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Purpose of Oil Pollution Prevention regulation
What is the purpose of the Oil Pollution Prevention regulation? When oil spills into navigable waters or onto adjoining shorelines, it can have harmful impacts on the environment, human health, and economic activity. EPA issued the Oil Pollution Prevention regulation to prevent oil spills and to assure that oil facility…
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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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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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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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Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed of under the Lead Renovation, Repair and Painting (RRP) Rule?
The RRP Rule requires the renovation firm to use precautions to ensure that all personnel, tools, and other items are free of dust and debris before leaving the work area. Workers with contaminated clothing can take that contamination home to their own children, and taking contaminated equipment to another jobsite…
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SPCC Training Materials for Production Sector
Does EPA offer any Spill Prevention, Control, and Countermeasure (SPCC) training materials specifically for the production sector? Yes. EPA has developed a “train-the-trainer” presentation for the production sector. The presentation provides information for organizations to hold trainings on the SPCC rule. The presentation is available in the SPCC Rule: Train-the-Trainer…
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How should lead-containing wastes from RRP renovations be handled and disposed?
While at the work site, wastes must be collected at the conclusion of each work day and at the conclusion of the renovation and stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…
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Can non-certified workers transport debris off site under the RRP Rule if they have had documented on-the-job training in this activity by the certified renovator?
Answer: Yes. The RRP Rule requires the certified renovator to regularly direct the work being performed by other individuals to ensure that the work practices are being followed, including ensuring that dust or debris does not spread beyond the work site. The certified renovator is responsible for providing training to…
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If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
Answer: The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share the responsibility for retaining and…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, how should I dispose of contaminated water used in two-bucket mopping?
EPA recommends contacting your local water treatment authority and asking about local requirements for handling and disposing of waste water. Question Number: 23002-20756 Find a printable PDF copy of all frequent questions pertaining to lead .
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What records must a subcontractor keep?
Answer: If the certified renovator assigned to the project is assigned by the subcontractor, the certified renovator is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share…
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I hear new record keeping requirements will take effect soon. What are they and when must my firm begin to comply with them?
Answer: Beginning July 6, 2010, when the final invoice for the renovation is delivered, or within 30 days of the completion of the renovation, whichever is earlier, the renovation firm must provide information demonstrating compliance with the training and work practice requirements of the RRP Rule to the owner of…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, what type of container is adequate for on-site storage of debris?
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 a barrier that prevents release of dust and debris out of the work area and prevents access to…
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