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When repainting rental housing, if the landlord supplies the paint and materials, and the tenant does the labor without receiving money, credit toward rent, or other compensation, does the RRP Rule apply?
No. The Lead Renovation, Repair, and Painting (RRP) Rule only applies to renovations performed for compensation. Question Number: 23002-23856 Find a printable PDF copy of all frequent questions pertaining to lead .
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When renovating the exterior of a high-rise building, does the requirement to close and seal doors and windows within 20 feet of the renovation include closing those openings two-plus floors above the floor where work is to be performed?
Not necessarily. When establishing containment for an exterior renovation on a multi-story building, you must close all doors and windows within 20 feet of the renovation on the same floor as the renovation, and close all doors and windows on all floors below that are the same horizontal distance from…
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What changes in a renovation firm's status require an amendment of certification and how much will it cost?
Answer : In accordance with § 745.89(c), any change to the information reported to EPA in a firm's most recent certification application must be reported in an amended certification application. There is no fee associated with the submission of an amended certification. Question Number: 23002-21581 Find a printable PDF copy…
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Does the Renovation, Repair, and Painting (RRP) Rule prohibit the deconstruction and reuse of old building materials containing lead-based paint?
Answer: No. The RRP Rule does not prohibit a firm from extracting, salvaging or reusing building materials that contain lead-based paint. However, the requirements of the RRP Rule may apply to these activities if they (1) occur in target housing or a child-occupied facility, and (2) disturb more than six…
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What is a studio apartment?
A studio apartment is an apartment in which the living area is not separated from the sleeping area. Question Number: 23002-22148 Find a printable PDF copy of all frequent questions pertaining to lead .
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My firm performs renovations in large apartment complexes that often consist of several separate buildings. If a renovation is to be performed in a common area in one building, are we required to provide pre-renovation education to all tenants in all buildings?
When renovations are to be performed in common areas of multi-unit target housing, the RRP Rule requires that the firm notify in writing both the owner of the building and each “affected unit.” See 745.84(b)(1) and (2). Common areas are those portions of a property generally accessible to residents/users, and…
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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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Naturally Occurring Hydrocarbon Mixtures Exemption
Pursuant to the risk management program regulations under 40 CFR §68.115(b)(2)(iii), regulated substances in naturally occurring hydrocarbon mixtures prior to entry into a natural gas processing plant or a petroleum refining process unit do not need to be considered when determining whether more than a threshold quantity is present at…
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