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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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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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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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Will there be an increase in turbidity (cloudiness or muddiness) or silt in the streams?
The increased flow from this work is expected to be minimal and should not impact turbidity or silt.
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Will returning the natural flow of water to Sulphur Run disturb areas with sheen?
Conditions in the streams are much improved because of previous cleanup work conducted in 2023. Although oily sheens remain, they are settled in the sediment and do not impact surface water unless disturbed. The increased water flow to Sulphur Run will be minimal and is not expected to disturb sheen…
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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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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 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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When can we access the streams again?
The upcoming cleanup efforts will focus on oil-based compounds which, based on recent sampling, are the only derailment-related contaminants remaining in the creeks. Please obey all posted signage and continue to avoid access in Sulphur and Leslie Runs until further notice.
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What is the status of the cleanup at the site?
In October 2023, it was announced that the excavation work, which removed the known areas of contaminated soil at the derailment site, was complete. The soil double-check work has been ongoing for months and is expected to continue into the fall. The timeline of our expected completion plans for final…
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Why collect the rainwater and snowmelt around the derailment site?
Until excavation work and confirmatory sampling are completed, any wastewater collected from the derailment site is considered a “listed hazardous waste” because it may have come into contact with vinyl chloride or other hazardous contaminants from the derailment. Even though the soil contamination has been removed, our double-check work is…
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What has changed?
For the past several months as the collected wastewater has gone through the system, sample results have shown that the wastewater meets the standards set for vinyl chloride and other derailment-caused contaminants without treatment, meaning it can be disposed of as non-hazardous waste. Testing of the collected wastewater will continue…
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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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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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