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How often does a facility need to complete an oil spill response training under the FRP requirements?
Facilities subject to the Facility Response Plan (FRP) regulations in 40 CFR Part 112, Subpart D are required to develop a facility response training program to train those personnel involved in oil spill response activities (§112.21(b)). How often does a facility need to complete an oil spill response training under…
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What is a significant and substantial harm facility?
Some substantial harm facilities may meet the criteria for a significant and substantial harm facility. After you have prepared and submitted your FRP, the RA may determine that your facility has the potential, not just for substantial harm, but for significant and substantial harm. If the RA makes that determination…
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Will an Ozone Generator protect me and my family from COVID-19?
No, do not use ozone generators in occupied spaces. When used at concentrations that do not exceed public health standards, ozone applied to indoor air does not effectively remove viruses, bacteria, mold, or other biological pollutants. Visit the Centers for Disease Control and Prevention's website for best practices to protect…
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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…
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Can air cleaning devices that use bipolar ionization, including portable air cleaners and in-duct air cleaners used in HVAC systems, protect me from COVID-19?
Bipolar ionization (also called needlepoint bipolar ionization) is a technology that can be used in HVAC systems or portable air cleaners to generate positively and negatively charged particles. Provided manufacturers have data to demonstrate efficacy, manufacturers of these types of devices may market this technology to help remove viruses, including…
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Will running an evaporative cooler (sometimes known as a "swamp cooler") or whole-house fan help protect me and my family from COVID-19?
Both evaporative coolers (or "swamp coolers") and whole-house fans can help protect people indoors from airborne transmission of COVID-19 because they increase ventilation with outside air to cool indoor spaces. Evaporative coolers are used in dry climates. They use water to provide cooling and increase relative humidity indoors. When operating…
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Where can professionals who manage school, office, and commercial buildings get information on ventilation and filtration to respond to COVID-19?
Professionals who operate school, office, and commercial buildings should consult the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) guidance for information on ventilation and filtration to help reduce risks from the virus that causes COVID-19. In general, increasing ventilation and filtration is usually appropriate; however, due to the…
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PE certification for an FRP if an SPCC impracticability determination is made
If the owner or operator of a facility subject to the SPCC regulations determines that the installation of any of the specified secondary containment structures or equipment is not practicable and accordingly provides in the facility’s SPCC Plan an oil spill contingency plan following the provisions of 40 CFR Part…
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Will an air cleaner or air purifier help protect me and my family from COVID-19 in my home?
When used properly, air purifiers can help reduce airborne contaminants including viruses in a home or confined space. However, by itself, a portable air cleaner is not enough to protect people from COVID-19. When used along with other best practices recommended by the Centers for Disease Control and Prevention, operating…
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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…
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How can I increase ventilation at home to help protect my family from COVID-19?
Ensuring proper ventilation with outside air is a standard best practice for improving indoor air quality. However, by itself, increasing ventilation is not enough to protect people from COVID-19. When used along with other best practices recommended by the Centers for Disease Control and Prevention, increasing ventilation can be part…
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Elements to include in Facility Response Plan
What key elements should I include in my Facility Response Plan? As you prepare your FRP, be sure that your plan includes the following elements: Emergency Response Action Plan (an easily accessible stand-alone section of the overall plan) including the identity of a qualified individual with the authority to implement…
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What are the FRP recordkeeping requirements?
What FRP recordkeeping requirements must I satisfy? You must maintain the response plan at your facility, along with plan updates reflecting material changes. You must also keep a log of response training drills and exercises. Records of inspections of response equipment must be kept for five years. If you determine…
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Under FRP, what is the definition of a qualified individual?
The FRP regulations require facilities to prepare an emergency response action plan and identify a qualified individual that has full authority, including contracting authority, to implement removal actions (40 CFR §112.20(h)(i)). What is the definition of a qualified individual? The relevant statute, CWA 311(j)(5)(C)(ii) requires that the plan identify the…
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Can running the HVAC system in my home help protect me from COVID-19?
By itself, running your HVAC system is not enough to protect yourself and your family from COVID-19. However, when used along with other best practices recommended by the Centers for Disease Control and Prevention, operating the HVAC system can be part of a plan to protect yourself and your family…
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