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Is interior containment required as well as exterior containment for an exterior window removal?
Yes. If removing windows from the exterior creates dust and debris on the interior as well as the exterior of the building, then the firm must follow the requirements in the Lead Renovation, Repair and Painting Rule for both interior and exterior containment. Before beginning the renovation, the firm must…
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May I as a training provider issue a certificate without a picture to a trainee who has successfully completed the course but objects to having his or her picture taken (or objects to possessing a photograph of him/herself) on religious grounds?
Yes. Training providers may provide a person who objects to having his or her picture taken because of sincerely held religious beliefs with the equivalent of a certificate without a picture. Specifically, the training provider may provide an “Acknowledgement of Completion” that the person has successfully completed the training (containing…
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My firm is doing renovations in a school during summer break, and no children under age six will be present during this period. Do we still have to comply with the pre-renovation education requirements? If so, how should the information be distributed?
My firm is going to perform renovations in a school during the students’ summer break. During the regular school year, the work area would fall under the definition of a child-occupied facility. However, no children under age six will be present during this multiple month break period. Do we still…
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According to your guidelines emergency projects are exempt from some requirements to the extent necessary to respond to the emergency. Does this mean that my firm does not need to be certified and my company doesn't need a certified renovator?
Question : My company only does emergency renovation work. According to your guidelines emergency projects are exempt from the warning sign, containment, waste handling, training, and certification requirements to the extent necessary to respond to the emergency. Emergency renovations are NOT exempt from the cleaning and cleaning verification requirements. Does…
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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. Does my firm need to be a certified firm under the Renovation, Repair, and Painting (RRP) Rule?
Answer: Yes. Beginning April 22, 2010, no firm may perform, offer, or claim to perform renovations covered by the Lead Renovation, Repair, and Painting (RRP) Rule without certification from EPA. A general contractor that subcontracts the entire renovation job to other firms must be certified as a firm for two…
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My company installs new or replacement seamless gutters. We install the gutters using self-tapping screws and the cumulative size of the total number of holes is only a couple of square inches. If the job does not involve sanding, scraping, repainting, repair, replacement or reconditioning of the fascia surface, is it covered by the RRP Rule?
Minor repair and maintenance activities are not subject to the requirements of the Lead Renovation, Repair, and Painting (RRP) Rule . For exterior renovations, minor repair and maintenance activities are those activities that disrupt 20 square feet or 29 less of painted surface, and do not use prohibited practices or…
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May renovator training providers provide reasonable accommodations to people with disabilities?
Yes. However, to pass the course an individual must successfully complete the hands-on skills assessment and receive a passing score on the course test. Question Number: 23002-19568 Find a printable PDF copy of all frequent questions pertaining to lead .
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The Renovation, Repair, and Painting (RRP) Rule requires HEPA vacuums to be used for cleaning up the dust created by renovations. What should I look for when purchasing a HEPA vacuum?
According to the definition in 40 CFR 745.83 : " HEPA vacuum means a vacuum cleaner which has been designed with a high-efficiency particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particulates of 0.3 microns with 99.97% efficiency…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, is composite sampling acceptable for clearance in lieu of cleaning verification?
Yes. Under the RRP Rule , cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another Federal, State, Territorial, Tribal or local law or regulation requires: The renovation firm to perform dust clearance sampling at the conclusion of…
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What is an "emergency renovation" for purposes of the Lead Renovation, Repair and Painting (RRP) Rule?
Emergency renovations are those performed in response to situations necessitating immediate action to address safety or public health hazards or threats of significant damage to equipment and/or property. The need for immediate action relieves firms from the pre-renovation education requirements. Likewise, emergency renovations are exempt from the warning sign, containment…
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When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and completely enclose the interior area in which I physically work. If these barriers are set up at a distance less than six feet from the perimeter of the work surface, must I still extend the containment on the floor beyond the vertical barrier to meet the six-foot requirement?
Answer: No, provided that the vertical containment system consists of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls (40 CFR § 745.85(a)(2)(i)(D)). This type of vertical containment acts as the functional equivalent of a wall for…
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My firm repairs windows in which the glass has been cracked or broken by removing and replacing the sash. For casement windows, we unscrew and remove the hinges on the old window, pull out the old sash, and install the new sash. For double-hung windows, we release the jambliner, pull out the sash with the damaged glass, and install the new sash. We may disturb paint on the hinges and screws, but do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?
Answer: Replacement of a window sash by simply unscrewing hinges or releasing it from a jambliner does not constitute “window replacement” for purposes of the RRP Rule. Therefore, such tasks may fit within the definition of minor repair and maintenance i.e., activities that disturb six square feet or less of…
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The Lead Renovation, Repair and Painting (RRP) Rule provisions require exterior containment. At what point is the wind too strong to allow work to continue?
The work practices for exterior projects are based on a performance standard -- 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…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, what type of container is adequate for on-site storage of debris?
At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…
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In a typical co-operative apartment building, occupants do not own the individual units; rather they “own” an undifferentiated share in the entire building and then “rent” back a specific unit from the co-operative corporation. Similarly, in a typical condominium building, owners of individual units jointly own the common areas of the building. For purposes of the pre-renovation education requirements, who are the “owners” in such situations?
Answer: EPA recognizes that co-operative apartments (“co-ops”) and condominiums (“condos”) can be structured in a variety of ways. For example, in the case of co-ops, a corporation (sometimes referred to as a “co-op association”) is often established and owns all the units and common areas comprising the co-op; in such…
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