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Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?
Yes, as long as the installation does not disturb more than six square feet of painted surface per room within a 30-day period. Question Number: 23002-15404 Find a printable PDF copy of all frequent questions pertaining to lead .
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Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?
Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…
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How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?
In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…
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Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?
In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…
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If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?
Yes. To qualify for the exception for minor repair and maintenance activities, the total amount of exterior paint disrupted must be 20 square feet or less. In addition, the job must not use prohibited practices or involve window replacement or demolition of painted surfaces. Question Number: 23002-18379 Find a printable…
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If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to make the hole is demolition of the surface, so the minor repair and maintenance exception does not apply. Making the hole using a cut-out technique that does not destroy the section of…
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When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or…
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Tier2 Submit software and confidential chemical location information
When using EPA’s Tier2 Submit software to comply with the annual Hazardous Chemical Inventory reporting requirement under the Emergency Planning and Community Right-to-Know Act (EPCRA) §312, how can a person withhold confidential chemical location information from disclosure to the public? In order to fulfill the proper reporting under EPCRA, a…
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Do states require extra Tier II information?
Do states require additional information on the Tier II report? How can I find out about the state data requirements? Some states do want additional Tier II information; contact your state Tier II administrator to learn specific details. Tier2 Submit includes fields for the additional information requested or required by…
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No Street Address Availability Tier II Reporting
Pursuant to 40 CFR 370.42(d) , Tier II chemical inventory information must include the complete name and address of the location of the facility (including the full street address or state road, city, county, State and zip code), latitude and longitude. If a facility does not have a street address…
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How would the Lead Renovation, Repair and Painting (RRP) Rule classify a pre-1978 property that is used for both residential and non-residential purposes?
EPA has interpreted target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. In other words, if a portion of residential property is used for nonresidential purposes, the portion will nonetheless…
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If a renovation is taking place in a home built in 1950, but in an addition that was built in 1980, does the Lead Renovation, Repair and Painting (RRP) Rule apply to the renovation?
Yes. The RRP Rule applies to a renovation in target housing unless it has been determined that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight…
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Older hotels built before 1978 are knocking down walls, combining two hotel rooms, and making their units two-room or even three-room suites. Does the RRP Rule apply when one-room units are converted to two-room suites?
Yes. A renovation performed for the purpose of converting a building, or part of a building, into target housing or a child-occupied facility is a renovation for purposes of the RRP Rule. Hotel suites that provide a sleeping area that is separate from the living area are covered by the…
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What is "housing for persons with disabilities"?
“Housing for persons with disabilities” means housing that is designed to meet the special needs of persons with disabilities and that is reserved for such persons. A person with a disability may include a person who has a disability attributable to a mental or physical impairment, or a person with…
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My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the new carpet, but sometimes there is. How do I know when I need to comply with the Lead Renovation, Repair and Painting (RRP) Rule?
If when installing the carpet, you disrupt six square feet or less of painted surface per room, the job is not covered by the RRP Rule . Question Number: 23002-19749 Find a printable PDF copy of all frequent questions pertaining to lead .
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