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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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What is a renovation?
The Lead Renovation, Repair, and Painting (RRP) Rule covers activities that modify an existing structure and that result in the disturbance of painted surfaces. All types of repair, remodeling, maintenance, modernization, and weatherization projects are covered, including projects performed as part of another Federal, State, or local program, if the…
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When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. If hammering painted components, even on the unpainted side, disturbs paint, creating dust or chips, the RRP Rule applies. Question Number: 23002-23787 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a company has several legal entities, does each entity have to become a certified firm?
Answer: Yes, if the corporate structure is such that the parent company is not liable for actions of the separate legal entities. Question Number: 23002-18225 Find a printable PDF copy of all frequent questions pertaining to lead .
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My non-profit organization applies for and receives grants to renovate older homes. We do not perform the renovations ourselves, we hire renovation contractors to perform them on our behalf. Must my non-profit organization become an RRP-certified firm?
Answer: Yes, even though your organization's employees do not actually perform the renovation activities, your organization must be an RRP-certified renovation firm because your organization, through the grant process, is offering to perform renovations for compensation, i.e., the grant. Question Number: 23002-19775 Find a printable PDF copy of all frequent…
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Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been painted?
Answer: The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. Therefore, renovations that disturb stucco are subject to the RRP Rule only if the stucco has been painted. Question Number: 23002-14025 Find a printable PDF copy of all frequent questions pertaining to lead .
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Are Department of Energy weatherization projects covered under the RRP Rule?
Answer : The Lead Renovation, Repair, and Painting (RRP) Rule defines “renovation” to include weatherization projects such as cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, and planing thresholds to install weather stripping. Other types of weatherization projects, such as window replacement, are…
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I am a facilities manager for a church with daycare and preschool programs. I recently became a certified renovator. If my staff and I do our own painting and remodeling work, do we need to be a certified firm?
Answer: Yes, if you perform, offer, or claim to perform renovations in a portion of the building that is a child-occupied facility. The 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 6 years…
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If I am painting a wall on which there are multiple coats of latex paint over the old lead-based paint and the paint is not peeling down to the lead paint level must I comply with the new Renovation, Repair, and Painting (RRP) regulations?
Yes, if the painted surface of the wall will be disturbed by the renovation. Question Number: 23002-18485 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a homeowner removes all the painted surfaces in a room and then hires a certified firm to remodel the room, does the renovator need to follow the RRP Rule?
No. Projects that do not disturb a painted surface are not subject to the RRP Rule. Question Number: 23002-18301 Find a printable PDF copy of all frequent questions pertaining to lead .
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If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbance of paint will not occur?
If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbances of painted surfaces will not occur? For example, a certified firm establishes containment and removes wall and…
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Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the RRP Rule? Are the schools or school systems then required to become certified renovation firms?
On or after April 22, 2010, all renovations covered by the Lead Renovation, Repair and Painting (RRP) Rule must be directed by certified renovators and must be performed by certified renovators or individuals trained by a certified renovator. The RRP rule requires any firm, including a local government agency that…
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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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What RRP requirements apply to a comprehensive renovation project involving the removal and replacement of all interior painted surfaces from target housing or a child-occupied facility?
A project that involves the removal and replacement of all interior painted surfaces but leaves all exterior painted surfaces intact is considered a renovation for RRP purposes. Therefore, all requirements of the RRP Rule apply including, but not limited to, those for firm and renovator certification, containment, waste disposal, cleaning…
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Can contractors submit their application to EPA before they complete required training, or must the application be submitted after the training is complete? Is proof of training required by the EPA in order for the contractor's application to be approved?
Answer: The firm certification process does not include the submission of renovator training credentials, so a firm can apply for certification before completing required training. As part of the application, the firm is required to certify it will comply with the requirements of the RRP Rule, including ensuring that all…
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