C33 Regulations and Procedures for Lead-Based Paint Abatement 2 — Questions and Answers
Question 1: Under EPA's RRP Rule, a firm performing renovation that disturbs lead-based paint in pre-1978 housing must be certified by whom?
- The local building department
- EPA or an EPA-authorized state program (Correct answer)
- OSHA
- The paint manufacturer
Correct answer: EPA or an EPA-authorized state program
The EPA RRP Rule requires firms to be certified by EPA or an EPA-authorized state program before performing work that disturbs lead-based paint in target housing.
The EPA RRP Rule requires firm certification by EPA or an authorized state. California has its own authorized program through the Department of Public Health (CDPH). Firm certification requires having at least one certified renovator on each job. Working without certification can result in penalties of up to $37,500 per day per violation.
Question 2: What is the minimum square footage of interior painted surface that must be disturbed before the RRP Rule applies?
- 2 square feet
- 6 square feet (Correct answer)
- 12 square feet
- 20 square feet
Correct answer: 6 square feet
The RRP Rule applies when renovation activities disturb more than 6 square feet of interior lead-based paint per room.
The RRP Rule applies to renovation activities disturbing: 6 square feet of interior paint per room, or 20 square feet of exterior paint per project. These thresholds are cumulative. If testing confirms the paint is NOT lead-based, the RRP Rule does not apply regardless of surface area.
Question 3: Under the RRP Rule, which lead paint testing method provides immediate results at the job site?
- Laboratory X-ray fluorescence
- Certified inspector visual assessment only
- EPA-recognized test kits (chemical spot tests) (Correct answer)
- Gas chromatography mass spectrometry
Correct answer: EPA-recognized test kits (chemical spot tests)
EPA-recognized test kits provide immediate on-site results, allowing renovators to determine the presence of lead-based paint without laboratory analysis.
EPA-recognized test kits are chemical spot tests that change color in the presence of lead. A negative result can be used to determine that lead-based paint is NOT present, exempting work from RRP requirements. XRF analyzers provide more precise results but require a certified inspector. Laboratory analysis is the most definitive but takes days.
Question 4: What post-renovation cleaning verification procedure is required under the RRP Rule for interior surfaces?
- Visual inspection only
- Dust wipe sampling analyzed by a laboratory
- Cleaning verification using wet disposable cloths compared to the EPA cleaning verification card (Correct answer)
- Air monitoring for lead particles
Correct answer: Cleaning verification using wet disposable cloths compared to the EPA cleaning verification card
The RRP Rule requires cleaning verification using wet disposable cleaning cloths compared to the EPA cleaning verification card.
After renovation work: (1) Pick up visible chips, (2) HEPA vacuum all surfaces, (3) Wet mop/wipe all surfaces, (4) After drying, wipe each surface with a wet cloth and compare to the EPA cleaning verification card. If the cloth is lighter than the card, the surface passes. Optional clearance by a certified inspector using dust wipe sampling is also acceptable.
Question 5: Under California law, who must receive the EPA pamphlet 'Renovate Right' before renovation work begins in pre-1978 housing?
- Only the contractor's employees
- The property owner and, for rental properties, the tenants of affected units (Correct answer)
- The local fire department
- The nearest hospital
Correct answer: The property owner and, for rental properties, the tenants of affected units
The RRP Rule requires the 'Renovate Right' pamphlet be distributed to the property owner and tenants before renovation begins.
Before starting renovation in pre-1978 housing, the certified renovator must distribute the 'Renovate Right' pamphlet to the owner and adult occupants/tenants. For common areas in multi-family housing, notice goes to all affected units. Distribution must be documented with a signed acknowledgment or certificate of mailing.
Question 6: What is the definition of 'lead-based paint' under federal regulations?
- Any paint containing detectable levels of lead
- Paint with lead content equal to or exceeding 1.0 mg/cm2 or 0.5% by weight (Correct answer)
- Paint manufactured before 1960
- Only paint with visible white lead pigment
Correct answer: Paint with lead content equal to or exceeding 1.0 mg/cm2 or 0.5% by weight
Federal regulations define lead-based paint as paint with lead content equal to or exceeding 1.0 mg/cm2 or 0.5% by weight (5,000 ppm).
Under HUD and EPA regulations, lead-based paint is paint containing lead equal to or exceeding 1.0 mg/cm2 (by XRF) or 0.5% by weight / 5,000 ppm (by laboratory analysis). Paint below these thresholds is not classified as lead-based, even if it contains some lead.
C33 Regulations and Procedures for Lead-Based Paint Abatement 2
Under EPA's RRP Rule, a firm performing renovation that disturbs lead-based paint in pre-1978 housing must be certified by whom?