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Are facilities that have received ISO 14001 certification exempt from audits?
If we have been audited by a qualified third party, for ISO 14001 certification or for other programs, are we exempt from audits? No. However, you may want to inform your implementing agency that you have gained such certification and indicate whether the third party reviewed Part 68 compliance as…
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Will risk management plan (RMP) submissions be subject to audits?
Will risk management plan (RMP) submissions be subject to audits? If so, who will conduct the audits? Yes. According to 40 CFR §68.220(a), the implementing agency will periodically audit RMPs in order to review their adequacy, and may require revisions of RMPs as necessary to ensure compliance. The implementing agency…
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Applicable requirements for Title V air permits
Under the CAA, air permitting authorities must ensure that sources are in compliance with applicable requirements to issue a permit. Do the CAA §112(r) provisions constitute applicable requirements for Title V air permits? Yes. Section 112(r) is an applicable requirement for CAA Title V air permits under 40 CFR Parts…
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Comprehensiveness and format of a management system
What is a management system (40 CFR §68.15(a))? How comprehensive must it be? Is there a standard format? The management system required under Subpart A of 40 CFR Part 68 is essentially a system defined by facility managers for integrating the implementation of the risk management program elements and assigning…
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Consolidated List of Chemicals Subject to EPA Regulatory Programs
EPA implements a number of regulatory programs that use specific chemical lists as part of the process to determine reporting applicability. Is there a consolidated list of chemicals that are subject to EPA programs? The Consolidated List of Chemicals subject to the Emergency Planning and Community Right-To-Know Act (EPCRA), Comprehensive…
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How to deregister facility from risk management program
How do I deregister my facility from the risk management program? If a facility is no longer subject to the risk management program, the facility owner or operator must deregister within six months (40 CFR §68.190(c)). To deregister, you should submit a letter to the RMP Reporting Center within six…
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Is there an EPA enforcement policy for violators of CAA §112 and the risk management program rule?
Yes, EPA has issued a Final Combined Enforcement Policy for section §112(r) Risk Management Program .
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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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What is the purpose of the Renovation, Repair, and Painting (RRP) Rule?
The purpose of the Renovation, Repair and Painting (RRP) Rule is to minimize exposure from lead-based paint dust during renovation, repair, or painting activities. This is a key effort in reducing the prevalence of childhood lead poisoning, particularly lead poisoning caused by housing contaminated by renovation activities. This will also…
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I have hired a firm to renovate my home, but now I am concerned about whether the firm is a lead-safe certified firm. How can I find out?
Answer: EPA has a searchable database to help you locate lead-safe certified firms near you at: https://cdxapps.epa.gov/ocspp-oppt-lead/firm-location-search . It is possible that your firm is not yet listed on EPA's web site, but is certified. If you do not find your firm on EPA's web site, you should call EPA's…
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Does the Renovation, Repair, and Painting (RRP) Rule apply to states and local governments?
Answer: The RRP Rule requires that renovators are trained in the use of lead safe work practices, that renovators and firms be certified, that providers of renovation training be accredited, and that renovators follow specific work practice standards. After April 22, 2010 contractors (including renovation, repair and painting workers, plumbers…
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Can non-certified workers transport debris off site under the RRP Rule if they have had documented on-the-job training in this activity by the certified renovator?
Answer: Yes. The RRP Rule requires the certified renovator to regularly direct the work being performed by other individuals to ensure that the work practices are being followed, including ensuring that dust or debris does not spread beyond the work site. The certified renovator is responsible for providing training to…
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Are sleeping areas in buildings built before 1978, such as those in fire and police stations, considered target housing?
Firehouses and police stations are not target housing. Therefore, places of temporary rest for employees in these buildings, such as sleeping rooms, are not subject to the Lead Renovation, Repair, and Painting (RRP) Rule . Question Number: 23002-33291 Find a printable PDF copy of all frequent questions pertaining to lead…
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I am a firm and there are no training providers offering classes near me. What do I do?
Answer: More than 340 EPA-accredited training providers have indicated to EPA that they are willing to travel to offer training classes. You can find a list of training providers, including those who are willing to travel, by using EPA's search tool at https://cdxapps.epa.gov/ocspp-oppt-lead/training-search . Question Number: 23002-17981 Find a printable…
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