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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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If a firm does business in several states, must they become certified in all states in which they manage a target property or is this requirement satisfied by certifying the firm in the state in which they are headquartered?
The RRP Rule applies in states and tribal areas that are not operating EPA-authorized programs. A firm with Federal certification under the RRP Rule may perform, offer, or claim to perform renovations in any of these states. In states and tribal areas with EPA-authorized programs, check with the state or…
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If a property is tested by a certified renovator, inspector, or risk assessor and found to be free of lead-based paint, does any testing need to be done again if work is done on the property several years later?
Where a certified renovator uses an EPA-recognized lead test kit or performs paint chip sampling to determine that a component is free of lead-based paint, or a lead-based paint free determination is made by a certified inspector or risk assessor, firms performing renovations on the same components may rely on…
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I understand that the RRP rule does not apply to dormitories. Does the rule apply to a unit of student housing made up of two bedrooms, a living room, and kitchen?
Yes. While the RRP rule does not apply to zero-bedroom housing, the type of housing described is not zero-bedroom housing. Zero-bedroom housing means a residential dwelling in which the living area is not separated from the sleeping area. Examples include efficiencies, studio apartments, and dormitory housing. In the example given…
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I operate a renovation firm and I have heard that my state will adopt its own lead Renovation, Repair and Painting program. Do I have to also be certified by EPA?
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 I mist and vacuum with a High Efficiency Particulate Air (HEPA) vacuum the plastic sheeting used by my firm for interior containment, can I move and re-use plastic sheeting on the same day and job?
No. The Lead Renovation, Repair and Painting Rule does not contemplate a permissible method of moving and re-using plastic sheeting used for interior containment. Question Number: 23002-18500 Find a printable PDF copy of all frequent questions pertaining to lead .
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If my firm already has abatement certification, is separate RRP certification necessary?
Lead Renovation, Repair, and Painting (RRP) firm certification is not required to perform lead abatements. However, if your firm performs, offers, or claims to perform renovations as well as abatements, after April 22, 2010 it must be a certified renovation firm. Question Number: 23002-18528 Find a printable PDF copy of…
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If I rent out apartments built before 1978, in order to comply with the Lead Renovation, Repair and Painting (RRP) Rule, do I need to get firm and renovator certification if I do my own work on it? What if I hire a renovation firm to do the work?
With respect to landlords, EPA believes that there are two circumstances where work being done in pre-1978 apartment is for compensation such that the landlord must be a Lead-Safe Certified Firm and use (or be) a certified renovator. First, if the landlord does the renovation him or herself, then the…
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If a renovation is to be performed on a private balcony of a single unit in a multi-unit target housing building, does that activity trigger the common area notification requirements?
A determination of whether the balcony renovation falls within a common area depends upon the scope of the renovation activity. A common area is a portion of a building that is generally accessible to all residents/users. Thus, if the work area established to contain dust and debris from the renovation…
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Is an electronic version of the lead information pamphlet sent to the customer via e-mail an acceptable means of distributing the information?
The distribution of the lead information pamphlet (40 CFR § 745.83) via e-mail is an acceptable means of distributing the pamphlet as long as the requirements of the Electronic Signatures in Global and National Commerce Act ("Act") (15 U.S.C. § 7001 et seq.) are met. The Act requires that the…
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If a renovator is only reimbursed for materials, would that be considered compensation?
No. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies, and non-profits; and rent for target housing or public or commercial building space…
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May principal instructors, working under the umbrella of an accredited training provider, independently advertise, provide training or use the EPA Lead-Safe Certified logo?
No. Principal instructors that advertise, provide training and use the logo must do so under the name of the accredited training provider for whom they work. They may also state that the organization which employs them is assisting with the training. Question Number: 23002-33375 Find a printable PDF copy of…
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My non-profit home repair organization performs renovations using mostly volunteers. We do some painting and scraping but we do mostly roof repair and interior work (bathrooms, kitchens, etc.). Is my organization’s work covered by the RRP Rule?
My non-profit home repair organization performs renovations using mostly volunteers. We do some painting and scraping but we do mostly roof repair and interior work (bathrooms, kitchens, etc.). Obviously, we want to be in compliance with the law and we want our volunteers, staff and homeowners to be safe. Equally…
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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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Is a health care facility or hospital covered under the RRP Rule if it meets the definition of a child-occupied facility?
Yes. The Lead Renovation, Repair, and Painting (RRP) Rule defines a child-occupied facility as a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under six years of age, on at least two different days within any week (Sunday through Saturday period), provided…
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