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Change of owner and RMP facility ID number
If a facility is sold to a new owner, does it keep its' original RMP Facility ID number? Yes. The facility will keep the ID number assigned by EPA.
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Facility ID number and re-registering a facility
If a facility deregisters, then reregisters, should the facility use the original RMP Facility ID or will it be assigned a new ID? The facility should use the original ID assigned by EPA.
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Resubmission of RMP for a facility that previously deregistered
A covered facility deregisters its RMP because it no longer has more than a threshold quantity of a regulated substance in a covered process. If the facility becomes subject to the CAA §112(r) risk management program regulations at a later date and submits a new RMP, should the facility submit…
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RMP Records Maintained Onsite
Pursuant to 40 CFR Part 68, Subpart G, the owner or operator of a stationary source subject to the risk management program regulations in Part 68 must develop and submit a risk management plan (RMP). Does the owner or operator have to maintain a written copy of the RMP on…
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I have not seen a reference to the EPA CDX system. Is the CDX system already established or can we submit reports in our choice of electronic formats?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The Central Data Exchange (CDX) is an established portal through which electronic data are submitted. All registered parties will have to first register with CDX in order to receive a CDX registration number. More information may be found…
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Do I have to register to use CDX and is this a separate registration process?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . You will have to register with CDX. (Registering with CDX is not the same as registering under regulation Section 80.1150.) Instructions are available via our Reporting for Fuel Programs web site. Question and Answer was originally posted at…
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Change of Ownership
If a facility that is subject to the risk management program regulations in 40 CFR Part 68 is sold to another owner, is the facility required to make a correction or a full update of its risk management plan (RMP)? If there are no changes in the covered operations at…
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RMP*eSubmit preparer access
How does a new Preparer get access to a Risk Management Plan (RMP) via RMP*eSubmit? First, the person must register with CDX. To register with CDX, go to https://cdx.epa.gov/ and complete the registration process for a Risk Management Plan “Preparer”. Once set up as a “Preparer”, the Certifying Official needs…
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Can renovator training courses, both initial and refresher courses, be taught online or via distance learning?
Answer: The final Renovation, Repair and Painting regulation, like the abatement program, permits the use of alternative training techniques (e.g., video training, computer-based training) as a supplement to the hands-on skills assessment, or as a substitute for the lecture portion of the training course requirements outlined in § 745.225. In…
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If a remodeling company that is a certified firm uses all contractual workers rather than employees, must each contractual worker be a certified renovator, or can the workers be trained on the job by a certified renovator employed by the firm?
Firms hiring contractual workers may provide the certified renovator that oversees the renovation project and provides on-the-job training to contractual workers and other non-certified workers. Question Number: 23002-18377 Find a printable PDF copy of all frequent questions pertaining to lead .
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Is the certified renovator assigned to a specific project responsible for the work practices of other contractors on the project if the certified renovator is an employee of the general contractor of the project?
All firms performing renovations must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that takes responsibility for ensuring…
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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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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 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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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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