When tenant accessibility to a work site within a common area can be precluded for the duration of a renovation, EPA considers that work site to be temporarily excluded from the common area of the building for pre-renovation education purposes because it is not accessible to the residents and users of the building. To qualify for this exclusion, however, the work site must be in an area which is enclosed by a wall, fence, or other permanent or temporary physical barrier which truly prevents access by tenants and other building users. Rope, tape lines, pylons, and similar work area designation devices which can be easily surmounted or bypassed are not acceptable barriers for this purpose.

Question Number: 23002-32360

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