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Displaying 16 - 30 of 38 results
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Plastic can be a slip hazard in some jobs, such as handling granite counter tops. This creates a more immediate safety concern than protecting the floor from dust. Can't I just clean the floor at the end of the job?
Answer: No. For interior renovations, before beginning the renovation the renovation firm must cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area six feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever…
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My firm is replacing windows on the second floor of a home. The windows are built into a bay that projects out from a steeply pitched slate roof. Does the RRP Rule require me to install plastic on the roof under the windows?
My firm is replacing windows on the second floor of a 90-year-old home. The windows are built into a bay that projects out from a steeply pitched slate roof. When setting up exterior containment for this job, does the RRP Rule require me to install plastic on the roof under…
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Under the Renovation, Repair, and Painting (RRP) Rule, in exterior containment if a large tree or shrub is within the work area can the plastic be placed around the base and would the plant, however large, also need to be covered?
Answer: The Lead Renovation, Repair, and Painting (RRP) Rule does not specifically address containment of trees or shrubs, but if dust, debris, or residue remains in the tree or shrub at the conclusion of the job, the site will not pass visual inspection. The work practices for exterior projects are…
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What is your recommendation if work under the Lead Renovation, Repair and Painting (RRP) Rule has started and it begins to rain? What do we do with the water that is on the plastic in the containment area?
Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in the waste water) leaves the work area while the renovation is being performed. In addition, the firm must maintain the integrity of the containment by ensuring that any plastic or other…
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When replacing an unpainted roof, sometimes sections of paint-covered lumber under the roof need to be removed. If damaged lumber is removed from only certain sections of the roof, does only this area need to be contained while we fix the lumber?
Yes. The renovation firm is responsible for containing the work area so that no dust or debris resulting from the disturbance of a painted surface leaves the work area while the renovation is being performed. Containment is not required for portions of the renovation outside this area that do not…
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Five-Year Accident History for Non-Gas Releases
Pursuant to 40 CFR §68.42(a), the owner or operator of a stationary source subject to the risk management program regulations must document significant accidental releases of regulated substances from a covered process in the five years prior to the submission of an initial or updated risk management plan (RMP). For…
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What level of off-site property damage triggers five-year accident history reporting?
What level of off-site property damage triggers reporting? Any level of known offsite property damage triggers inclusion of the accident in the five-year accident history. You are not required to conduct a survey to determine if such damage occurred, but if you know, or could reasonably be expected to know…
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Do I need to report releases for processes that have shut down?
A process involving a regulated substance had an accidental release with off-site consequences two years ago. The process has been shut down. Do I have to report anyway? No. The release does not have to be reported in your accident history. Your Risk Management Plan only needs to address operating…
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Are releases under prior ownership included in the five-year accident history?
Documentation of a five-year accident history is required as part of the hazard assessment under 40 CFR Section 68.42. Should a stationary source subject to the risk management program regulations report as part of the five-year accident history any accidents that occurred when the facility was under prior ownership? Yes…
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What constitutes "significant property damage on site?"
Under the hazard assessment requirements at 40 CFR Part 68, Subpart B, the owner or operator of a covered stationary source must document a five-year accident history that includes all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths…
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Is the off-site death of livestock considered environmental damage?
Under the hazard assessment requirements of 40 CFR Part 68, Subpart B, an owner or operator must document a five-year accident history including all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property…
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If I paint without disturbing the surface of the existing paint, can I use a tarp instead of 6 mil plastic?
Yes. Projects that do not disturb a painted surface are not subject to the RRP Rule. Question Number: 23002-18508 Find a printable PDF copy of all frequent questions pertaining to lead .
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If I mist and vacuum with a High Efficiency Particulate Air (HEPA) vacuum the plastic sheeting used by my firm for interior containment, can I move and re-use plastic sheeting on the same day and job?
No. The Lead Renovation, Repair and Painting Rule does not contemplate a permissible method of moving and re-using plastic sheeting used for interior containment. Question Number: 23002-18500 Find a printable PDF copy of all frequent questions pertaining to lead .
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Differences in accident history between Program 1 eligibility and the hazard assessment
Program 1 eligibility under 40 CFR §68.10(b) is contingent upon the process not having had an accidental release of a regulated substance that led to offsite death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk management plan submission. Additionally, as part…
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Program 1 Five-year Accident History and Hazard Assessment Differences
Pursuant to the risk management program regulations under 40 CFR §68.10(b), Program 1 eligibility requires that the process has not had an accidental release of a regulated substance that led to off-site death, injury, or response and restoration activities at an environmental receptor within five years prior to the risk…
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