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CFAT Impacts on EPCRA and RMP
The Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS) impose comprehensive federal security regulations for high-risk chemical facilities. Do the CFATS alter the requirements that apply to a facility covered under both CFATS and either the Emergency Planning and Community Right-to-Know Act (EPCRA) or the Clean Air Act section…
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EPCRA Reporting Mechanisms for Protecting Sensitive Business Information
Does EPCRA provide any mechanisms for facilities that must submit Tier II inventory information to protect sensitive business information? Trade secret and confidential location information (CLI) are two separate confidentiality provisions under EPCRA. Trade secret claims made under EPCRA Sections 303, 311, 312, or 313 allow facilities to claim the…
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Where can I get more information or copies of the lead-based paint abatement application forms and instructions?
Answer: Information regarding certification under EPA’s lead-based paint abatement program is available at https://www.epa.gov/lead/lead-based-paint-abatement-and-evaluation-program-overview . Question Number: 23002-32438 Find a printable PDF copy of all frequent questions pertaining to lead .
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When must I take refresher training?
You must take refresher training before you apply for recertification to EPA. You should begin looking for available courses well before your current certification expires, because refresher courses may not be available in your area on a frequent basis. However, EPA recommends that you take your refresher training no earlier…
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When do persons applying for certification as inspectors, risk assessors, or supervisors apply to EPA, before or after taking the 3rd party exam?
Answer: Persons applying for certification as inspectors, risk assessors, and/or supervisors must apply to EPA before taking the 3rd party certification exam. For more information about applying for certification as a lead-based paint abatement professional please refer to EPA’s Lead-based Paint Professionals page . Question Number: 23002-33448 Find a printable…
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When individuals apply for certification in the Federal program under 40 C.F.R. 745.226(a)(1)(i), how long will the certification last?
Answer : For individuals who have taken courses which included a course test and a hands-on skills assessment, the full certification period for individuals applying under 745.226(a)(1)(i) will run for three years from the date of issuance of certification by EPA. For individuals who have taken courses which included a…
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The definition of “soil sample” at 40 CFR §745.63 relies on certain American Society of Testing Materials (ASTM) standards. Did EPA intend to prevent the use of EPA and HUD standards for soil 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’s announcement of June 18, 2010 modify the Lead Renovation Repair and Painting Rule’s requirements that contractors use lead-safe work practices when working in pre-1978 housing or child-occupied facilities?
Answer: This announcement does not change the requirement that all contractors take steps to protect children and families from the dangers of lead poisoning by becoming certified and following the work practice standards and the associated recordkeeping requirements. As of April 22, 2010 all contractors have been required to be…
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How does the June 18, 2010 announcement impact renovators in states that have adopted their own RRP programs?
Answer: If you work in a state authorized by EPA to run their own renovation program, you should contact them for information on their certification requirements. If you work in a state where EPA administers the renovation program your firm needs to be certified by EPA. Please refer to the…
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Thousands of renovators are already trained and their firms are EPA certified. Will EPA enforce against renovators who did not receive their training certification before December 31, 2010?
It is most important that all contractors follow the RRP work practice standards. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before the enforcement of the firm certification and individual renovator requirements begins. Therefore, renovators who have not been able…
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Are landfills covered under Title III of SARA since they are covered by RCRA?
Yes, landfills are subject to certain Title III requirements. Subtitle A of Title III is intended to identify facilities which present a potential hazard for a chemical emergency and to provide a process for local emergency planning committees to engage with such facilities in determining the significance of the release…
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Are mobile boosters eligible for the transportation exemption?
An oil company owns many wells on an oil field. Each well is on its own plot of land. These plots are not adjacent or contiguous and, therefore, each well is its own facility. When operating these wells, it is sometimes necessary to inject air or gas into the well…
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Pipeline tanks and the transportation exemption in Title III
An oil corporation's pipeline facility contains three kinds of tanks. One type is a breakout tank used to receive and store hazardous liquids transported by a pipeline for reinjection and continued transportation by the corporation's pipeline. Another type is used to receive and store hazardous liquid for delivery to pipelines…
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What must I do to be recertified?
Answer: Prior to the expiration of your current certificate, you must take an accredited refresher training course, you must apply to EPA for recertification, and you must pay a recertification fee. Question Number: 23002-32442 Find a printable PDF copy of all frequent questions pertaining to lead .
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When do I apply for recertification?
Answer: You must be recertified by EPA before your current certification expires. EPA therefore recommends that you submit your application for recertification no later than 90 days before your current certification expires. Question Number: 23002-32445 Find a printable PDF copy of all frequent questions pertaining to lead .
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