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May I generate RINs that I produced and sold for non-road use in the past so that I can reinstate those RINs under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.1426(c)(2) provides that RINs are assigned to a volume of renewable fuel when ownership of the RIN is transferred along with ownership of the volume of renewable fuel. A comparable provision appear in the RFS1 regulations, at…
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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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In a situation where an importer leases tankage from another company, e.g., from a for-hire terminal, who must register such import facility, the company that owns the terminal, the importer that leases the tankage, or both?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.2(r), an importer is defined as "a person who imports gasoline or gasoline blending stocks or components from a foreign country into the United States...." Accordingly, it is the importer of the gasoline, and not the…
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If my fuel is already registered with the Fuels and Fuel Additives program under 40 CFR Part 79, do I still need to register with the RFS2 program under 40 CFR Part 80?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Even if your fuel or fuel additive is already registered under 40 CFR Part 79, there are additional registration requirements for parties regulated under the RFS2 program, as specified in 40 CFR 80.1450.
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May I generate RINs for renewable fuel that I produced and sold for non-motor vehicle use in the past so that I can reinstate those RINs under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. RINs that were previously generated in 2009 and 2010 may be reinstated if they were retired for non-motor vehicle use. However, RINs may not be generated for renewable fuel produced in the past in order to retire…
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Once I register my fuel for the RFS2 program under §80.1450, do I still need to register my fuel under 40 CFR Part 79?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Renewable fuels intended for use or used in motor vehicles are required to be registered under 40 CFR part 79 prior to any introduction into commerce. Manufacturers of renewable fuels and fuel additives not registered under part…
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Does EPA consider it a conflict of interest for a third-party company to assist a group of renewable fuel producers and importers of renewable fuel to help meet the requirements of the re-registration and engineering review pursuant to section 80.1450?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA does not restrict a renewable fuel producer or an importer of renewable fuel from seeking a third-party company to assist them in meeting the re-registration and engineering review requirements pursuant to section 80.1450. The renewable fuel producer…
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Will common carriers be required to register their transport trucks as oxygenate blending facilities?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Normally, only the owner of the gasoline produced at an oxygenate blending operation must register as an oxygenate blender. If a common carrier blends gas in trucks that it owns it must meet all of the requirements for…
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Is the licensed professional engineer conducting the engineering review required to perform the site visit in person, or can they delegate the site visit to another person who maybe assisting them in the engineering review?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Pursuant to §80.1450(b)(2), all verifications must be performed by the licensed professional engineer conducting the engineering review. This requirement includes conducting the site visits. The licensed professional engineer conducting the engineering review must perform the site visits to…
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In addition to 2009 RINs, may a party reinstate 2008 and 2010 RINs that were retired for non-road use under RFS1?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Pursuant to §80.1429(g), any 2009 RINs that were retired for non-motor vehicle, heating oil or jet fuel use under RFS1 may be reinstated under RFS2. The regulations do not allow 2008 RINs to be reinstated. Since RFS1 RINs…
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