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If a certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?
Answer: The renovation firm is the entity responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The certified renovator is responsible for preparing the records demonstrating that the renovation was…
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I have a for-profit business where I purchase residential properties and renovate them. Is this type of renovation work on pre-1978 properties covered by the Lead Renovation, Repair, and Painting (RRP) Rule?
Yes. Individuals who buy, renovate and sell pre-1978 residential properties for a profit (i.e., house flippers) or lease pre-1978 residential properties (i.e., landlords), and do the renovation work themselves, are performing renovations for compensation and are therefore subject to all requirements under the RRP Rule . You must be a…
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If a certified inspector or risk assessor determines that a component was installed post-1978 and is therefore free of lead-based paint, can the renovation firm rely on this determination?
Yes, as long as the renovation firm has obtained a copy of the determination. The firm must retain a copy of the determination for three years after completion of the renovation. Question Number: 23002-18218 Find a printable PDF copy of all frequent questions pertaining to lead .
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My local community has formed a “Long Term Recovery Committee”. The committee gathers donations and provides assistance to families via volunteer work crews and/or contracted skilled labor. Are these efforts subject to the RRP Rule?
My local community has formed a “Long Term Recovery Committee” to assist in the rebuilding and recovery efforts following a natural disaster. The committee, which is a coalition of member agencies from the faith community, nonprofit agencies, government programs, businesses and individual donors, gathers monetary and material donations and provides…
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Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?
Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the Lead Renovation, Repair, and Painting (RRP) Rule for a period of three years following completion of the renovation. The RRP Rule does not specify the format in which…
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Is a lead-based paint inspection sufficient to determine compliance with requirements of the RRP rule?
Question: Is a lead-based paint inspection, performed by a certified inspector or risk assessor, that includes a written determination that various building components are free of paint or other surface coatings containing lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight sufficient…
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Is work done by friends, a brother-in-law or volunteers covered by the Lead Renovation, Repair and Painting (RRP) Rule if no one is compensated?
No. The RRP Rule only applies to renovations performed for compensation. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies, and non-profits; and…
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Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?
Yes. The Lead Renovation, Repair, and Painting (RRP) Rule does not specify the format in which these documents must be kept, but they must be available at the work site. Documents are not available if they cannot be viewed. Certified renovators must have with them at the work site copies…
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When repainting rental housing, if the landlord supplies the paint and materials, and the tenant does the labor without receiving money, credit toward rent, or other compensation, does the RRP Rule apply?
No. The Lead Renovation, Repair, and Painting (RRP) Rule only applies to renovations performed for compensation. Question Number: 23002-23856 Find a printable PDF copy of all frequent questions pertaining to lead .
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When testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized lead test kit, must I test every component affected by the renovation?
Answer: Yes. Because certified renovator training does not cover sampling protocols, certified renovators using EPA-recognized lead test kits or performing paint chip sampling to determine the applicability of the RRP Rule must test each and every component that will be affected in order to determine that the RRP Rule does…
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I am an owner/agent for an apartment community built prior to 1978. In 2004, testing of a random sample of units were negative for lead paint but positive for lead dust. With the positive lead dust result, are we required to comply with the RRP Rule?
No. As long as the determination that the units are free of lead-based paint was made by an inspector or risk assessor certified by EPA or by an authorized State or Tribal program, renovations in the building are not covered by the Lead Renovation, Repair, and Painting (RRP) Rule…
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How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for example, to church groups who, as part of their missionary work, are making improvements for low-income residents?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to renovations performed for compensation. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies…
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If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
Answer: The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share the responsibility for retaining and…
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If a property is tested by a certified renovator, inspector, or risk assessor and found to be free of lead-based paint, does any testing need to be done again if work is done on the property several years later?
Where a certified renovator uses an EPA-recognized lead test kit or performs paint chip sampling to determine that a component is free of lead-based paint, or a lead-based paint free determination is made by a certified inspector or risk assessor, firms performing renovations on the same components may rely on…
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If a renovator is only reimbursed for materials, would that be considered compensation?
No. Compensation includes pay for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees of contractors, building owners, property management companies, child-occupied facility operators, State and local government agencies, and non-profits; and rent for target housing or public or commercial building space…
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