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Displaying 106 - 120 of 253 results
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Is it permissible for a training provider to employ more than one training manager?
Answer : Yes. The Rule requires that a training provider employ a training manager that meets the qualifications in 40 CFR 745.225(c)(1). EPA does not interpret this to be a limitation on the permissible number of training managers. Therefore, a training provider may employ more than one training manager so…
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Are evacuations and sheltering-in-place considered for Program 1 eligibility?
A facility performed a worst-case release scenario and determined that there are no public receptors within the endpoints. There are several residences located just outside the endpoint. In reviewing the five year accident history, there were several releases of a regulated substance, in which the residences were notified by the…
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Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.”
Answer: “Minor repair and maintenance” is defined in 40 CFR 745.83 as activities that disrupt less than 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or…
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What RRP requirements apply to a comprehensive renovation project involving the removal and replacement of all interior painted surfaces from target housing or a child-occupied facility?
A project that involves the removal and replacement of all interior painted surfaces but leaves all exterior painted surfaces intact is considered a renovation for RRP purposes. Therefore, all requirements of the RRP Rule apply including, but not limited to, those for firm and renovator certification, containment, waste disposal, cleaning…
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Does the June 18, 2010, announcement mean that EPA will not enforce certification and training requirements until after October 1, 2010, for firms and December 31, 2010, for renovators?
Answer: EPA is not stopping its enforcement against any renovation firms and individual renovators who do not comply with requirements of work practice standards and associated recordkeeping requirements. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before enforcement of the…
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Can contractors submit their application to EPA before they complete required training, or must the application be submitted after the training is complete? Is proof of training required by the EPA in order for the contractor's application to be approved?
Answer: The firm certification process does not include the submission of renovator training credentials, so a firm can apply for certification before completing required training. As part of the application, the firm is required to certify it will comply with the requirements of the RRP Rule, including ensuring that all…
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My firm acts as a general contractor - we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the job site?
Answer: Not necessarily. All firms performing renovations, including general contractors, must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement by hiring another certified…
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Does the RRP Rule apply to demolishing and disposing of the following types of structures?
Question: Does the RRP Rule apply to demolishing and disposing of: An entire pre-1978 home or building? An entire, non-attached free-standing structure on the same property such as a garage, shed, or gazebo? An attached but segregated section of pre-1978 home or building such as a sunroom, addition, two-story porch…
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Does the minor maintenance exception mean that if I drill one-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule?
The exception is based on the area of paint disrupted, which in this example is based on the combined areas of the holes drilled in the wall. Question Number: 23002-15677 Find a printable PDF copy of all frequent questions pertaining to lead . Other Frequent Questions about the RRP Program…
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Are trainers authorized to use the EPA Lead-Safe Certified Logo?
Answer: Accredited training providers may use the logo on their site and marketing materials as long as it is used as a tool to guide renovators through the firm certification process (i.e., explain the difference between firm certification and individual training). Training providers may inform students that only certified firms…
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Are renovations in short-term lodgings, such as hotels and motels, time share properties, and homeless shelters, covered by the Lead Renovation, Repair and Painting (RRP) Rule?
Yes, if the property renovated is not a zero-bedroom dwelling. A zero-bedroom dwelling is a residential dwelling in which the living area is not separated from the sleeping area. The term includes efficiencies, studio apartments, dormitory housing, military barracks and rentals of individual rooms in residential dwellings. The short-term nature…
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I am the owner of my renovation firm, but I am not a certified renovator. May I be the "attesting individual" named on the RRP firm certification application?
Yes. The attesting individual need not be a certified renovator. Question Number: 23002-18047 Find a printable PDF copy of all frequent questions pertaining to lead .
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How is window repair or maintenance, as distinct from removal, treated under the RRP Rule? Would the rule apply to a job that replaced parts or components of a window, such as broken or failed glass, hardware, or balance systems, where some components might be painted, but the frame of the window would remain?
Answer: Replacing a pane of glass or fixing a broken window balancer is not a window replacement. However, this activity would be subject to the rule unless it meets the definition of minor repair and maintenance. To be considered minor repair and maintenance, the renovation must not disrupt more than…
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Does the RRP Rule apply to renovations that disturb ceramic tile where the glaze on the tile contains lead at regulated levels?
No. Ceramic tile glaze is neither a surface coating nor a painted surface. Therefore, renovations that disturb ceramic tile glaze are not subject to the RRP Rule. Question Number: 23002-15691 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does the RRP Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?
No. The RRP Rule applies to activities that result in the disturbance of painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15691 Find a printable PDF copy of all frequent questions pertaining to lead .
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