Laws & Regulations
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Requests for Volume Requirement Waiver under the Renewable Fuel Standard Program
Outside parties can petition EPA to waive in part or in whole the annual volume standard if they can show economic or environemental harm, similar to the authorities provided to the Administrator under the Clean Air Act.
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EPA's Vapor Intrusion Database: Evaluation and Characterization of Attenuation Factors for Chlorinated Volatile Organic Compounds and Residential Buildings
This report presents technical information about sites in the U.S. that have been investigated for vapor intrusion.
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What records must a subcontractor keep?
Answer: If the certified renovator assigned to the project is assigned by the subcontractor, the certified renovator is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share…
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What is EPA's rule to: (1) lower fees for the Lead-Based Paint Activities Programs (for abatement, i.e., total removal) and (2) set fees for the 2008 Lead Renovation, Repair and Painting (RRP) Program?
In March 2009, EPA issued a rule to address fees for its lead-based paint programs. The rule addresses two areas: first, it modifies and lowers the existing fees for EPA's Lead-based Paint Activities regulations that govern lead abatement, inspection and risk assessment activities; second, it establishes fees to cover costs…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, when testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized lead test kit, must I test every component affected by the renovation?
Yes. Certified renovators using EPA-recognized lead test kits to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does not apply to a particular renovation because certified renovator training does not cover sampling protocols…
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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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My firm performs renovations covered by the RRP rule, but solely in the capacity of a subcontractor. If the general contractor is a certified firm, does my firm also have to be certified, or can we just provide the certified renovator?
Answer: All firms performing, offering, or claiming to perform renovations covered by the RRP rule must be certified. In this case, both the general contractor and subcontractor must become certified firms. Question Number: 23002-31784 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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Is anyone exempt from paying fees under the Fee Rule for Abatement and Renovate, Repair and Painting (RRP) Programs?
Yes. TSCA section 402(a)(3) exempts state, local government and non-profit training programs from federal accreditation fees. However, it does not provide an exemption for the certification fees of firms or individuals. Question Number: 23002-33302 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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How does the June 18, 2010 announcement impact renovators in states that have adopted their own RRP programs?
Answer: If you work in a state authorized by EPA to run their own renovation program, you should contact them for information on their certification requirements. If you work in a state where EPA administers the renovation program your firm needs to be certified by EPA. Please refer to the…
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Are there any American Society of Testing Materials (ASTM) standards that EPA considers “documented methodologies”?
Answer: Yes. ASTM Standards are voluntary consensus standards developed after careful review by technical committees which generally include EPA and HUD staff. ASTM Standards relating to lead often reference EPA and HUD documents, just as EPA and HUD documents often reference appropriate ASTM Standards. Although EPA did not specifically list…
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The definition of “soil sample” at 40 CFR §745.63 relies on certain American Society of Testing Materials (ASTM) standards. Did EPA intend to prevent the use of EPA and HUD standards for soil samples?
Answer: No. In establishing work practice standards for lead-based paint activities, EPA did not intend to prevent the use of EPA/HUD standards. As a general matter, the requirements are not prescriptive but instead state that certain activities be conducted using appropriate documented methodologies. For example, §745.227(c)(3) requires that dust samples…
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I own a sole proprietorship, and I plan to get trained and certified as a certified renovator under the RRP Rule. Will that be sufficient since I have no employees?
No. Beginning April 22, 2010, all firms performing renovations covered by the RRP rule must be certified. "Firm" means a company, partnership, corporation, sole proprietorship or individual doing business, association, or other business entity; a Federal, State, Tribal or local government agency; or a nonprofit organization. Question Number: 23002-18123 Find…
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I am the owner of my renovation firm, but I am not a certified renovator. May I be the "attesting individual" named on the RRP firm certification application?
Yes. The attesting individual need not be a certified renovator. Question Number: 23002-18047 Find a printable PDF copy of all frequent questions pertaining to lead .
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I am a firm and there are no training providers offering classes near me. What do I do?
Answer: More than 340 EPA-accredited training providers have indicated to EPA that they are willing to travel to offer training classes. You can find a list of training providers, including those who are willing to travel, by using EPA's search tool at https://cdxapps.epa.gov/ocspp-oppt-lead/training-search . Question Number: 23002-17981 Find a printable…
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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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What do I do if I need to mail a paper Electronic Signature Agreement (ESA) due to Identity Proofing failure or opting out of the online process?
A paper ESA will be sent to the email address provided on your application. A copy of this form can also be found in your CDX Inbox. Print this form, sign it, and mail it to: EPA Lead Data Processing Center c/o CGI Federal 12601 Fair Lakes Circle Fairfax, VA…
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What is a “whole house gut rehabilitation project” for Lead Renovation, Repair and Painting (RRP) Rule purposes? If target housing has, at some point after 1978, been gut-rehabbed, would the RRP Rule apply to subsequent renovations on the property?
The phrase “gut rehabilitation” may have different meanings across the construction industry. EPA, however, used the phrase “whole house gut rehabilitation” in a very limited sense to describe only those activities that demolish and rebuild a structure to a point where it is effectively new construction. At a minimum, these…
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Where can I get more information on lead in drinking water?
Answer: For more information, visit https://www.epa.gov/ground-water-and-drinking-water/basic-information-about-lead-drinking-water or contact us online at https://www.epa.gov/ground-water-and-drinking-water/forms/online-form-epas-office-ground-water-and-drinking-water . You may also contact by email at safewater@epa.gov . Your state or local public health department will also be able to provide information about lead. Question (23002-32409) Find a printable PDF copy of all frequent questions pertaining…