...ensure
that all programs or activities receiving Federal financial assistance that affect human health or
the environment do not directly, or through contractual or other arrangements, use criteria,
methods, or practices that discriminate on the basis of race, color, or national origin."3

EPA has a responsibility to ensure that recipients and subrecipients of federal financial
assistance from EPA—including states, municipalities, and other public and private entities-
comply with federal civil rights laws that prohibit discrimination on the basis of race, color,

1	Executive Order 12898: Federal Actions to Address Environmental Justice in Minority Populations and Low-
Income Populations, 59 FR 7629, February 16,1994. (https://www.archives.gov/federal-register/executive-
orders/1994.html#12898)

2	Presidential Memorandum on Executive Order for Federal Actions to Address Environmental Justice In Minority
Populations and Low-Income Populations (pdf): https://www.epa.gov/sites/default/files/2015-
02/documents/clinton memo 12898.pdf

3	Id.

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national origin (including limited English proficiency), disability, sex and age, including Title VI of
the Civil Rights Act of 1964.4

EPA's implementing regulation generally prohibits discrimination in any programs, activities,
and services receiving federal financial assistance (40 C.F.R. § 7.30;

https://www.ecfr.gov/current/title-40/chapter-l/subchapt	jbpart-B/section-7.30).

In addition, EPA's implementing regulations at 40 C.F.R. § 7.35 states that programs or activities
receiving EPA assistance "shall not directly or through contractual, licensing, or other
arrangements on the basis of race, color, or national origin...":

•	subject a person to segregation or separate treatment;

•	deny a person or group the opportunity to participate as members of any planning or
advisory body;

•	restrict a person in any way in the enjoyment of any advantage or privilege enjoyed by
others receiving any service, aid, or benefit provided by the program;

•	use criteria or methods of administration "which have the effect of subjecting individuals to
discrimination;" or

•	choose a site or location of a facility with "the purpose or effect of excluding individuals
from, denying them the benefits of, or subjecting them to discrimination," among other
things.

EPA's nondiscrimination regulation at 40 C.F.R. Parts 5 and 7 also contain longstanding
procedural requirements applicable to applicants for and recipients (including sub-recipients) of
EPA financial assistance.5 These requirements include having a notice of nondiscrimination,
nondiscrimination coordinator, grievance procedures, a process for collecting and maintaining
nondiscrimination compliance information, and pursuant to Title VI and the Rehabilitation Act
of 1973, developing policies and procedures for ensuring meaningful access to programs and
activities for individuals with limited-English proficiency and individuals with disabilities. In

4	Title VI of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000(d) etseq. (Title VI); Section 504 of the Rehabilitation Act
of 1973, as amended, 29 U.S.C., 29 U.S.C. § 794, Title IX of the Education Amendments of 1972, as amended, 20
U.S.C. §§ 1681 et seq.; Age Discrimination Act of 1975,42 U.S.C. §§ 6101 et seq.; Federal Water Pollution Control
Act Amendments of 1972, Pub. L. 92 500 § 13, 86 Stat. 903 (codified as amended at 33 U.S.C. § 1251 (1972)); 40
C.F.R. Parts 5 and 7.

5	EPA's nondiscrimination regulation at 40 C.F.R. Parts 5 and 7 requires recipients to establish and implement their
own nondiscrimination programs. See 40 C.F.R. §§ 7.80-7.100.

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addition, recipients' public participation processes must also be implemented consistent with
the federal civil rights laws.6

EPA intends to carefully evaluate the implementation of EPA financial assistance programs to
ensure compliance with civil rights laws by recipients of EPA funding and that no community is
excluded from receiving or denied benefit of EPA funding based on race, color, national origin
(including limited English proficiency), age, disability, or sex.

For more information about the federal civil rights laws enforced by EPA, including Title VI,
please visit: https://www.epa.eov/ocr/title-vi-laws-and-reeulations and
https://www.epa.eov/oec/external-civil-riehts-compliance-office-title-vi.

6 See Title VI, 42 U.S.C. 2000(d) etseqSection 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 794;
Lau v. Nichols, 414 U.S. 563, 568-69 (1974) (finding that the government properly required language services to be
provided under a recipient's Title VI obligations not to discriminate based on national origin); 40 C.F.R. § 7.35(a).
See also U.S. EPA, Guidance to Environmental Protection Agency Financial Assistance Recipients Regarding Title VI
Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons. 69 FR 35602 (June
25, 2004) (available at https://www.epa.gov/sites/production/files/2020-

02/documents/title_vi_lep_guidance_for_epa_recipients_2004.06.25.pdf);_U.S. EPA, Title VI Public Involvement
Guidance for EPA Assistance Recipients Administering Environmental Permitting Programs, 71 FR 14207 (March 21,
2006) (available at https://www.epa.gov/sites/production/files/2020-

02/documents/title_vi_public_involvement_guidance_for_epa_recipients_2006.03.21.pdf); U.S. EPA, Procedural
Safeguards Checklist for Recipients, at https://www.epa.gov/sites/prodyction/files/2020-
02/documents/procedural safeguards checklist for recipients 2020.01.pdf (rev. Jan. 2020) (which provides a
more detailed explanation of nondiscrimination obligations and best practices): U.S. EPA, Disability

Nondiscrimination Plan Sample, at https://www.epa.gov/sites/production/files/2020-

02/documents/disability nondiscrimination plan sample for recipients 2020.01.pdf. (2017).

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SECTION VI. FY 2023-2024 NATIONAL PROGRAM MEASURES

Subject
Area

BFS Code

Measure Text

FY 2023 National
Planning Target

Comments/
Clarification

TRI

N-TRI

Completed Toxics Release
Inventory (TRI) data quality checks

600

Region

Lead

N-RRPday

Average number of days to
complete reviews for Lead RRP
Training Provider Reaccreditations



Region

Lead

N-RRPfr

Increase the rate of Lead RRP firm
recertifications



Region/State

Lead

N-RRPapp

Annual percentage of viable lead-
based paint abatement
certification applications that
require less than grantee state-
established timeframes to process



Region/State

Lead

N-RRPab

Number of lead abatements
performed by certified abatement
contractors occurring in the region



Region/State

Lead

N-RRP2

Number of active lead-based paint
renovation, repair and painting
certification training providers
accredited by the regional office



Region/State

Lead

N-RRPtr

Number of tribal partnerships
including projects addressing lead-
based paint hazards and exposure
reduction in the region.



Region/Tribe

P2

N-P2case

Number of P2 case studies
developed and submitted to OPPT
for posting on the EPA P2 website
in the P2 Resources Search Tool



Region/State
/Tribe

P2

N-P2act

Number of activities performed to
amplify the lessons learned from
the P2 Grants and provide P2



Region/State
/Tribe

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information to businesses and
others

P2 N-P2ej Number of EJ communities, as
identified from the EPA EJ
demographic index, and/or tribes
engaged or provided P2 outreach

P2 N-P2grnt Number of P2 grants that fully

reported the required output and
outcome measures described in
the P2 Grant RFAs

P2	P2mtc Metric tons of carbon dioxide

equivalent (MTC02e) reduced or
offset through pollution
prevention in the region

Region/State
/Tribe

Region/State
/Tribe

Region/State
/Tribe

SECTION VII. CONTACTS

Contact Name

Subject/Program Area

Phone

Email

Jennifer Vernon

OCSPP Planning and
Accountability Lead

202-564-6573

Vernon.jennifer@epa.gov

Cindy Wire

Office of Pesticide
Programs (OPP)

415-947-4242

Wire.Cindy@epa.gov

Edna Kapust

OPPT Office of
Pollution Prevention
and Toxics (OPPT)

202-564-8818

Kapust.edna@epa.gov

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