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Accidental releases from non-covered processes
Should the owner or operator include accidental releases from processes containing listed substances below the threshold quantity in the five-year accident history required under the hazard assessment provisions of 40 CFR Part 68, Subpart B, and in the incident investigation requirements under 40 CFR Part 68, Subparts C and D…
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Do I have to report accidents that resulted in medical treatment?
I had a release where several people were treated at the hospital and released; they attributed their symptoms to exposure. We do not believe that their symptoms were in fact the result of exposure to the released substance. Do we have to report these as offsite impacts? Yes, you should…
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What is the Tier 2 Vehicle & Gasoline Sulfur Program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The Tier 2 Vehicle and Gasoline Sulfur Program is a landmark program, begun in January 2004, that affects every new passenger vehicle and every gallon of gasoline sold in the U.S. By designing cleaner cars that run on…
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May I use the pamphlet “Protect Your Family From Lead in Your Home” to meet my obligations for pre-renovation education under the RRP Rule?
Answer: No. As of December 22, 2008, only the pamphlet “ Renovate Right ” may be used to comply with the pre-renovation education requirements of the RRP Rule. “ Protect Your Family ” is still available for use during real-estate sales and lease transactions and for general information. Question Number…
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My firm is replacing windows in a condominium. Is this type of exterior work considered work in a common area, and if so, must other owners and occupants be informed about the job?
Exterior renovations of multi-unit target housing are considered renovations of a common area. A common area is a portion of a building that is generally accessible to all residents or users of the building. Renovations in common areas of multi-unit target housing, such as condominiums, must be performed in accordance…
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Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the owner or occupant. What is the difference between a certificate of mailing and certified mail?
A certificate of mailing is a receipt showing evidence of mailing, while certified mail provides proof of mailing and delivery of mail. When using the certificate of mailing option, no record is kept at the mailing office and a receipt is not obtained when mail is delivered to the addressee…
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When multiple contractors are involved in a single renovation, must every contractor provide pre-renovation education? Can a certified firm assign its responsibility to a property management company?
All firms performing, offering or claiming to perform renovations are responsible for ensuring compliance with the pre-renovation education requirements of the RRP Rule. However, it is unnecessary for the same notifications and information to be given out repeatedly during a single renovation. Accordingly, a firm may discharge the task by…
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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 does the accident history's five-year period begin?
The hazard assessment requirements under 40 CFR Part 68, Subpart B include provision of a five-year accident history, as specified at §68.42. When does the five-year period to be reported in the accident history begin? The five-year accident history must include information on all accidental releases from covered processes meeting…
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What is the definition of injury?
Under the hazard assessment requirements of 40 CFR Part 68, Subpart B, an owner or operator must document a five-year accident history including 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…
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Do Program Level 1 processes need to do five-year accident histories?
What is the relationship between the accident history criteria for Program 1 and the five-year accident history? If my process is eligible for Program 1, do I still need to do a five-year accident history? The five-year accident history is an information collection requirement that is designed to provide data…
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Can a refiner or importer use gasoline sulfur test methods other than ASTM D 2622-98, especially for sulfur levels of 10 ppm and less?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The rule designates ASTM D 2622 as the benchmark test method by which compliance will be determined, and that is the test that the Agency typically will use in establishing compliance. However, the rule does permit alternative test…
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There is significant difference between "refiner" and "refinery". Portions of the regulations use "refiner" where "refinery" is the appropriate term. While it may be clear from the context that "refinery" is meant, text should be changed to avoid any poss
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . We agree with the comment and intend to make these clarifications in a future rulemaking. These clarifications would not affect the regulatory requirements in the current final rule.
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I am planning on sending the pamphlet via certificate of mailing to a tenant who occupies a unit scheduled to be renovated. Does the tenant’s name need to be addressed on the mailing, or is it acceptable to address the envelope to Attn: Tenant/Occupant?
Answer: The tenant’s name and address must be indicated on the mailing. The RRP Rule requires a renovator to provide the “Renovate Right” pamphlet to an adult in each unit. Therefore, the name and address of an adult occupant in each unit must be indicated on the mailing. The renovator…
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If working in target housing occupied by persons who are blind, how should a firm comply with the pre-renovation information distribution requirements?
EPA’s pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools is currently not published in a Braille format. In addition to distributing the regular pamphlet, a firm working in such an environment should take extra precaution to ensure that the owner and occupants are…
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