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The definition of “wipe sample” relies on two very specific American Society of Testing Materials (ASTM) standards. In referencing the ASTM standards, did EPA intend to prevent the use of EPA and HUD standards for wipe samples?
Answer: No. In establishing work practice standards for lead-based paint activities, EPA did not intend to prevent the use of EPA/HUD standards. As a general matter, the requirements are not prescriptive, but instead state that certain activities be conducted using appropriate documented methodologies. For example, §745.227(c)(3) requires that dust samples…
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Does EPA require inspectors, risk assessors, dust sampling techs, or anyone who performs LBP and/or lead dust sampling to document any visible LBP deterioration on components and estimate the surface area of deteriorating paint during a lead evaluation?
Answer: It depends on the type of evaluation being done. The work practice standards at 40 C.F.R. 745.227 provide instructions for addressing deteriorated lead-based paint during lead hazard screens, risk assessments, and post-abatement clearance activities. Inspections only examine the presence of leadbased paint and do not consider deterioration. Instructions for…
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Must all persons present on an abatement job site be certified?
Answer: No. The regulations at 745.220(b) require that persons engaged in lead-based paint activities defined in 745.223 must be certified. The work practice standards at 745.227 are specific as to which disciplines may perform which lead-based paint activities. However, EPA recognizes that other activities such as interim controls may also…
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Do EPA’s current rules require inspectors, risk assessors, dust sampling technicians, or any individual who performs lead-based paint and/or lead dust sampling to document any visible lead-based paint deterioration on components and estimate the surface area of deteriorating paint during a lead evaluation?
Answer: It depends on the type of evaluation being done. The work practice standards at 40 CFR 745.227 provide instructions for addressing deteriorated lead-based paint during lead hazard screens, risk assessments, and post-abatement activities. Inspections only examine the presence of lead-based paint and do not consider deterioration. Instructions for dust…
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Immediately following the completion of renovation activities, a company conducts an examination which reveals dust levels above the action level. Is removal of dust to address the failure of this examination considered abatement?
Answer: No. The removal of dust to address the failure of the examination would be considered part of cleanup from the renovation. Routine cleanup of renovation-related dust is not abatement, even if the dust is known to be above the dust lead reportable level. For more information on lead-safe work…
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What is the difference between Abatement Certification and Renovation (RRP) Certification?
Answer: Abatement certification, also known as Lead-Based Paint Activities certification, is a specialized type of certification for firms who specifically work with lead-based paint such as lead abatement firms, lead risk assessor firms, and lead inspection firms. Abatement intentionally addresses lead-based paint hazards. Renovation (RRP) certification is appropriate for firms…
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What is included in the emissions “Tiers”?
The Tiers are assigned by a Source Classification Code (SCC), which has the most detail about the emissions processes that generate the emissions. The full list of SCCs, their associated Tiers, and the SCC descriptions is available online at https://ofmpub.epa.gov/sccwebservices/sccsearch/ .
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In some areas of the country, refresher courses are offered infrequently. Can an individual applying for recertification re-take an initial course in the lead-based paint activity discipline for which they are certified instead of taking a refresher course?
Answer: Yes. The certified individual can simply re-take the initial course in the discipline for which they are certified. Question Number: 23002-33463 Find a printable PDF copy of all frequent questions pertaining to lead .
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Must employees of Federal agencies who conduct lead-based paint activities be certified as individuals? Must their agencies be certified as firms? Must Federal agencies pay certification fees for individuals and firms?
Answer: Yes. TSCA section 408 generally requires Federal agencies and their employees to comply with all Federal, State, interstate, and local requirements, both substantive and procedural, respecting leadbased paint, lead-based paint activities, and lead-based paint hazards in the same manner and to the same extent as any non-governmental entity is…
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Must I take a third party certification exam?
Answer : No third party exam is required for recertification, even if you choose to take another initial training course rather than a refresher training course. Question Number: 23002-32439 Find a printable PDF copy of all frequent questions pertaining to lead .
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Must self-employed or one-person businesses that perform lead-based paint activities, such as lead-based paint inspections, risk assessments, or abatements, be certified as firms in addition to being certified as individuals?
Answer: Yes. Under 745.226(a)(5), individuals performing lead-based paint activities must be certified, so all self-employed persons must be certified as individuals in the appropriate discipline(s). In addition, the definition of certified firm at 745.223 includes sole proprietorships that perform lead-based paint activities. The definition of certified firm also includes other…
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Does TSCA section 402 apply to U.S. military bases, facilities, and installations located outside of the U.S.?
Answer: No. EPA does not have authority to regulate environmental conditions in foreign countries. Environmental compliance by Department of Defense installations overseas is governed by a number of documents. For example, Executive Order 12088, dated October 13, 1978, requires that the heads of government agencies responsible for constructing or operating…
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If a person takes supervisor training, is that person qualified to seek certification as a worker?
Answer: Yes. The training requirements of supervisors cover the same topics required of workers and there are no additional education or experience requirements for workers. Therefore, a person who successfully completes supervisor training would be qualified to seek certification as a worker. Question Number: 23002-33451 Find a printable PDF copy…
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Must refresher course completion certificates for lead-based paint abatement certification bear an expiration date?
Answer: No. The requirement that a completion certificate include an expiration date only applies to “interim certifications.” Refresher course completion certificates do not expire in the Federal program. Specifically, 40 CFR 745.225(e)(4) and (e)(5)(vi), in describing requirements for refresher courses, refer back to 40 CFR 745.225(c), the requirements for initial…
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What if I am already certified by an EPA authorized state or tribal program?
Answer: If you are already certified by an EPA-authorized program in a particular discipline, and you want to obtain Federal certification, you must be prepared to submit the following in your online application : Copy of your currently valid certificate (license/permit) from the authorized State or Tribe. Passport photograph (JPG…
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