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Displaying 16 - 30 of 33 results
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Does the Renovation, Repair, and Painting (RRP) Rule prohibit the deconstruction and reuse of old building materials containing lead-based paint?
Answer: No. The RRP Rule does not prohibit a firm from extracting, salvaging or reusing building materials that contain lead-based paint. However, the requirements of the RRP Rule may apply to these activities if they (1) occur in target housing or a child-occupied facility, and (2) disturb more than six…
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My firm performs renovations in large apartment complexes that often consist of several separate buildings. If a renovation is to be performed in a common area in one building, are we required to provide pre-renovation education to all tenants in all buildings?
When renovations are to be performed in common areas of multi-unit target housing, the RRP Rule requires that the firm notify in writing both the owner of the building and each “affected unit.” See 745.84(b)(1) and (2). Common areas are those portions of a property generally accessible to residents/users, and…
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When a home or an apartment unit is repainted in preparation for a new tenant, is the painting activity always considered a “renovation” for purposes of the pre-renovation education requirements even if no surface preparation activity is performed prior to painting?
Answer: No. The primary determinant of whether a given activity constitutes a “renovation” under the RRP Rule is whether that activity disturbs a painted surface. The practice of recoating painted surfaces in preparation for new tenants would not constitute “renovation” unless accompanied by activities that disturb the painted surface and…
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How can a firm comply with the pre-renovation education requirements if the owner desires that the renovation begin immediately?
Answer: If the renovation is taking place in an owner-occupied dwelling unit, a firm must simply provide the owner with a copy of the pamphlet, and either (1) obtain, from the owner, a written acknowledgement that the owner has received the pamphlet, or (2) obtain a certificate of mailing at…
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How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for example, to church groups who, as part of their missionary work, are making improvements for low-income residents?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to renovations performed for compensation. 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…
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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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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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What are the pre-renovation education requirements for a vacant apartment?
Firms performing renovations must provide pre-renovation education to the owner of the unit and to an adult occupant. If the unit is not occupied, providing pre-renovation education to the owner of the unit is sufficient. EPA has prepared a document with additional information . Question Number: 23002-21374 Find a printable…
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Does a renovator need to attempt personal delivery of the lead information pamphlet to a tenant more than one time before utilizing the “self-certification of pamphlet delivery” option?
Answer: Personal delivery of the lead information pamphlet is preferable, wherever possible, because EPA believes that tenants will be more likely to read the information if it is handed directly to them. It also affords tenants an opportunity to raise concerns and ask questions about the renovation. EPA recognizes, however…
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The RRP Rule requires delivery of the “Renovate Right” pamphlet to the owner and occupants of target housing. My firm was hired to perform a renovation in a pre-1978 apartment building. Is delivery of the pamphlet to the property manager sufficient for purposes of delivery to the owner of the building?
Answer: Yes. Property managers are acting in the capacity of agents for the building owners. For this reason, a property manager may receive, and acknowledge receipt of, the lead hazard pamphlet on behalf of the owner. In situations where property managers or their employees are performing the renovations themselves, they…
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I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of painted wood siding that tested positive for lead. The underlying painted surface is greater than twenty square feet. Must I comply with the Rule when removing the aluminum siding?
Answer: The work practices for exterior projects are based on a performance standard – if the activity disturbs a painted surface (generally, by creating paint chips or dust) in excess of 20 square feet, the work area must be contained so that dust or debris does not leave the work…
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Can notices for multi-family housing common area renovations be delivered to the mailboxes of dwelling units, or only to the actual units themselves?
Answer: Should a firm decide to comply with the pre-renovation education requirements by hand delivering or mailing “Renovate Right” pamphlets and notices, they may do so either through delivery of the notices directly to tenant units or through delivery to tenant mailboxes. If mailbox delivery is used, both hand delivery…
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My firm is doing renovations in a school during summer break, and no children under age six will be present during this period. Do we still have to comply with the pre-renovation education requirements? If so, how should the information be distributed?
My firm is going to perform renovations in a school during the students’ summer break. During the regular school year, the work area would fall under the definition of a child-occupied facility. However, no children under age six will be present during this multiple month break period. Do we still…
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