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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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Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?
Yes, as long as the installation does not disturb more than six square feet of painted surface per room within a 30-day period. Question Number: 23002-15404 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?
Yes. To qualify for the exception for minor repair and maintenance activities, the total amount of exterior paint disrupted must be 20 square feet or less. In addition, the job must not use prohibited practices or involve window replacement or demolition of painted surfaces. Question Number: 23002-18379 Find a printable…
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If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to make the hole is demolition of the surface, so the minor repair and maintenance exception does not apply. Making the hole using a cut-out technique that does not destroy the section of…
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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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When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or…
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My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the new carpet, but sometimes there is. How do I know when I need to comply with the Lead Renovation, Repair and Painting (RRP) Rule?
If when installing the carpet, you disrupt six square feet or less of painted surface per room, the job is not covered by the RRP Rule . Question Number: 23002-19749 Find a printable PDF copy of all frequent questions pertaining to lead .
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If I certify a nonroad flexible-fuel engine under 40 CFR Part 1054, are owners and operators prohibited from using gasoline-ethanol blended fuels containing greater than 10 volume percent ethanol under 80.1504(a)(1) in my nonroad flexible-fuel engine?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, owners and operators of nonroad engines, vehicles, and equipment where the nonroad engine is certified under 40 CFR Part 1054 as a flexible-fuel engine are not prohibited from using gasoline-ethanol blended fuels containing greater than 10 volume…
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Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.”
Answer: “Minor repair and maintenance” is defined in 40 CFR 745.83 as activities that disrupt less than 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or…
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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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Does the minor maintenance exception mean that if I drill one-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule?
The exception is based on the area of paint disrupted, which in this example is based on the combined areas of the holes drilled in the wall. Question Number: 23002-15677 Find a printable PDF copy of all frequent questions pertaining to lead . Other Frequent Questions about the RRP Program…
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In a multi-family building, does the standard for interiors of six square feet or less, or the standard for exteriors of 20 square feet or less of disrupted painted surface apply to the whole building or can it be applied to each separate unit?
For interiors, the exception for work that disrupts six square feet or less of painted surface applies to each individual room and is inclusive of all work done in the room in any 30-day period. For exteriors, to qualify for the exception for minor repair and maintenance activities, the total…
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Is replacing a pane of glass or fixing a broken window balancer a renovation covered by the RRP Rule?
It depends. Replacing a pane of glass or fixing a broken window balancer can disturb paint. If the job disrupts more than six square feet of painted surface per room, the job is not considered minor repair and maintenance and it is covered by the RRP Rule. When removing a…
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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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