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If an Asbestos Hazard Emergency Response Act (AHERA) accredited-training course is taught by someone other than instructors certified by the state or the Environmental Protection Agency (EPA), can an approved contractor/instructor sign certificates?
No. An EPA Asbestos Hazard Emergency Response Act (AHERA) accredited training course must be taught by EPA/state approved instructors and only those approved instructors may issue AHERA approved training course certificates. Other Frequent Questions about Asbestos Learn About Asbestos Asbestos and School Buildings Information for Owners and Managers of Buildings…
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Is there a formal requirement that an Asbestos Model Accreditation Plan (MAP) asbestos training course must have a training manual?
Accredited trainers are not required to have a formal training manual, per se. According to the Asbestos Model Accreditation Plan (MAP), at Unit III, (A)(3), (A)(4)(d) and (A)(5) of appendix C to 40 CFR part 763, subpart E, a trainer’s application for course approval must include the course curriculum, a…
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What are the requirements under the Asbestos Hazard Emergency Response Act (AHERA) for refresher training for a person who wants to "step down" his/her certification from contractor/supervisor status to worker status?
If such a person takes contractor/supervisor refresher courses on an annual basis, that person may perform in both the contractor/supervisor and worker roles. If, however, the person chooses only to take annual worker refresher courses, that person may continue to act in the role of an accredited worker but loses…
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What is the applicability of Federal asbestos inspector accreditation requirements under the Asbestos Hazard Emergency Response Act (AHERA) to real estate appraisers?
Real estate appraisers may not assess the suspected presence, location, or condition of asbestos in a school building or a public and commercial building during an appraisal unless they are accredited pursuant to the Toxic Substances Control Act (TSCA) and the Asbestos Model Accreditation Plan (MAP), as conducting an examination…
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When would a conflict of interest exist among Asbestos Model Accreditation Plan (MAP)-accredited personnel?
A conflict of interest with respect to Asbestos Model Accreditation Plan (MAP)-accredited personnel would exist if, for example, the management planner and abatement contractor worked for the same firm. The planner might recommend to the LEA more expensive response actions than are necessary in the management plan. Other Frequent Questions…
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The training requirements specified in 40 CFR part 763 appear to apply to projects (excluding small-scale, short-duration projects) involving interior building components. Specifically, is roofing work and other exterior work covered?
Worker training requirements specified in 40 CFR part 763, including those for accreditation under the Asbestos Model Accreditation Plan (MAP), apply to interior building projects done in schools and public and commercial buildings. Additionally, the asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP), Occupational Safety and Health Administration (OSHA)…
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If RFG is shipped from a refinery to a terminal through a proprietary pipeline system, may the pipeline rely on the refinery and terminal test results to satisfy the quality assurance defense element?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In a case where EPA documents a downstream standard violation at a proprietary terminal that is served only by a proprietary pipeline that receives gasoline only from a proprietary refinery, the company that owns the refinery, pipeline and…
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If, due to piping constraints, a refiner must put a purchased or inter-refinery transferred batch of finished gasoline through the refinery blendstock system, but does so without the batch losing integrity, must the refiner include the batch in his compli
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. As per § 80.65(i) of the regulations, any refiner, importer, or oxygenate blender shall exclude from all compliance calculations, the volume and properties of any RFG that is produced at another refinery or oxygenate blending facility, or…
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In areas where an oxy fuels program is in effect, how do these requirements coincide with RFG requirements? In areas where there is an overlap, are any regulatory changes necessary by the state?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In areas that are covered by both a state's winter oxy fuels and the federal RFG programs, the fuel must comply with both program requirements. Therefore, the more stringent 2.7 wt% minimum requirement of the winter oxy fuels…
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If foreign product is acquired by an importer through an exchange agreement instead of a sale, does it change identification of the importer for RFG reporting purposes?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The person who is the importer of record for Customs purposes should be the importer for RFG purposes, and this is usually the gasoline owner, regardless of how that ownership was acquired.(7/1/94) This question and answer was…
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If terminals utilize the services of outside laboratories for periodic sampling and testing, how can the terminal limit exposure to liability in the event non-complying product from the tested tank(s) leaves the terminal during the three or four days befo
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A terminal-distributor's release of RFG that does not meet applicable standards would constitute a violation of § 80.78(a)(1) for which the distributor would be liable, and it would not be a defense if the violation was caused by…
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If a pipeline must be classified as a refiner, how would that be handled administratively by EPA? Since pipelines don't own the product, would pipeline have to become buyers and sellers for regulatory purposes?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners must be registered with EPA. The pipeline need not be an owner of the gasoline to be a refiner.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July…
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What are the sampling and testing requirements for terminal blenders (barges, trucks and pipelines)?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If the facility's activities fit the definition of a refiner, it would have to sample and test each batch of gasoline as required under § 80.65(e). If its activities fit the definition of an oxygenate blender, it would…
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What are the requirements for retailers in the covered areas?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Retailers are subject to certain controls and prohibitions on reformulated gasoline as provided in § 80.78 of the regulations, such as meeting downstream standards, not selling conventional gasoline in RFG areas, selling VOC-controlled gasoline for the proper VOC…
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What information needs to be included on RBOB product transfer documents? Is any information about min/max's required?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The PTD requirements pertaining to RBOB can be found in § 80.77. They include the type of RBOB and the type and amount of oxygenate to be added as well as the min/max's for benzene and RVP, for…
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