Search Frequent Questions

Displaying 1 - 15 of 18 results

• Determining frequency of coordination activities
  

  The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? Ultimate responsibility…

  • Last published: June 5, 2024

• Who Must Develop an Emergency Response Program?

  The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date…

  • Last published: September 30, 2024

• A home sustained flooding as a result of a hurricane. Once the flood water recedes, my firm must make the necessary renovations. How do the record keeping requirements apply to an emergency renovation? 

  Emergency renovations (other than interim controls performed in response to a child with an elevated blood lead level) are exempt from the training, certification, sign posting, waste handling and containment requirements of the Lead Renovation, Repair and Painting (RRP) Rule only to the extent necessary to respond to the emergency…

  • Last published: October 29, 2024

• Does the RRP rule apply to contractors working on homes damaged by a hurricane or other natural disaster?

  Damage from a major storm or other natural disaster could result in the need for emergency renovations. Certain requirements of the RRP Rule do not apply to emergency renovations, which are renovation activities that were not planned but result from a sudden, unexpected event that, if not immediately attended to…

  • Last published: November 14, 2024

• 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…

  • Last published: January 13, 2025

• If a renovator takes the refresher course early, would the new certification be valid for five years from the date of training, or five years from the date that the previous certification expires?

  Question : I’m a training provider and have been accredited for the renovator refresher course. If a renovator takes the refresher course early (i.e., before their previous certification has expired), would the new certification be valid for five years from the date of training, or five years from the date…

  • Last published: November 19, 2024

• I'm an accredited training provider. Can the final course assessment to be administered in an "open book" format?

  No. The training provider is responsible for maintaining the validity and integrity of the course test to ensure that it accurately evaluates the trainee’s knowledge and retention of the course topics. A course test administered in an open book format does not evaluate whether a student has sufficiently learned and…

  • Last published: November 19, 2024

• Remote coordination with local authorities
  

  The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). If a stationary source is in a remote location and in-person annual coordination is deemed impractical, can…

  • Last published: June 5, 2024

• Emergency Response Coordination Activities Effective Date

  The RMP Amendments finalized on January 13, 2017 included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because…

  • Last published: September 30, 2024

• 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…

  • Last published: November 14, 2024

• Are exercises required as a part of the emergency response program requirements under 40 CFR Part 68, Subpart E?

  Yes. At least once each calendar year, the owner or operator of a stationary source with any Program 2 or Program 3 process must conduct an exercise of the stationary source's emergency response notification mechanisms per 40 CFR 68.90(b)(3) or 68.95(a)(1)(i), as appropriate, before December 19, 2024, and annually thereafter…

  • Last published: March 12, 2024

• Types of Information Relevant for Response Planning

  The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency…

  • Last published: September 30, 2024

• How do I know if a child has an Elevated Blood Level (EBL) prior to my work if he or she hasn't had their blood lead tested recently?

  Answer: It is never the renovation firm’s responsibility to determine whether a child has an elevated blood lead (EBL) level. Question Number: 23002-16822 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 14, 2024

• If a student in a renovator training course is unable to read and understand English, may the exam be read to them in their native language?

  No. Separate course accreditations are required for each renovation course a training provider offers that is in a language other than English. Courses presented in a language other than English must use instructor manuals, exams, and other course materials in that language that have been reviewed by EPA as part…

  • Last published: November 19, 2024

• According to your guidelines emergency projects are exempt from some requirements to the extent necessary to respond to the emergency. Does this mean that my firm does not need to be certified and my company doesn't need a certified renovator?

  Question : My company only does emergency renovation work. According to your guidelines emergency projects are exempt from the warning sign, containment, waste handling, training, and certification requirements to the extent necessary to respond to the emergency. Emergency renovations are NOT exempt from the cleaning and cleaning verification requirements. Does…

  • Last published: November 19, 2024