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What about a situation where the homeowner is acting as their own general contractor and hires multiple companies to do different portions of the work? In this situation, would each business participating be required to follow the rules and assign a separate certified renovator to supervise their portion of the work including separate containment?
Answer: While the homeowner may be performing the role of general contractor by hiring firms and organizing their work, the homeowner is not performing, offering, or claiming to perform a renovation and therefore does not need to be a certified firm. The firms hired by the homeowner to perform renovation…
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Thousands of renovators are already trained and their firms are EPA certified. Will EPA enforce against renovators who did not receive their training certification before December 31, 2010?
It is most important that all contractors follow the RRP work practice standards. However, EPA is providing additional time for renovation firms and workers to obtain the necessary training and certifications before the enforcement of the firm certification and individual renovator requirements begins. Therefore, renovators who have not been able…
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Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the owner or occupant. What is the difference between a certificate of mailing and certified mail?
A certificate of mailing is a receipt showing evidence of mailing, while certified mail provides proof of mailing and delivery of mail. When using the certificate of mailing option, no record is kept at the mailing office and a receipt is not obtained when mail is delivered to the addressee…
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What are the requirements for covering doorways used to access the work area?
Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area. Question Number: 23002-21413 Find a printable PDF copy of all frequent questions pertaining…
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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…
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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…
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To avoid harming the homeowner's grass and landscaping, may my firm fold up the plastic sheeting used for containment at night and re-use it the next day?
Yes, as long as your firm does so in a way that contains any dust and debris on the plastic. One way to accomplish this is to collect and remove the paint chips and debris from the plastic sheeting at the end of each day, mist the sheeting and fold…
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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…
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What mil plastic is considered impermeable?
The regulation does not specify a particular thickness of plastic sheeting considered to be impermeable, but rather includes a performance standard. The performance standard requires firms to isolate the work area, prevent dust and debris from exiting and ensure plastic sheeting is not torn or displaced. Certain guidance materials recommend…
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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 .
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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…
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When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. If hammering painted components, even on the unpainted side, disturbs paint, creating dust or chips, the RRP Rule applies. Question Number: 23002-23787 Find a printable PDF copy of all frequent questions pertaining to lead .
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When must scaffolding and vertical shrouding be used on an exterior renovation when other buildings are in close proximity to the work area?
The certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. The certified renovator must be on site while the containment is established and is responsible…
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When multiple contractors are involved in a single renovation, must every contractor provide pre-renovation education? Can a certified firm assign its responsibility to a property management company?
All firms performing, offering or claiming to perform renovations are responsible for ensuring compliance with the pre-renovation education requirements of the RRP Rule. However, it is unnecessary for the same notifications and information to be given out repeatedly during a single renovation. Accordingly, a firm may discharge the task by…
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When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or…
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