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  • What, if any, additional requirements or liabilities exist if a homeowner independently removes the protective barriers and containment measures implemented by the firm during a renovation?

    Before a firm begins a renovation, they are required to comply with all information distribution requirements under the Lead Renovation, Repair and Painting (RRP) Rule and to post signs that clearly define the work area and warn occupants and other persons not involved in renovation activities to remain outside of…

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  • Who is responsible for controlling dust and debris from renovation waste once the waste container or truck used to transport the waste leaves the renovation site?

    When a renovation firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris. The Lead Renovation, Repair and Painting (RRP) Rule does not address the responsibilities of other entities. EPA recommends consulting with state and local waste disposal authorities to learn…

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  • Who is affected by the Fee Rule for Lead Abatement and Renovation, Repair and Painting (RRP) Programs?

    The Fee Rule for Lead Abatement and RRP Programs establishes fees that will be charged for training programs seeking accreditation, for firms engaged in renovations seeking certification and for individuals (for example, risk assessors) or firms engaged in lead-based paint activities that govern lead abatement, inspection and risk assessment activities…

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  • Can a homeowner use an EPA-recognized lead test kit to check for lead-based paint?

    Answer: A number of lead test kits are available for consumer purchase in most retail hardware stores; however, the Consumer Product Safety Commission (CPSC) states that consumers should exercise caution when using these lead test kits to evaluate consumer products for potential lead exposures. Find more information online . To…

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  • How can I obtain D-Lead® test kits?

    The D-Lead® test kits are available for purchase from certain distributors and retail outlets. Locate a distributor or retailer online , email [email protected] or call 414-962-3006. Question Number: 23002-16390 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • Is lead paint testing required under the Lead Renovation, Repair and Painting (RRP) Rule?

    No. A firm can either assume lead-based paint is present and follow the requirements of the RRP Rule (which requires no testing), or test and if lead-based paint is found follow the requirements of the regulation. Question Number: 23002-32338 Find a printable PDF copy of all frequent questions pertaining to…

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  • When testing a work area, does one lead test kit or paint chip sample suffice for any single component?

    The certified renovator is only required to use one lead test kit or paint chip sample for each component, even if the surface of the component is extensive (e.g., a large wall). Question Number: 23002-23865 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • How does EPA verify accuracy and completeness of RMPs?

    What does EPA plan to do to verify the accuracy and completeness of submitted Risk Management Plans (RMPs)? All RMPs received by EPA go through an electronic verification process that checks the submission for its completeness. This completeness check determines whether information has been provided for all of the required…

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  • Five-year Anniversary Due Date and Time

    Pursuant to the risk management program regulations in 40 CFR §68.190, the owner or operator of a stationary source shall revise and update the RMP at least once every five years from the date of initial submission. At what time on the 5-year anniversary date is the RMP due? The…

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  • Required Contractor Contact Information

    A facility that uses a contractor to prepare its RMP must include in the registration section the name, mailing address, and telephone number of the contractor who prepared the RMP (40 CFR §68.160(b)(14)). When a contractor only prepares a portion of an RMP on behalf of a facility, does the…

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  • How many worst-case release scenarios must be analyzed and documented in the RMP?

    As a part of the hazard assessment requirements in 40 CFR Part 68, Subpart B, I must analyze worst-case release scenarios and document certain analyses in my risk management plan (RMP). How many worst-case release scenarios must be analyzed, and how many analyses must be specifically documented in the RMP…

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  • What does "control of the same person" mean?

    Control of the same person refers to corporate control, not site management. If two divisions of a corporation operate at the same site, even if each operation is managed separately, they will count as one source provided the other criteria are met because they are under control of the same…

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  • Identifying public receptors and property with restricted access

    Does public receptor cover only buildings on a property or the entire property? If the owner of the land next to my site restricts access to the land, is it still a public receptor? Public receptors are not limited to buildings. For example, if there are houses near your property…

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  • What is the definition of "offsite property damage?"

    I am working on the five-year accident history portion of the hazard assessment under the RMP. Section 68.42(a) tells me to include "all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage…

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  • When to Revise OCA

    The risk management program in 40 CFR Part 68 requires facilities to conduct an off-site consequence analysis (OCA) to provide information to state, local, and federal governments and the public about the potential consequences of an accidental chemical release. When does a facility need to revise its OCA? The owner…

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