Learn the Issues
-
What records will my firm be required to keep to comply with the Renovation, Repair, and Painting Rule?
The following records must be retained for three years following the completion of a renovation: Reports (if any) certifying that lead-based paint is not present; Records relating to the distribution of the lead pamphlet; and Documentation of compliance with the requirements of the regulation ( EPA has prepared a sample…
-
What training requirements apply to non-certified workers who have previous EPA/HUD lead-safe work practices training or accredited abatement supervisor or worker training?
The Lead Renovation, Repair, and Painting (RRP) Rule requires certified renovators to provide on-the-job training (OJT) to non-certified workers on the work practices they will be using in performing their assigned tasks. The amount of OJT needed and the topics that need to be covered depend on the knowledge and…
-
What is the definition of a child under 6 years of age?
Answer: A child under six years of age is a child that is less than 72 months old. Question Number: 23002-22691 Find a printable PDF copy of all frequent questions pertaining to lead .
-
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…
-
What changes in a renovation firm's status require an amendment of certification and how much will it cost?
Answer : In accordance with § 745.89(c), any change to the information reported to EPA in a firm's most recent certification application must be reported in an amended certification application. There is no fee associated with the submission of an amended certification. Question Number: 23002-21581 Find a printable PDF copy…
-
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…
-
What is a studio apartment?
A studio apartment is an apartment in which the living area is not separated from the sleeping area. Question Number: 23002-22148 Find a printable PDF copy of all frequent questions pertaining to lead .
-
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…
-
Under the Renovation, Repair, and Painting (RRP) Rule, in exterior containment if a large tree or shrub is within the work area can the plastic be placed around the base and would the plant, however large, also need to be covered?
Answer: The Lead Renovation, Repair, and Painting (RRP) Rule does not specifically address containment of trees or shrubs, but if dust, debris, or residue remains in the tree or shrub at the conclusion of the job, the site will not pass visual inspection. The work practices for exterior projects are…
-
Under the RRP Rule, can a certified renovator supervise workers of a different company, or must each firm involved in a project furnish a certified renovator?
All firms performing renovations 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. The Lead Renovation, Repair, and Painting (RRP) Rule does not prohibit firms from reaching agreement on which will supply the certified…
-
Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?
Yes. The Lead Renovation, Repair, and Painting (RRP) Rule does not specify the format in which these documents must be kept, but they must be available at the work site. Documents are not available if they cannot be viewed. Certified renovators must have with them at the work site copies…
-
EPA RCRA ID: PAD056602923
RCRA Corrective Action Cleanup Site for PAD056602923 Vorteq Coil Finishers (Formerly: Wismarq Industries, Prior Coated Metals) in Allentown, Pennsylvania
-
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…
-
Under the RRP Rule, do paint chips and debris need to be removed from protective sheeting even if such chips and debris can be effectively contained by the sheeting or the sealed container the sheeting is contained in for disposal?
Yes. After the renovation has been completed, the firm must clean the work area until no dust, debris, or residue remains. The first cleaning step required by the Lead Renovation, Repair, and Painting (RRP) Rule is to collect all paint chips and debris and, without dispersing any of it, seal…
-
EPA RCRA ID: PAD980552020
RCRA Corrective Action Cleanup Site for PAD980552020
-
EPA RCRA ID: PAD003001732
RCRA Corrective Action Cleanup Site for PAD003001732 Everchem Specialty Chemicals Co. Leigh Valley Logistics ( Formerly: Black & Decker) in Allentown, Pennsylvania
-
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…
-
Plastic can be a slip hazard in some jobs, such as handling granite counter tops. This creates a more immediate safety concern than protecting the floor from dust. Can't I just clean the floor at the end of the job?
Answer: No. For interior renovations, before beginning the renovation the renovation firm must cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area six feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever…
-
My non-profit organization receives grants to arrange renovations in older housing. My organization is responsible for locating eligible properties and hiring firms to perform the renovations. Must my organization become an RRP-certified firm?
My non-profit organization receives grants to arrange for renovations in older housing, such as weatherization projects or general modernization. Typically, these grants come with eligibility conditions for properties and/or property owners and tenants, but specific properties or projects are not identified. My organization is responsible for locating eligible properties and…
-
The certified renovator is required to have proof of their certification at the work site. If the certified renovator provides on-the-job training to workers, does there need to be documentation of that training at the work site too?
Answer: No. Certified renovators must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. Certified renovators are also responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned…