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  • Hot Work Definition and Requirements

    Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to…

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  • Do I have to conduct incident investigations of releases resulting from theft?

    The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of covered substances, such as anhydrous ammonia? If…

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  • Do Program 1 processes have to complete a process hazard analysis?

    Do owners or operators of Program 1 processes have to complete a process hazard analysis? No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes must complete a…

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  • Is a hazard review synonymous with a process hazard analysis (PHA)?

    The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention…

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  • How often must compliance audits be performed?

    How often must owners or operators of stationary sources subject to the risk management program regulations perform compliance audits? The regulations at 40 CFR §§68.58(a) and 68.79(a) state that owners or operators must certify that they have evaluated compliance with the applicable prevention program provisions at least once every three…

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  • Do settlement communications, such as past “agreements in principle,” impact the implementation of the final Consent Decrees?

    The parties are bound by the terms of the various final, publicly available consent decrees. These consent decrees were made available for public comment before they were finalized and entered by the Court. Past settlement communications and documents created in the course of settlement discussions have been incorporated (or not)…

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  • What is the Confidentiality Order?

    The Confidentiality Order (Order) is a court order entered by the Federal District Court for the District of Montana (Court) on August 8, 2002, and amended by the Court on December 31, 2003, that applies to Superfund settlement negotiations in the Clark Fork River Basin, including the following sites: Silver…

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  • How does EPA ensure that the potentially responsible parties complete their work?

    All cleanup activities performed by the PRPs are subject to enforcement instruments (i.e., consent decrees or administrative orders) that provide for EPA approval of all deliverables and oversight of all work performed by the PRPs.

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  • How do I verify that the fees I am being asked to pay are correct?

    Answer: Click the link that applies to your application type: Firm Individual Training Provider If you still have questions, call the National Lead Information Center at 1-800-424-LEAD . Question Number: 23002-37013 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • How do I know that my transaction will be secure?

    Answer: Online transactions are managed by the U.S. Department of Treasury. For more information regarding the security controls in place to protect your transactions, please visit https://pay.gov/public/home . Question Number: 23002-37016 Find a printable PDF copy of all frequent questions pertaining to lead .

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  • How does my firm become Renovation, Repair, and Painting (RRP) Certified?

    Answer : EPA's Renovation, Repair, and Painting program applies to all states, tribes and territories where EPA has not specifically provided authorization for that state, tribe or territory to operate the program themselves. Currently, there are 15 states and 1 tribe that are authorized by EPA to operate their own…

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  • How does my firm become Abatement Certified?

    Answer: EPA's Abatement program applies to all states, tribes and territories where EPA has not specifically provided authorization for that state, tribe or territory to operate the program themselves. EPA only administers the abatement program in the following states, tribes and territories: Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico…

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  • How do I become certified as an Individual in the Lead Abatement program?

    Answer: EPA's Abatement program applies to all states, tribes and territories where EPA has not specifically provided authorization for that state, tribe or territory to operate the program themselves. EPA only administers the abatement program in the following states, tribes and territories: Alaska, Arizona, Florida, Idaho, Montana, Nevada, New Mexico…

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  • How do I become accredited as a Training Provider?

    Answer: Trainers seeking accreditation in an EPA administered state must submit their applications and fees online through EPA’s CDX system, the EPA’s electronic reporting system: https://cdx.epa.gov . If you have not previously created a CDX account, click “Register with CDX”, accept the terms, choose “LEAD: Lead-Based Paint Program”, and select…

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  • Does compliance under OSHA's PSM demonstrate compliance with the risk management program?

    The Clean Air Act Amendments of 1990 (CAAA) mandated the Occupational Safety and Health Administration (OSHA) to develop a regulatory program to protect workers from the risk of accidents that involve hazardous chemicals. OSHA promulgated its Process Safety Management Standard (PSM) on February 24, 1992 (57 FR 6356), codified at…

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