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A home sustained flooding as a result of a hurricane. Once the flood water recedes, my firm must make the necessary renovations. How do the record keeping requirements apply to an emergency renovation?
Emergency renovations (other than interim controls performed in response to a child with an elevated blood lead level) are exempt from the training, certification, sign posting, waste handling and containment requirements of the Lead Renovation, Repair and Painting (RRP) Rule only to the extent necessary to respond to the emergency…
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Do states require extra Tier II information?
Do states require additional information on the Tier II report? How can I find out about the state data requirements? Some states do want additional Tier II information; contact your state Tier II administrator to learn specific details. Tier2 Submit includes fields for the additional information requested or required by…
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No Street Address Availability Tier II Reporting
Pursuant to 40 CFR 370.42(d) , Tier II chemical inventory information must include the complete name and address of the location of the facility (including the full street address or state road, city, county, State and zip code), latitude and longitude. If a facility does not have a street address…
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Does an ethanol producer who sells undenatured ethanol to a U.S. importer who denatures it at the port need to register with EPA under RFS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RFS regulations specify that foreign producers of ethanol for use in transportation fuel, heating oil or jet fuel for import to the US who do not add denaturant to their product, must register under RFS. See 80.1450(b)…
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Does the RRP rule apply to contractors working on homes damaged by a hurricane or other natural disaster?
Damage from a major storm or other natural disaster could result in the need for emergency renovations. Certain requirements of the RRP Rule do not apply to emergency renovations, which are renovation activities that were not planned but result from a sudden, unexpected event that, if not immediately attended to…
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Tier2 Submit software and confidential chemical location information
When using EPA’s Tier2 Submit software to comply with the annual Hazardous Chemical Inventory reporting requirement under the Emergency Planning and Community Right-to-Know Act (EPCRA) §312, how can a person withhold confidential chemical location information from disclosure to the public? In order to fulfill the proper reporting under EPCRA, a…
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Entering Alternative Storage Types and Pressure and Temperature Conditions on Tier II Form
EPA provides a list of storage types and conditions for pressure and temperature in the instructions for the paper Tier II form and as dropdown menus in Tier2 Submit. Are facilities required to use the storage types and conditions that EPA provides, or can facilities provide different values? Facilities are…
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Attaching Site Plan Using Tier2 Submit
Tier2 Submit does allow a user to attach and submit a site plan with the Tier II inventory information. However, before using Tier2 Submit to submit a site plan, the facility should check with the relevant State or Tribal Emergency Response Commission ( SERC or TERC ) and/or their state…
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Range Code or Specific Weight for Maximum Amount and Average Daily Amount on Tier II Form
When submitting Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 Tier II reports, does the owner or operator of the facility need to enter a specific weight in pounds for the maximum amount and the average daily amount of a certain hazardous chemical present at the facility, or should…
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What are the requirements for a foreign producer who wishes to generate RINs for the renewable fuel they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Foreign producers who plan to generate RINs must register and conduct a third-party engineering review pursuant to section 80.1450. Additionally, such foreign producers must meet the requirements in section 80.1466 prior to generating any RINs for their fuel…
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Tier2 Submit validation error due to incorrect CAS number
What do I do if I get a validation error in Tier2 Submit due to an incorrect Chemical Abstracts Service (CAS) number? Your CAS number should be typed exactly as it appears on the substance's SDS. Review your safety data sheet (SDS) to see if the CAS number was typed…
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Completing Tier II Forms When Information Has Not Changed
Pursuant to 40 CFR 370.42(c) and (r) , an owner or operator submitting federal Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II inventory information must indicate if the facility or chemical information is identical to that submitted last year. If the facility or chemical information is the same as…
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How do I know if a child has an Elevated Blood Level (EBL) prior to my work if he or she hasn't had their blood lead tested recently?
Answer: It is never the renovation firm’s responsibility to determine whether a child has an elevated blood lead (EBL) level. Question Number: 23002-16822 Find a printable PDF copy of all frequent questions pertaining to lead .
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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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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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