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Can a training provider that is accredited only in a Federal program state teach a course at a location in an authorized State that would lead to certification in the Federal program?
Answer : The Federal program does not restrict the location where Federal program training courses can be provided. In other words, a federally-accredited training provider may provide training in any state, and the resultant certification would enable a person to work in all federal program states. However, the Federally-accredited training…
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Does a supervisor need to be certified as a worker to conduct lead-based paint activities normally conducted by certified workers?
Answer: No. Question Number: 23002-33450 Find a printable PDF copy of all frequent questions pertaining to lead .
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Can a training provider that is accredited only in an authorized State teach a course in an out-of-state location that would lead to certification in the authorized State?
Answer: Because the training provider is not Federally-accredited and is not offering a course that would lead to EPA certification, the Federal lead-based paint program regulations do not apply. However, EPA recommends that the training provider discuss applicable State program requirements with the authorized State. Question Number: 23002-33460 Find a…
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Are there any American Society of Testing Materials (ASTM) standards that EPA considers “documented methodologies”?
Answer: Yes. ASTM Standards are voluntary consensus standards developed after careful review by technical committees which generally include EPA and HUD staff. ASTM Standards relating to lead often reference EPA and HUD documents, just as EPA and HUD documents often reference appropriate ASTM Standards. Although EPA did not specifically list…
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The definition of “wipe sample” relies on two very specific American Society of Testing Materials (ASTM) standards. In referencing the ASTM standards, did EPA intend to prevent the use of EPA and HUD standards for wipe samples?
Answer: No. In establishing work practice standards for lead-based paint activities, EPA did not intend to prevent the use of EPA/HUD standards. As a general matter, the requirements are not prescriptive, but instead state that certain activities be conducted using appropriate documented methodologies. For example, §745.227(c)(3) requires that dust samples…
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Does EPA require inspectors, risk assessors, dust sampling techs, or anyone who performs LBP and/or lead dust sampling to document any visible LBP deterioration on components and estimate the surface area of deteriorating paint during a lead evaluation?
Answer: It depends on the type of evaluation being done. The work practice standards at 40 C.F.R. 745.227 provide instructions for addressing deteriorated lead-based paint during lead hazard screens, risk assessments, and post-abatement clearance activities. Inspections only examine the presence of leadbased paint and do not consider deterioration. Instructions for…
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Must all persons present on an abatement job site be certified?
Answer: No. The regulations at 745.220(b) require that persons engaged in lead-based paint activities defined in 745.223 must be certified. The work practice standards at 745.227 are specific as to which disciplines may perform which lead-based paint activities. However, EPA recognizes that other activities such as interim controls may also…
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Do EPA’s current rules require inspectors, risk assessors, dust sampling technicians, or any individual who performs lead-based paint and/or lead dust sampling to document any visible lead-based paint deterioration on components and estimate the surface area of deteriorating paint during a lead evaluation?
Answer: It depends on the type of evaluation being done. The work practice standards at 40 CFR 745.227 provide instructions for addressing deteriorated lead-based paint during lead hazard screens, risk assessments, and post-abatement activities. Inspections only examine the presence of lead-based paint and do not consider deterioration. Instructions for dust…
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Immediately following the completion of renovation activities, a company conducts an examination which reveals dust levels above the action level. Is removal of dust to address the failure of this examination considered abatement?
Answer: No. The removal of dust to address the failure of the examination would be considered part of cleanup from the renovation. Routine cleanup of renovation-related dust is not abatement, even if the dust is known to be above the dust lead reportable level. For more information on lead-safe work…
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What is the difference between Abatement Certification and Renovation (RRP) Certification?
Answer: Abatement certification, also known as Lead-Based Paint Activities certification, is a specialized type of certification for firms who specifically work with lead-based paint such as lead abatement firms, lead risk assessor firms, and lead inspection firms. Abatement intentionally addresses lead-based paint hazards. Renovation (RRP) certification is appropriate for firms…
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In some areas of the country, refresher courses are offered infrequently. Can an individual applying for recertification re-take an initial course in the lead-based paint activity discipline for which they are certified instead of taking a refresher course?
Answer: Yes. The certified individual can simply re-take the initial course in the discipline for which they are certified. Question Number: 23002-33463 Find a printable PDF copy of all frequent questions pertaining to lead .
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Must employees of Federal agencies who conduct lead-based paint activities be certified as individuals? Must their agencies be certified as firms? Must Federal agencies pay certification fees for individuals and firms?
Answer: Yes. TSCA section 408 generally requires Federal agencies and their employees to comply with all Federal, State, interstate, and local requirements, both substantive and procedural, respecting leadbased paint, lead-based paint activities, and lead-based paint hazards in the same manner and to the same extent as any non-governmental entity is…
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Must I take a third party certification exam?
Answer : No third party exam is required for recertification, even if you choose to take another initial training course rather than a refresher training course. Question Number: 23002-32439 Find a printable PDF copy of all frequent questions pertaining to lead .
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Must self-employed or one-person businesses that perform lead-based paint activities, such as lead-based paint inspections, risk assessments, or abatements, be certified as firms in addition to being certified as individuals?
Answer: Yes. Under 745.226(a)(5), individuals performing lead-based paint activities must be certified, so all self-employed persons must be certified as individuals in the appropriate discipline(s). In addition, the definition of certified firm at 745.223 includes sole proprietorships that perform lead-based paint activities. The definition of certified firm also includes other…
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Does TSCA section 402 apply to U.S. military bases, facilities, and installations located outside of the U.S.?
Answer: No. EPA does not have authority to regulate environmental conditions in foreign countries. Environmental compliance by Department of Defense installations overseas is governed by a number of documents. For example, Executive Order 12088, dated October 13, 1978, requires that the heads of government agencies responsible for constructing or operating…
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