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If a renovator disrupts six square feet or less of painted surface per room in several rooms inside one property, does the RRP Rule apply?
No, as long as no prohibited work practices are used and the work does not involve window replacement or demolition of painted surfaces. The exception to the Lead Renovation, Repair, and Painting (RRP) Rule for work that disrupts six square feet or less of painted surface applies to each individual…
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According to your guidelines emergency projects are exempt from some requirements to the extent necessary to respond to the emergency. Does this mean that my firm does not need to be certified and my company doesn't need a certified renovator?
Question : My company only does emergency renovation work. According to your guidelines emergency projects are exempt from the warning sign, containment, waste handling, training, and certification requirements to the extent necessary to respond to the emergency. Emergency renovations are NOT exempt from the cleaning and cleaning verification requirements. Does…
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My company installs new or replacement seamless gutters. We install the gutters using self-tapping screws and the cumulative size of the total number of holes is only a couple of square inches. If the job does not involve sanding, scraping, repainting, repair, replacement or reconditioning of the fascia surface, is it covered by the RRP Rule?
Minor repair and maintenance activities are not subject to the requirements of the Lead Renovation, Repair, and Painting (RRP) Rule . For exterior renovations, minor repair and maintenance activities are those activities that disrupt 20 square feet or 29 less of painted surface, and do not use prohibited practices or…
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What is an "emergency renovation" for purposes of the Lead Renovation, Repair and Painting (RRP) Rule?
Emergency renovations are those performed in response to situations necessitating immediate action to address safety or public health hazards or threats of significant damage to equipment and/or property. The need for immediate action relieves firms from the pre-renovation education requirements. Likewise, emergency renovations are exempt from the warning sign, containment…
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My firm repairs windows in which the glass has been cracked or broken by removing and replacing the sash. For casement windows, we unscrew and remove the hinges on the old window, pull out the old sash, and install the new sash. For double-hung windows, we release the jambliner, pull out the sash with the damaged glass, and install the new sash. We may disturb paint on the hinges and screws, but do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?
Answer: Replacement of a window sash by simply unscrewing hinges or releasing it from a jambliner does not constitute “window replacement” for purposes of the RRP Rule. Therefore, such tasks may fit within the definition of minor repair and maintenance i.e., activities that disturb six square feet or less of…
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My firm removes and replaces garage doors made up of multiple panels, each of which has an exterior painted surface area of <20 square feet. If we disturb the paint on just one of the door panels, is that activity subject to the Lead Renovation, Repair and Painting (RRP) Rule?
An activity that disturbs less than 20 square feet of exterior painted surface and otherwise meets the definition of minor repair and maintenance is not subject to the RRP Rule . However, the RRP Rule provides that when removing painted components, or portions of painted components, the entire surface area…
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