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Criteria for oil production facilities to be qualified facilities
Qualified facilities are eligible for streamlined regulatory requirements in 40 CFR §112.6, which include self-certification of SPCC Plans. What criteria do oil production facilities have to meet in order to be considered qualified facilities? Oil production facilities, like all other facilities, must meet the criteria in §112.3(g)(1) or (2) to…
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Is my EPA renovator certification accepted in all states and tribal areas?
Answer: Not necessarily. Whether to accept certification from another jurisdiction is up to the individual state or tribal area. EPA cannot compel states or tribes to adopt programs identical to the Federal program or to establish reciprocity provisions. However, EPA continues to encourage states and tribes that may be considering…
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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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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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I am a facilities manager for a church with daycare and preschool programs. I recently became a certified renovator. If my staff and I do our own painting and remodeling work, do we need to be a certified firm?
Answer: Yes, if you perform, offer, or claim to perform renovations in a portion of the building that is a child-occupied facility. The RRP Rule defines a child-occupied facility as a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years…
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If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbance of paint will not occur?
If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the direction of a certified renovator using trained workers, can uncertified workers complete the job if further disturbances of painted surfaces will not occur? For example, a certified firm establishes containment and removes wall and…
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My firm is certified by an authorized state. Does this certification allow my firm to work in EPA-administered jurisdictions?
No. You must apply for and receive EPA certification before offering, performing, or claiming to perform renovations covered by the RRP Rule in EPA-administered jurisdictions. Question Number: 23002-19752 Find a printable PDF copy of all frequent questions pertaining to lead .
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Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the RRP Rule? Are the schools or school systems then required to become certified renovation firms?
On or after April 22, 2010, all renovations covered by the Lead Renovation, Repair and Painting (RRP) Rule must be directed by certified renovators and must be performed by certified renovators or individuals trained by a certified renovator. The RRP rule requires any firm, including a local government agency that…
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SPCC compliance dates for farms
What are the Spill Prevention, Control, and Countermeasure (SPCC) compliance dates for farms? On November 22, 2011, EPA amended the date by which certain farms must prepare, or amend, and implement their SPCC Plans to May 10, 2013 to comply with SPCC rule amendments promulgated since July 2002 ( 76…
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Can contractors submit their application to EPA before they complete required training, or must the application be submitted after the training is complete? Is proof of training required by the EPA in order for the contractor's application to be approved?
Answer: The firm certification process does not include the submission of renovator training credentials, so a firm can apply for certification before completing required training. As part of the application, the firm is required to certify it will comply with the requirements of the RRP Rule, including ensuring that all…
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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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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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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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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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