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Displaying 16 - 30 of 38 results
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When renovating a common area in an apartment building, must my firm provide pre-renovation education to all tenants?
Yes. Firms performing renovations in common areas of multi-unit housing must comply with the information distribution requirements before beginning renovation activities. The firm must provide the owner of the common area being renovated (generally the building owner) with the "Renovate Right" pamphlet and obtain a written acknowledgement of receipt. The…
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I regularly perform renovations and repairs to common areas in a large apartment complex. Must I provide separate notice to the tenants for each one of these activities or is there any way to avoid such duplication?
Answer: EPA recognizes that neither residents nor owners/managers/renovators are well-served if duplicative notifications are frequently issued for similar renovation activities. There are several options owners/managers/renovators may use to most efficiently provide residents in both single-family and multifamily housing with the necessary information. (A) Informational Signs – Owners/managers/renovators may provide notice…
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What is a mobile refueler?
A mobile refueler is a bulk storage container onboard a vehicle or being towed that is designed or used solely to store and transport fuel for transfer into or from an aircraft, motor vehicle, locomotive, vessel, ground service equipment, or other oil storage container. Mobile refuelers may be found at…
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Are generator sets considered oil-filled operational equipment?
No. Generator sets (gen sets) are a combination of oil-filled operational equipment and a bulk storage container. Lubrication systems on gen sets may be oil-filled operational equipment, but bulk storage tanks providing fuel for the generator typically are not oil-filled operational equipment.
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SPCC Rule regulated oil types
What types of oil does the Spill Prevention, Control, and Countermeasure (SPCC) Rule address? The term oil means oil of any kind or in any form, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of…
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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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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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What types of oil does the SPCC Rule address?
The term oil means oil of any kind or in any form, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits…
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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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If a renovation is to be performed on a private balcony of a single unit in a multi-unit target housing building, does that activity trigger the common area notification requirements?
A determination of whether the balcony renovation falls within a common area depends upon the scope of the renovation activity. A common area is a portion of a building that is generally accessible to all residents/users. Thus, if the work area established to contain dust and debris from the renovation…
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Is an electronic version of the lead information pamphlet sent to the customer via e-mail an acceptable means of distributing the information?
The distribution of the lead information pamphlet (40 CFR § 745.83) via e-mail is an acceptable means of distributing the pamphlet as long as the requirements of the Electronic Signatures in Global and National Commerce Act ("Act") (15 U.S.C. § 7001 et seq.) are met. The Act requires that the…
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What are the pre-renovation education requirements for a vacant apartment?
Firms performing renovations must provide pre-renovation education to the owner of the unit and to an adult occupant. If the unit is not occupied, providing pre-renovation education to the owner of the unit is sufficient. EPA has prepared a document with additional information . Question Number: 23002-21374 Find a printable…
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Does a renovator need to attempt personal delivery of the lead information pamphlet to a tenant more than one time before utilizing the “self-certification of pamphlet delivery” option?
Answer: Personal delivery of the lead information pamphlet is preferable, wherever possible, because EPA believes that tenants will be more likely to read the information if it is handed directly to them. It also affords tenants an opportunity to raise concerns and ask questions about the renovation. EPA recognizes, however…
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The RRP Rule requires delivery of the “Renovate Right” pamphlet to the owner and occupants of target housing. My firm was hired to perform a renovation in a pre-1978 apartment building. Is delivery of the pamphlet to the property manager sufficient for purposes of delivery to the owner of the building?
Answer: Yes. Property managers are acting in the capacity of agents for the building owners. For this reason, a property manager may receive, and acknowledge receipt of, the lead hazard pamphlet on behalf of the owner. In situations where property managers or their employees are performing the renovations themselves, they…
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