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Determining frequency of coordination activities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? Ultimate responsibility…
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Who Must Develop an Emergency Response Program?
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date…
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Does the Fee Rule for Abatement and RRP Programs apply nationwide?
Answer: The rule applies only in those states and tribes without their own authorized lead programs. Currently, EPA implements the Lead-based Paint Activities program in 11 states and the Lead Renovation, Repair, and Painting Rule in 36 states. Question Number: 23002-33305 Find a printable PDF copy of all frequent questions…
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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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Where can I get more information on the Fee Rule for Lead Abatement and Lead Renovation, Repair and Painting (RRP) Programs?
Answer: You can find fee rule information at Lead Renovation, Repair and Painting Program Rules . You can also contact the National Lead Information Center at 1-800-424-LEAD . Question Number: 23002-33298 Find a printable PDF copy of all frequent questions pertaining to lead .
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My firm drills a series of 1/2-inch diameter holes in sheet rock to dry it out where rooms have been flooded. Is drilling these holes a prohibited practice?
No. The requirement for HEPA exhaust control does not apply to the use of all power tools. Specifically, HEPA exhaust control is not required when using a power drill to drill holes in sheetrock. When using a power drill with a drill bit to cut through sheetrock, the speed associated…
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Why have the fees for Lead-Based Paint Activities program decreased since they were first implemented in 1999?
Since 1999, EPA has made substantial changes in the way it administers its accreditation and certification program. The transition to the automated federal Lead-based Paint Program (FLPP) database and the associated centralized data processing has resulted in lower overall costs of the Lead-Based Paint Activities program . Question Number: 23002-33300…
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Remote coordination with local authorities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). If a stationary source is in a remote location and in-person annual coordination is deemed impractical, can…
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Emergency Response Coordination Activities Effective Date
The RMP Amendments finalized on January 13, 2017 included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because…
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What costs does EPA incur that must be recovered by the fees under the Fee Rule for Abatement and RRP Programs?
Answer: The fees recover EPA's costs for processing applications, enforcing program requirements, and administrative activities such as maintenance of the central database and administering certification examinations. Question Number: 23002-33303 Find a printable PDF copy of all frequent questions pertaining to lead .
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How do RRP requirements apply to pressure washing? What containment and other preparation are required?
Pressure washing is not a prohibited practice under the Lead Renovation, Repair, and Painting (RRP) Rule . Pressure washing is subject to the same containment requirements as other permissible work practices. Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in…
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Why does EPA charge fees for accreditations and certifications?
As specified in the Toxic Substances Control Act (TSCA), EPA must establish and implement a fee schedule to recover to the U.S. Treasury the Agency's costs of administering and enforcing the standards and requirements applicable to lead-based paint training programs and contractors. Question Number: 23002-33304 Find a printable PDF copy…
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Types of Information Relevant for Response Planning
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency…
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Is anyone exempt from paying fees under the Fee Rule for Abatement and Renovate, Repair and Painting (RRP) Programs?
Yes. TSCA section 402(a)(3) exempts state, local government and non-profit training programs from federal accreditation fees. However, it does not provide an exemption for the certification fees of firms or individuals. Question Number: 23002-33302 Find a printable PDF copy of all frequent questions pertaining to lead .
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What is EPA's rule to: (1) lower fees for the Lead-Based Paint Activities Programs (for abatement, i.e., total removal) and (2) set fees for the 2008 Lead Renovation, Repair and Painting (RRP) Program?
In March 2009, EPA issued a rule to address fees for its lead-based paint programs. The rule addresses two areas: first, it modifies and lowers the existing fees for EPA's Lead-based Paint Activities regulations that govern lead abatement, inspection and risk assessment activities; second, it establishes fees to cover costs…
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