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My firm was hired to scrape and repaint siding on a pre-1978 home. The siding is relatively new and was installed after 1978, but was nailed over top of the old lead-based exterior paint. Does the Lead Renovation, Repair and Painting (RRP) Rule apply?
Yes. The RRP Rule applies to a renovation in target housing unless it has been determined that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligram per square centimeter (mg/cm2) or 0.5% by weight…
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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…
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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…
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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…
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What is a child-occupied facility?
A child-occupied facility is a building, or a portion of a building, constructed prior to 1978, visited regularly by the same child, under six years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least three hours…
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When repainting rental housing, if the landlord supplies the paint and materials, and the tenant does the labor without receiving money, credit toward rent, or other compensation, does the RRP Rule apply?
No. The Lead Renovation, Repair, and Painting (RRP) Rule only applies to renovations performed for compensation. Question Number: 23002-23856 Find a printable PDF copy of all frequent questions pertaining to lead .
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When renovating the exterior of a high-rise building, does the requirement to close and seal doors and windows within 20 feet of the renovation include closing those openings two-plus floors above the floor where work is to be performed?
Not necessarily. When establishing containment for an exterior renovation on a multi-story building, you must close all doors and windows within 20 feet of the renovation on the same floor as the renovation, and close all doors and windows on all floors below that are the same horizontal distance from…
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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…
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Does the Renovation, Repair, and Painting (RRP) Rule prohibit the deconstruction and reuse of old building materials containing lead-based paint?
Answer: No. The RRP Rule does not prohibit a firm from extracting, salvaging or reusing building materials that contain lead-based paint. However, the requirements of the RRP Rule may apply to these activities if they (1) occur in target housing or a child-occupied facility, and (2) disturb more than six…
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What do you need to do to become a certified firm?
Answer: Firm certification is easy and straightforward – you need only submit a short application and fee to EPA. View the form and associated materials here . Certified firms will be able to advertise that they are certified by EPA under the Lead Renovation, Repair, and Painting (RRP) Program…
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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 .
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My firm performs renovations in large apartment complexes that often consist of several separate buildings. If a renovation is to be performed in a common area in one building, are we required to provide pre-renovation education to all tenants in all buildings?
When renovations are to be performed in common areas of multi-unit target housing, the RRP Rule requires that the firm notify in writing both the owner of the building and each “affected unit.” See 745.84(b)(1) and (2). Common areas are those portions of a property generally accessible to residents/users, and…
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When a home or an apartment unit is repainted in preparation for a new tenant, is the painting activity always considered a “renovation” for purposes of the pre-renovation education requirements even if no surface preparation activity is performed prior to painting?
Answer: No. The primary determinant of whether a given activity constitutes a “renovation” under the RRP Rule is whether that activity disturbs a painted surface. The practice of recoating painted surfaces in preparation for new tenants would not constitute “renovation” unless accompanied by activities that disturb the painted surface and…
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Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed of under the Lead Renovation, Repair and Painting (RRP) Rule?
The RRP Rule requires the renovation firm to use precautions to ensure that all personnel, tools, and other items are free of dust and debris before leaving the work area. Workers with contaminated clothing can take that contamination home to their own children, and taking contaminated equipment to another jobsite…
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DOE provides weatherization grants to states, which in turn provide grants to non-profit sub-grantees. These sub-grantees fall into one of three categories: 1. The sub-grantee uses its own employees to perform all the weatherization services in the home, 2. The sub-grantee uses a combination of its own employees and contractors to perform weatherization services, or 3. The sub-grantee has no employees that perform weatherization services; instead, every service is performed by a hired contractor. Must these sub-grantees be RRP-certified firms?
Answer : Beginning April 22, 2010, no firm may perform, offer, or claim to perform renovations covered by the RRP Rule without certification from EPA. Sub-grantees that use their own employees to perform any or all of the weatherization services in the home, such as the sub-grantees in the first…
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