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Displaying 226 - 237 of 237 results
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When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and completely enclose the interior area in which I physically work. If these barriers are set up at a distance less than six feet from the perimeter of the work surface, must I still extend the containment on the floor beyond the vertical barrier to meet the six-foot requirement?
Answer: No, provided that the vertical containment system consists of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls (40 CFR § 745.85(a)(2)(i)(D)). This type of vertical containment acts as the functional equivalent of a wall for…
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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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The Lead Renovation, Repair and Painting (RRP) Rule provisions require exterior containment. At what point is the wind too strong to allow work to continue?
The work practices for exterior projects are based on a performance standard -- the certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. The certified…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, what type of container is adequate for on-site storage of debris?
At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…
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In a typical co-operative apartment building, occupants do not own the individual units; rather they “own” an undifferentiated share in the entire building and then “rent” back a specific unit from the co-operative corporation. Similarly, in a typical condominium building, owners of individual units jointly own the common areas of the building. For purposes of the pre-renovation education requirements, who are the “owners” in such situations?
Answer: EPA recognizes that co-operative apartments (“co-ops”) and condominiums (“condos”) can be structured in a variety of ways. For example, in the case of co-ops, a corporation (sometimes referred to as a “co-op association”) is often established and owns all the units and common areas comprising the co-op; in such…
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When a unit is not occupied by its owner, 40 CFR 745.84(a)(2) states that the “Renovate Right” pamphlet must be provided to an adult occupant prior to beginning any covered renovation activities. What does EPA consider an “adult” for these purposes?
Answer: For purposes of receiving the pamphlet pursuant to the pre-renovation education requirements, EPA believes that “adult” means a person who has reached 18 years of age. Question Number: 23002-33372 Find a printable PDF copy of all frequent questions pertaining to lead .
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Must notifications for common area renovations always be provided to every unit in a multifamily housing complex?
Answer: Not necessarily. When renovations are to be performed in common areas of multi-family housing (i.e., those portions of the property generally accessible to all residents/users), the RRP Rule requires that each “affected unit” be notified in writing. See 745.84(b)(2). As a general matter, all units in the housing are…
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What is the “work area?”
Answer: The “work area” is the area established by a certified renovator to contain the dust and debris generated from a renovation. In other words, the work area is defined by the containment measures established by the certified renovator. While a renovator has some discretion in setting up a sufficient…
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Will a renovator working for a firm that has submitted a certification application to EPA but has not received its certification be allowed to work on pre-1978 properties assuming compliance with all other requirement of the RRP Rule?
No. Beginning April 22, 2010, no firm may perform, offer or claim to perform renovations covered by the RRP Rule without certification from EPA. Question Number: 23002-25193 Find a printable PDF copy of all frequent questions pertaining to lead .
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A homeowner is acting as their own general contractor and hires multiple companies to do the work. Would each business be required to follow the Lead Renovation Repair and Painting (RRP) Rule and assign certified renovators to supervise their portion of the work including separate containment?
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 tasks…
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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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May the renovator training provider give the exam orally?
Yes. There is no requirement that the course test be conducted in writing. Each individual must successfully complete the hands-on skills assessment and receive a passing score on the course test to pass any course. Question Number: 23002-19573 Find a printable PDF copy of all frequent questions pertaining to lead…
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