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Does EPA’s announcement of June 18, 2010 modify the Lead Renovation Repair and Painting Rule’s requirements that contractors use lead-safe work practices when working in pre-1978 housing or child-occupied facilities?
Answer: This announcement does not change the requirement that all contractors take steps to protect children and families from the dangers of lead poisoning by becoming certified and following the work practice standards and the associated recordkeeping requirements. As of April 22, 2010 all contractors have been required to be…
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How does the June 18, 2010 announcement impact renovators in states that have adopted their own RRP programs?
Answer: If you work in a state authorized by EPA to run their own renovation program, you should contact them for information on their certification requirements. If you work in a state where EPA administers the renovation program your firm needs to be certified by EPA. Please refer to the…
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Thousands of renovators are already trained and their firms are EPA certified. Will EPA enforce against renovators who did not receive their training certification before December 31, 2010?
It is most important that all contractors follow the RRP work practice standards. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before the enforcement of the firm certification and individual renovator requirements begins. Therefore, renovators who have not been able…
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Who is responsible for controlling dust and debris from renovation waste once the waste container or truck used to transport the waste leaves the renovation site?
When a renovation firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris. The Lead Renovation, Repair and Painting (RRP) Rule does not address the responsibilities of other entities. EPA recommends consulting with state and local waste disposal authorities to learn…
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For purposes of cleaning the work area following a renovation, is the interior floor of a garage considered interior or exterior space?
In general, the interior floor of a garage is considered an interior space for purposes of post-renovation cleanup. EPA recognizes the fact that it may occasionally be impossible for firms to meet all of the cleaning and verification requirements under the Rule for garage floors such as those that are…
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If a renovator uses the required practices to remove containment and clean a work area, then performs successful cleaning verification, can the project then be done using uncertified workers and without work practices required by the RRP Rule?
Yes, as long as the balance of the project can be completed without disturbing a painted surface. Question Number: 23002-18385 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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Does the June 18, 2010, announcement mean that EPA will not enforce certification and training requirements until after October 1, 2010, for firms and December 31, 2010, for renovators?
Answer: EPA is not stopping its enforcement against any renovation firms and individual renovators who do not comply with requirements of work practice standards and associated recordkeeping requirements. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before enforcement of the…
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My firm is replacing windows on a pre-1978 home. The homeowner already scraped and repainted their house but did not follow lead-safe work practices, leaving paint chips scattered throughout the landscaping. How best should I proceed?
A firm working on a property that is already contaminated with paint chips, dust, debris and residue must proceed by containing the work area for the renovation, and complying with all cleaning requirements under the Lead Renovation, Repair and Painting (RRP) Rule for that work area. Paint chips, dust, debris…
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Under the RRP Rule, do paint chips and debris need to be removed from protective sheeting even if such chips and debris can be effectively contained by the sheeting or the sealed container the sheeting is contained in for disposal?
Yes. After the renovation has been completed, the firm must clean the work area until no dust, debris, or residue remains. The first cleaning step required by the Lead Renovation, Repair, and Painting (RRP) Rule is to collect all paint chips and debris and, without dispersing any of it, seal…
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When waste from renovations has been removed from the work area and placed in on-site storage, may the waste be stored in a covered waste container or must it all be bagged for disposal?
Properly implemented, either option can meet the requirements of the Lead Renovation, Repair and Painting (RRP) Rule . At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind…
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PE certifying a technical amendment
Except as provided in 40 CFR §112.6 for qualified facilities, a Professional Engineer (PE) must certify all technical amendments to an existing SPCC Plan (§112.5(c)). When certifying a technical change to an existing SPCC Plan, does the PE have to inspect and certify the entire Plan or only the amended…
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Who would be liable for the fine if a state or local government that was not a certified firm hired a contractor that was not certified?
Answer: The hired firm would be in violation of the Renovation, Repair, and Painting Rule if it was uncertified and performing a covered renovation. Question Number: 23002-24814 Find a printable PDF copy of all frequent questions pertaining to lead .
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