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

• 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

• 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…

  • Last published: November 20, 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

• 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…

  • Last published: November 5, 2024

• 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…

  • Last published: November 5, 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

• Under the Lead Renovation, Repair and Painting (RRP) Rule, how should I dispose of contaminated water used in two-bucket mopping?

  EPA recommends contacting your local water treatment authority and asking about local requirements for handling and disposing of waste water. Question Number: 23002-20756 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 19, 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

• 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