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Does the Renovation, Repair, and Painting (RRP) Rule apply to renovations done in an apartment between tenants? Does it matter if children live in other apartments in the building?
Answer: Temporarily unoccupied or vacant rental housing is not exempt from the requirements of the RRP Rule. Question Number: 23002-15669 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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My firm is performing a renovation in an unoccupied home that will be put up for sale when work is done. Does the RRP Rule apply to this renovation?
Yes. Temporarily unoccupied or vacant housing is not exempt from the requirements of the Lead Renovation, Repair, and Painting (RRP) Rule . Question Number: 23002-19754 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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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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Does the Renovation, Repair, and Painting (RRP) Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?
No. The RRP Rule applies to activities that result in the disturbance of painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15696 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does the RRP Rule apply to federal employees performing work on federal facilities?
Yes. Federal agencies and their employees must comply with all Federal, State, interstate, and local requirements, both substantive and procedural, respecting lead-based paint in the same manner and to the same extent as any non-governmental entity. In addition, the RRP Rule requires all renovations performed after April 22, 2010, to…
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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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Does the RRP rule apply to simple painting activities that occur when rental properties turn over? Approximately half of the rental units in the country get new tenants each year. This means a large number of properties are being repeated.
If there is no surface preparation that disturbs the existing paint prior to painting, the RRP Rule does not apply. If you disturb paint by scraping or sanding while preparing the surface, the RRP Rule applies. Question Number: 23002-15692 Find a printable PDF copy of all frequent questions pertaining to…
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Does the RRP Rule apply to office buildings, stores, and other commercial buildings?
No, unless the renovation is taking place in a child-occupied facility that is located in a commercial building. “Child-occupied facility’’ means 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…
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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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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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My firm repairs windows by removing and replacing the sash. We may disturb paint on the hinges and screws, but do not otherwise disturb a painted surface. Is this work subject to the Lead Renovation, Repair and Painting (RRP) Rule?
Replacement of a window sash by simply unscrewing hinges or releasing it from a jambliner does not constitute "window replacement" for purposes of the RRP Rule . Therefore, such tasks may fit within the definition of minor repair and maintenance i.e., activities that disturb six square feet or less of…
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