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Federal Facilities Complying with EPCRA 302, 304, 311, 312
Executive Order 13693 was the most recent, and current order that required federal facilities to comply with all aspects of the Emergency Planning and Community Right-to-Know Act. On May 17, 2018, the President issued E.O. 13834 , “Executive Order Regarding Efficient Federal Operations”, which, in part, revoked E.O. 13693. Are…
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Does an LEPC have to consist of one individual representative from each organization?
A Local Emergency Planning Committee (LEPC) must be representative of different groups and organizations, as described in Section 301(c). It states that, at a minimum, an LEPC must include "...representatives from each of the following groups or organizations: elected State and local officials; law enforcement; civil defense; firefighting; first aid…
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Liability of individuals as members of SERCs and LEPCs
Can individuals, as members of a state emergency response commission or a local emergency planning committee, be sued and/or be held liable for their commission's or committee's failure to fulfill its EPCRA requirements? Under Section 326, an individual may assert a federal cause of action against a state emergency response…
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How did EPA determine TPQs for EHSs?
How did EPA determine threshold planning quantities for extremely hazardous substances? The Agency assigned chemicals to threshold planning quantity (TPQ) categories based on an index that accounts for the toxicity and the potential of each chemical, in an accidental release, to become airborne. This approach does not give a measure…
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Differences between the risk management program and EPCRA
How do the Clean Air Act (CAA) risk management program requirements differ from the hazardous chemical reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA)? The hazardous chemical reporting requirements under EPCRA sections 311 and 312 ( 40 CFR Part 370 ) are separate and distinct from those…
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What does the Renovation, Repair, and Painting (RRP) Rule require?
Answer: The RRP Rule requires that renovators are trained in the use of lead-safe work practices, that renovators and firms be certified, that providers of renovation training be accredited, and that renovators follow specific work practice standards. Additional information on this rule can be found at https://www.epa.gov/lead . Question Number…
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Is it a violation of the Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified?
The Lead Renovation, Repair, and Painting (RRP) Rule does not impose requirements on homeowners. However, the hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered renovation. Question Number: 23002-19015 Find a printable PDF copy of all frequent questions pertaining to lead…
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Will a renovator working for a firm that has submitted a certification application to EPA but has not received its certification be allowed to work on pre-1978 properties assuming compliance with all other requirement of the RRP Rule?
No. Beginning April 22, 2010, no firm may perform, offer or claim to perform renovations covered by the RRP Rule without certification from EPA. Question Number: 23002-25193 Find a printable PDF copy of all frequent questions pertaining to lead .
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