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If a certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?
Answer: The renovation firm is the entity responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The certified renovator is responsible for preparing the records demonstrating that the renovation was…
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When testing a work area, does one lead test kit or paint chip sample suffice for any single component?
The certified renovator is only required to use one lead test kit or paint chip sample for each component, even if the surface of the component is extensive (e.g., a large wall). Question Number: 23002-23865 Find a printable PDF copy of all frequent questions pertaining to lead .
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Can a homeowner use an EPA-recognized lead test kit to check for lead-based paint?
Answer: A number of lead test kits are available for consumer purchase in most retail hardware stores; however, the Consumer Product Safety Commission (CPSC) states that consumers should exercise caution when using these lead test kits to evaluate consumer products for potential lead exposures. Find more information online . To…
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How can I obtain D-Lead® test kits?
The D-Lead® test kits are available for purchase from certain distributors and retail outlets. Locate a distributor or retailer online , email [email protected] or call 414-962-3006. Question Number: 23002-16390 Find a printable PDF copy of all frequent questions pertaining to lead .
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Is lead paint testing required under the Lead Renovation, Repair and Painting (RRP) Rule?
No. A firm can either assume lead-based paint is present and follow the requirements of the RRP Rule (which requires no testing), or test and if lead-based paint is found follow the requirements of the regulation. Question Number: 23002-32338 Find a printable PDF copy of all frequent questions pertaining to…
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Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?
Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the Lead Renovation, Repair, and Painting (RRP) Rule for a period of three years following completion of the renovation. The RRP Rule does not specify the format in which…
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What lead test kits are recognized by EPA?
Answer: EPA recognizes three lead test kits for use in complying with the negative response criterion of the RRP rule. They are the Luxfer Magtech LeadCheck TM kit (for use on ferrous metal, plaster, drywall and wood), the State of Massachusetts kit (for use on drywall, plaster), and the D-Lead®…
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Does EPA recognize the Luxfer Magtech LeadCheckTM test kit for use on red paint?
Yes. EPA recognizes this lead test kit for use on any color paint as long as the lead test kit is used in accordance with the manufacturer’s instructions. Note: 3M has sold the formulation and trademarks related to the 3M™ LeadCheck™ test kits to Luxfer Magtech. EPA recognizes the LeadCheck™…
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What changes did EPA finalize to the SPCC Rule in December 2006?
The revised rule modifies requirements for facilities with smaller oil storage capacity and specific types of oil-filled operating equipment. If a facility has 10,000 gallons or less in aggregate aboveground oil storage capacity and the facility meets the oil discharge history criteria, then an owner/operator of a facility may prepare…
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SPCC change in ownership
If there is a change in ownership at a facility, can the facility operate under the same SPCC Plan without the certification from a professional engineer (PE)? If no change in procedures has been made, it may still be feasible to operate under the existing SPCC Plan. The information in…
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Liability of oil retailers at SPCC regulated farm
If a farm is out of compliance of Spill Prevention, Control, and Countermeasure (SPCC) regulations and is checked by EPA and/or has a spill, is the retailer that filled the tank liable? No, EPA considers the oil tank owner responsible for lack of compliance.
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If a certified renovator using an EPA-recognized lead test kit or paint chip sampling determines that the components that will be affected by a renovation are free of lead-based paint, can a firm that does not have RRP certification do the actual renovation work? What record-keeping requirements would apply?
Where a certified renovator performs paint chip sampling or uses an EPA-recognized lead test kit following the lead test kit manufacturer’s instructions, tests each component affected by the renovation, and determines that the components are free of paint or other surface coatings that contain lead at regulated levels, the renovation…
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Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?
Yes. The Lead Renovation, Repair, and Painting (RRP) Rule does not specify the format in which these documents must be kept, but they must be available at the work site. Documents are not available if they cannot be viewed. Certified renovators must have with them at the work site copies…
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Is it true that the lead test kits that were recognized by EPA before September 1, 2010, are no longer recognized since that date?
No. The lead test kits that were recognized by EPA before September 1, 2010 did not automatically lose their recognition on September 1, 2010. As discussed in the 2008 Lead Renovation, Repair and Painting (RRP) Rule , prior to September 1, 2010, manufacturers seeking recognition of their lead test kit…
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I am an EPA-certified lead risk assessor. Can I use an EPA-recognized lead test kit when assessing whether or not a pre-1978 home contains lead-based paint for purposes of the RRP Rule?
Answer: Yes. In addition to a certified renovator, a person certified by EPA as a risk assessor or lead inspector may use an EPA-recognized lead test kit to determine that regulated lead-based paint is not present in a home. Such a report can also be used to confirm that the…
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