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Displaying 1 - 15 of 211 results
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If an Asbestos Hazard Emergency Response Act (AHERA) accredited-training course is taught by someone other than instructors certified by the state or the Environmental Protection Agency (EPA), can an approved contractor/instructor sign certificates?
No. An EPA Asbestos Hazard Emergency Response Act (AHERA) accredited training course must be taught by EPA/state approved instructors and only those approved instructors may issue AHERA approved training course certificates. Other Frequent Questions about Asbestos Learn About Asbestos Asbestos and School Buildings Information for Owners and Managers of Buildings…
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Is there a formal requirement that an Asbestos Model Accreditation Plan (MAP) asbestos training course must have a training manual?
Accredited trainers are not required to have a formal training manual, per se. According to the Asbestos Model Accreditation Plan (MAP), at Unit III, (A)(3), (A)(4)(d) and (A)(5) of appendix C to 40 CFR part 763, subpart E, a trainer’s application for course approval must include the course curriculum, a…
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Why are industries exempt under OSHA's PSM subject to RMP?
The Program 3 prevention program requirements under 40 CFR Part 68 are almost identical to the requirements of OSHA's process safety management (PSM) standard. OSHA exempts certain industries from the PSM standard. Why does EPA not exempt those same industries from the CAA §112(r) risk management program requirements? EPA and…
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What if the quantity in the process fluctuates?
What if the quantity in the process fluctuates? I may not have a threshold quantity now, but I will intermittently exceed the threshold quantity. You do not need to comply with the rule and file an RMP unless you have more than threshold quantity in a process; however, once you…
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What are the requirements under the Asbestos Hazard Emergency Response Act (AHERA) for refresher training for a person who wants to "step down" his/her certification from contractor/supervisor status to worker status?
If such a person takes contractor/supervisor refresher courses on an annual basis, that person may perform in both the contractor/supervisor and worker roles. If, however, the person chooses only to take annual worker refresher courses, that person may continue to act in the role of an accredited worker but loses…
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What is the applicability of Federal asbestos inspector accreditation requirements under the Asbestos Hazard Emergency Response Act (AHERA) to real estate appraisers?
Real estate appraisers may not assess the suspected presence, location, or condition of asbestos in a school building or a public and commercial building during an appraisal unless they are accredited pursuant to the Toxic Substances Control Act (TSCA) and the Asbestos Model Accreditation Plan (MAP), as conducting an examination…
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When would a conflict of interest exist among Asbestos Model Accreditation Plan (MAP)-accredited personnel?
A conflict of interest with respect to Asbestos Model Accreditation Plan (MAP)-accredited personnel would exist if, for example, the management planner and abatement contractor worked for the same firm. The planner might recommend to the LEA more expensive response actions than are necessary in the management plan. Other Frequent Questions…
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Process identification and distance between vessels
How far apart do separate vessels have to be to be considered different processes? There is no hard and fast rule for how great this distance should be before you do not need to consider the vessels as part of one process. Two vessels at opposite ends of a large…
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What does "same industrial group" mean?
Operations at a site that belong to the same three-digit North American Industry Classification System (NAICS) code prefix (which has replaced the old SIC codes) belong to the “same industrial group. In addition, where one or more operations at the site serve primarily as support facilities for the main operation…
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Updating RMP if EPA lists a new substance
What if EPA lists a new substance? You will have three years from the date on which the new listing is effective to come into compliance for any process that is covered because EPA has listed a new substance.
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Should tank capacity be considered when determining thresholds?
When determining whether a threshold amount of a regulated substance is present in a process (e.g., a tank), must the owner or operator of a stationary source consider the total capacity of the process, or the actual amount of regulated substance contained in the process? The threshold determination is based…
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The training requirements specified in 40 CFR part 763 appear to apply to projects (excluding small-scale, short-duration projects) involving interior building components. Specifically, is roofing work and other exterior work covered?
Worker training requirements specified in 40 CFR part 763, including those for accreditation under the Asbestos Model Accreditation Plan (MAP), apply to interior building projects done in schools and public and commercial buildings. Additionally, the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), Occupational Safety and Health Administration (OSHA)…
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Is it required that the professional engineer conducting the engineering review must be licensed in the state in which the renewable fuel facility is located?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The licensed professional engineer should comply with the state laws where the renewable fuel facility is located to determine whether or not their license allows them to conduct business in that state.
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I have not seen a reference to the EPA CDX system. Is the CDX system already established or can we submit reports in our choice of electronic formats?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The Central Data Exchange (CDX) is an established portal through which electronic data are submitted. All registered parties will have to first register with CDX in order to receive a CDX registration number. More information may be found…
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May I generate RINs that I produced and sold for non-road use in the past so that I can reinstate those RINs under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.1426(c)(2) provides that RINs are assigned to a volume of renewable fuel when ownership of the RIN is transferred along with ownership of the volume of renewable fuel. A comparable provision appear in the RFS1 regulations, at…
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