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Can renovator training courses, both initial and refresher courses, be taught online or via distance learning?
Answer: The final Renovation, Repair and Painting regulation, like the abatement program, permits the use of alternative training techniques (e.g., video training, computer-based training) as a supplement to the hands-on skills assessment, or as a substitute for the lecture portion of the training course requirements outlined in § 745.225. In…
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Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?
Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…
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How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?
In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…
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Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?
In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…
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If a remodeling company that is a certified firm uses all contractual workers rather than employees, must each contractual worker be a certified renovator, or can the workers be trained on the job by a certified renovator employed by the firm?
Firms hiring contractual workers may provide the certified renovator that oversees the renovation project and provides on-the-job training to contractual workers and other non-certified workers. Question Number: 23002-18377 Find a printable PDF copy of all frequent questions pertaining to lead .
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Is the certified renovator assigned to a specific project responsible for the work practices of other contractors on the project if the certified renovator is an employee of the general contractor of the project?
All firms performing renovations must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that takes responsibility for ensuring…
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What about a situation where the homeowner is acting as their own general contractor and hires multiple companies to do different portions of the work? In this situation, would each business participating be required to follow the rules and assign a separate certified renovator to supervise their portion of the work including separate containment?
Answer: While the homeowner may be performing the role of general contractor by hiring firms and organizing their work, the homeowner is not performing, offering, or claiming to perform a renovation and therefore does not need to be a certified firm. The firms hired by the homeowner to perform renovation…
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The certified renovator is required to have proof of their certification at the work site. If the certified renovator provides on-the-job training to workers, does there need to be documentation of that training at the work site too?
Answer: No. Certified renovators must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. Certified renovators are also responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned…
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What training requirements apply to non-certified workers who have previous EPA/HUD lead-safe work practices training or accredited abatement supervisor or worker training?
The Lead Renovation, Repair, and Painting (RRP) Rule requires certified renovators to provide on-the-job training (OJT) to non-certified workers on the work practices they will be using in performing their assigned tasks. The amount of OJT needed and the topics that need to be covered depend on the knowledge and…
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How would the Lead Renovation, Repair and Painting (RRP) Rule classify a pre-1978 property that is used for both residential and non-residential purposes?
EPA has interpreted target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. In other words, if a portion of residential property is used for nonresidential purposes, the portion will nonetheless…
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If a renovation is taking place in a home built in 1950, but in an addition that was built in 1980, does the Lead Renovation, Repair and Painting (RRP) Rule apply to the renovation?
Yes. The RRP Rule applies to a renovation in target housing unless it has been determined that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight…
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Older hotels built before 1978 are knocking down walls, combining two hotel rooms, and making their units two-room or even three-room suites. Does the RRP Rule apply when one-room units are converted to two-room suites?
Yes. A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation for purposes of the RRP Rule. Hotel suites that provide a sleeping area that is separate from the living area are covered by the…
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What is "housing for persons with disabilities"?
“Housing for persons with disabilities” means housing that is designed to meet the special needs of persons with disabilities and that is reserved for such persons. A person with a disability may include a person who has a disability attributable to a mental or physical impairment, or a person with…
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Does the term "target housing" mean just low income housing, or any home built before 1978 regardless of the financial status of the occupants?
Answer: “Target housing” means any housing constructed prior to 1978, except housing for the elderly or persons with disabilities or any 0-bedroom dwelling (unless any child who is less than six years of age resides or is expected to reside in such housing). The income of the occupants of the…
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Are renovations in short-term lodgings, such as hotels and motels, time share properties, and homeless shelters, covered by the Lead Renovation, Repair and Painting (RRP) Rule?
Yes, if the property renovated is not a zero-bedroom dwelling. A zero-bedroom dwelling is a residential dwelling in which the living area is not separated from the sleeping area. The term includes efficiencies, studio apartments, dormitory housing, military barracks and rentals of individual rooms in residential dwellings. The short-term nature…
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