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Does the Renovation, Repair, and Painting (RRP) Rule require a certified state lead inspector or risk assessor, who does not do renovation work, to become a certified renovation firm in order to take dust wipe samples?
Answer : No. A certified inspector or risk assessor may make determinations regarding the presence of leadbased paint at a renovation site without becoming certified as a renovation firm. Question Number: 23002-15697 Find a printable PDF copy of all frequent questions pertaining to lead .
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Do all renovation course instructors need to be approved as principal instructors? For example, to reach a 6:1 student-to-instructor ratio with 18 people in the class, may we have one principal instructor who teaches the entire lecture and is assisted by two additional hands-on instructors (who are not approved as principal instructors)?
Answer: Every accredited training program must employ a qualified training manager, and it is the job of the training manager to designate a qualified principal instructor for each course. The principal instructor is responsible for the organization of the course and oversees the teaching of all course material. The training…
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How do RRP requirements apply to pressure washing? What containment and other preparation are required?
Pressure washing is not a prohibited practice under the Lead Renovation, Repair, and Painting (RRP) Rule . Pressure washing is subject to the same containment requirements as other permissible work practices. Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in…
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How does a firm or renovator document or confirm the age of the structure? Is a signed statement by the occupant sufficient? Can publicly available information such as tax records, etc. be sufficient?
Renovation firms are responsible for determining the age of the property. The property owner is likely to be a good source of information on the age of a home or other building, but the firm may not rely on the statement of the property owner as to the construction date…
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Does the RRP Rule apply to removing a roof that is not painted?
The RRP Rule applies to work that disturbs painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15689 Find a printable PDF copy of all frequent questions pertaining to lead .
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I am an owner/agent for an apartment community built prior to 1978. In 2004, testing of a random sample of units were negative for lead paint but positive for lead dust. With the positive lead dust result, are we required to comply with the RRP Rule?
No. As long as the determination that the units are free of lead-based paint was made by an inspector or risk assessor certified by EPA or by an authorized State or Tribal program, renovations in the building are not covered by the Lead Renovation, Repair, and Painting (RRP) Rule…
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How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for example, to church groups who, as part of their missionary work, are making improvements for low-income residents?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to renovations performed for compensation. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies…
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I am a contractor a couple years from retirement and I am closing down my business. I do not plan to become certified under the RRP Rule. My understanding is that I can continue working on homes built after 1978?
The Lead Renovation, Repair, and Painting (RRP) Rule does not apply to renovations in housing built in 1978 or later. Question Number: 23002-17978 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
Answer: The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share the responsibility for retaining and…
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If a firm does business in several states, must they become certified in all states in which they manage a target property or is this requirement satisfied by certifying the firm in the state in which they are headquartered?
The RRP Rule applies in states and tribal areas that are not operating EPA-authorized programs. A firm with Federal certification under the RRP Rule may perform, offer, or claim to perform renovations in any of these states. In states and tribal areas with EPA-authorized programs, check with the state or…
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If a property is tested by a certified renovator, inspector, or risk assessor and found to be free of lead-based paint, does any testing need to be done again if work is done on the property several years later?
Where a certified renovator uses an EPA-recognized lead test kit or performs paint chip sampling to determine that a component is free of lead-based paint, or a lead-based paint free determination is made by a certified inspector or risk assessor, firms performing renovations on the same components may rely on…
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I understand that the RRP rule does not apply to dormitories. Does the rule apply to a unit of student housing made up of two bedrooms, a living room, and kitchen?
Yes. While the RRP rule does not apply to zero-bedroom housing, the type of housing described is not zero-bedroom housing. Zero-bedroom housing means a residential dwelling in which the living area is not separated from the sleeping area. Examples include efficiencies, studio apartments, and dormitory housing. In the example given…
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I operate a renovation firm and I have heard that my state will adopt its own lead Renovation, Repair and Painting program. Do I have to also be certified by EPA?
Answer: If you work in a state authorized by EPA to run their own renovation program, you should contact them for information on their certification requirements. If you work in a state where EPA administers the renovation program your firm needs to be certified by EPA. Please refer to the…
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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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If my firm already has abatement certification, is separate RRP certification necessary?
Lead Renovation, Repair, and Painting (RRP) firm certification is not required to perform lead abatements. However, if your firm performs, offers, or claims to perform renovations as well as abatements, after April 22, 2010 it must be a certified renovation firm. Question Number: 23002-18528 Find a printable PDF copy of…
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