EPA's Most Asked RRP Questions

Ever wonder if other colleagues have the same questions you have about RRP?  Here's some of this month's most  frequently asked questions: Q: If I mist and HEPA vacuum the plastic sheeting used by my firm for interior containment, can I move and re-use plastic sheeting on the same day and job? A: No.  The Rule does not contemplate a permissible method of moving and re-using plastic sheeting used for interior containment. Our comments:  Maybe we should invest in plastic sheeting. Q: Is it a violation of the Renovation, Repair, and Painting Rule (RRP) for a homeowner to hire a firm that is not certified? A: The Renovation, Repair, and Painting Rule (RRP) does not impose requirements on homeowners, unless they are performing renovations in rental space. However, the hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered renovation. Our Comments: It appears to many certified contractors that this is how they are losing business to non-certified firms. Q: Do test results from a certified renovator using an EPA recognized test kit (40 CFR § 745.83) become an official part of the lead-based paint testing record for that house thus negating the need for a certified lead inspector or certified lead risk assessor to conduct the inspection in that area of the house? Can a certified renovator conduct a complete lead-based paint inspection and give the property owner as an inspection report? A: The results of paint testing using test kits are part of the official lead-based paint testing record for a home, and must be disclosed under EPA's Real Estate Disclosure regulation (40 CFR part 745, subpart F).  However, EPA's regulations only provide for a certified inspector or risk assessor to conduct a lead-based paint inspection and to prepare a lead-based paint inspection report.  Thus, allowing renovators to test components does not negate the requirement that a certified inspector or risk assessor follow the requirements set forth in § 745.227(b) when conducting a lead-based paint inspection. Our Comments:  If you're not certified as an inspector or risk assessor, then your testing will not qualify as a lead-based paint inspection report.  Check out the "requirements" under the referenced section 745.277 Feel free to share your comments!

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