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Displaying 151 - 165 of 253 results
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When a home or an apartment unit is repainted in preparation for a new tenant, is the painting activity always considered a “renovation” for purposes of the pre-renovation education requirements even if no surface preparation activity is performed prior to painting?
Answer: No. The primary determinant of whether a given activity constitutes a “renovation” under the RRP Rule is whether that activity disturbs a painted surface. The practice of recoating painted surfaces in preparation for new tenants would not constitute “renovation” unless accompanied by activities that disturb the painted surface and…
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Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed of under the Lead Renovation, Repair and Painting (RRP) Rule?
The RRP Rule requires the renovation firm to use precautions to ensure that all personnel, tools, and other items are free of dust and debris before leaving the work area. Workers with contaminated clothing can take that contamination home to their own children, and taking contaminated equipment to another jobsite…
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DOE provides weatherization grants to states, which in turn provide grants to non-profit sub-grantees. These sub-grantees fall into one of three categories: 1. The sub-grantee uses its own employees to perform all the weatherization services in the home, 2. The sub-grantee uses a combination of its own employees and contractors to perform weatherization services, or 3. The sub-grantee has no employees that perform weatherization services; instead, every service is performed by a hired contractor. Must these sub-grantees be RRP-certified firms?
Answer : Beginning April 22, 2010, no firm may perform, offer, or claim to perform renovations covered by the RRP Rule without certification from EPA. Sub-grantees that use their own employees to perform any or all of the weatherization services in the home, such as the sub-grantees in the first…
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When waste from renovations has been removed from the work area and placed in on-site storage, may the waste be stored in a covered waste container or must it all be bagged for disposal?
Properly implemented, either option can meet the requirements of the Lead Renovation, Repair and Painting (RRP) Rule . At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind…
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When testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized lead test kit, must I test every component affected by the renovation?
Answer: Yes. Because certified renovator training does not cover sampling protocols, certified renovators using EPA-recognized lead test kits or performing paint chip sampling to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does…
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Does the RRP Rule apply to renovations in mobile homes?
Answer: Yes, if the mobile home meets the definition of target housing. “Target housing” is any housing constructed before 1978, except housing for the elderly or persons with disabilities or any 0-bedroom dwelling (unless any child who is less than six years of age resides or is expected to reside…
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What do you need to do to become a certified firm?
Answer: Firm certification is easy and straightforward – you only submit an application and fee to EPA online through EPA’s CDX system, the EPA’s electronic reporting system: https://cdx.epa.gov . Certified firms will be able to advertise that they are certified by EPA under the RRP program, and will also be…
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What is a child-occupied facility?
Answer: A child-occupied facility is a building, or a portion of a building, constructed prior to 1978, visited regularly by the same child, under six years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least three…
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Program 3 applicability and NAICS code determination
A covered process that is ineligible for Program 1 will be subject to Program 3 requirements if the process is in one of ten specified North American Industrial Classification System (NAICS) codes, or is subject to the OSHA Process Safety Management (PSM) standard (40 CFR Part 68.10(d)). When determining Program…
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Can a newly-constructed process that has no accident history qualify for Program 1 status?
The eligibility criteria for Program 1 status under 40 CFR Part 68 include a requirement that the process must not have had an accidental release resulting in serious offsite consequences for the past five years (40 CFR §68.10(b)(1)). Can a newly-constructed process that has no accident history qualify for Program…
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Are processes subject to delegated state OSHA programs classified as program level 3?
If my state administers the OSHA program under a delegation from the federal OSHA, does that mean that my processes that are subject to OSHA PSM under the state rules are in Program 3? Yes, as long as the process does not qualify for Program 1. Any process subject to…
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Are all covered processes subject to identical risk management program requirements?
The risk management program regulations in 40 CFR Part 68 are applicable to owners or operators of stationary sources at which more than a threshold quantity of a regulated substance is present in a process (40 CFR Section 68.10(a)). Are all covered processes subject to identical risk management program requirements…
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Certifying RMP process at higher program level
If a process qualifies as Program Level 1, can a facility designate it as a Program Level 2 or 3 in their Risk Management Plan? No. The owner or operator of a stationary source with a process eligible for Program 1 must certify their Program 1 designation in their Risk…
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How should lead-containing wastes from RRP renovations be handled and disposed?
While at the work site, wastes must be collected at the conclusion of each work day and at the conclusion of the renovation and stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…
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How can a firm comply with the pre-renovation education requirements if the owner desires that the renovation begin immediately?
Answer: If the renovation is taking place in an owner-occupied dwelling unit, a firm must simply provide the owner with a copy of the pamphlet, and either (1) obtain, from the owner, a written acknowledgement that the owner has received the pamphlet, or (2) obtain a certificate of mailing at…
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