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Displaying 106 - 120 of 236 results
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I understand that the RRP Rule does not apply to housing for the elderly. Does this term refer to specific built houses in 55+ communities or does it refer to all residential homes with this demographic living there?
"Housing for the elderly" means retirement communities or similar types of housing reserved for households composed of one or more persons 62 years of age or more at the time of initial occupancy. Housing for the elderly is not subject to the RRP Rule unless a child who is less…
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I'm an accredited training provider. Can the final course assessment to be administered in an "open book" format?
No. The training provider is responsible for maintaining the validity and integrity of the course test to ensure that it accurately evaluates the trainee’s knowledge and retention of the course topics. A course test administered in an open book format does not evaluate whether a student has sufficiently learned and…
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If a general contractor hires a subcontractor to work at a renovation site, does the subcontractor need to be a certified firm if the subcontractor does not disturb any paint?
Firms performing tasks that disturb no painted surfaces whatsoever do not need to be certified. However, since conditions at the job site may be difficult to predict, EPA strongly recommends that all firms involved in the renovation be certified and use properly trained and certified personnel. For example, a firm…
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If a property owner and a property management company have entered in to a consent agreement that does not admit an actual violation, is the property management company required to acknowledge a lead-based paint violation for firm certification?
No. Question Number: 23002-18350 Find a printable PDF copy of all frequent questions pertaining to lead .
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In a multi-family building, does the standard for interiors of six square feet or less, or the standard for exteriors of 20 square feet or less of disrupted painted surface apply to the whole building or can it be applied to each separate unit?
For interiors, the exception for work that disrupts six square feet or less of painted surface applies to each individual room and is inclusive of all work done in the room in any 30-day period. For exteriors, to qualify for the exception for minor repair and maintenance activities, the total…
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If I paint without disturbing the surface of the existing paint, can I use a tarp instead of 6 mil plastic?
Yes. Projects that do not disturb a painted surface are not subject to the RRP Rule. Question Number: 23002-18508 Find a printable PDF copy of all frequent questions pertaining to lead .
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If I completed renovator training in an authorized state, what do I need to do to work for an EPA certified firm in EPA-administered jurisdictions?
Answer: There are no additional requirements. To become a certified renovator or certified dust sampling technician, an individual must successfully complete the appropriate course accredited by EPA or by an EPA-authorized state or tribal program. The course completion certificate serves as proof of certification. For a list of states, tribes…
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Must a certified lead abatement professional also become trained and certified to do renovation or repair work?
Yes. Because some skills are different (such as cleaning verification), RRP training and certification is required even if someone already has abatement certification. Question Number: 23002-19615 Find a printable PDF copy of all frequent questions pertaining to lead .
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My firm acts as a general contractor - we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, does my firm need to have a certified renovator at the job site?
Answer: Not necessarily. All firms performing renovations, including general contractors, must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement by hiring another certified…
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My firm installs replacement doors. We simply remove the hinge bolts, unscrew and remove the hinges, and install the new door and hinges. We may disturb paint on the hinges and bolts but no other painted surface. Is this work subject to the RRP Rule?
My firm installs replacement doors. We simply remove the hinge bolts, take away the old door, unscrew and remove the hinges, and install the new door and hinges. We may disturb paint on the hinges and bolts but do not otherwise disturb a painted surface. Is this work subject to…
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My firm is removing and replacing a furnace. The surface area of the old furnace exceeds six square feet. Does the RRP Rule apply to this activity?
The RRP Rule applies to modifications of an existing structure, or portions thereof, that result in the disturbance of painted surfaces. Fixtures such as furnaces, radiators and heating elements, as opposed to personal property, are part of existing structures for RRP purposes. In this case, if the surface coating of…
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My firm plans on doing renovation work on a storage building of an apartment complex. The apartment complex is target housing, but the storage building was constructed after 1978. Will our work on the storage building be covered under the RRP Rule?
My firm plans on doing renovation work on a storage building which is detached from, but a part of, an apartment complex. The apartment complex was constructed prior to 1978 and would be considered target housing. The storage building, however, was constructed after 1978. Will our work on the storage…
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My firm replaces garage doors. We unbolt the door from its hardware and remove it without penetrating, scraping, or removing paint. Is this work subject to the RRP Rule?
Answer: If unbolting and removing the door does not disturb a painted surface in the hinges, door, or frame, the Lead Renovation, Repair, and Painting (RRP) Rule does not apply. For more information on what types of activities disturb paint, go to the following question: 23002-14867 . Question Number: 23002-19760…
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My firm removes and replaces windows from the exterior of a building or residence. To contain dust in the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior, from which the window is removed and replaced. All removal and replacement work is performed from the exterior, and we still apply the exterior containment measures as provided in the Rule. Does the interior containment method described meet the requirements under the Rule?
Answer: No. Although EPA encourages your firm to continue to use this method of supplemental containment, the minimum requirements of the RRP rule must still be met. Specifically, the floor surface must be covered with taped down plastic sheeting or other impermeable material six feet the perimeter of the work…
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My firm was hired to scrape and repaint siding on a pre-1978 home. The siding is relatively new and was installed after 1978, but was nailed over top of the old lead-based exterior paint. Does the Lead Renovation, Repair and Painting (RRP) Rule apply?
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 milligram per square centimeter (mg/cm2) or 0.5% by weight…
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