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When and under what conditions will a LBP Project Designer be required?

Upon a review of the EPA and HUD requirements, we find that there is not a simple answer to this question. In previous draft rules, HUD and EPA recommended that those abatement projects above a certain "threshold size" of 10 units require a Project Designer. However, no recommendations of size were included in the final HUD/EPA requirements. The EPA now simply states that a project designer must be used in "large scale projects" as determined by the property owner (See 40 CFR Part 745.225(d)(4)).

Will an abatement notification form be required in advance for small, short-term projects?

Yes. Abatement notification forms are required at least five business days prior to commencement of abatement activities as established in OAC 252:110-5-1(4). Business day is defined as Monday through Friday with the exception of State holidays. Please be advised that unless an alternative agreement is negotiated, the five business day window is a requirement.

In the same sense a risk assessor can perform the same duties as an inspector, can a supervisor perform the same duties as an abatement worker?

Yes. A supervisor can perform the duties of an abatement worker. However, an abatement worker cannot oversee or supervise himself on a project. An individual certified as a supervisor can oversee himself on a project.

What is the difference between Lead-based Paint (LBP) abatement and renovation?

Abatements, inspections, and risk assessments are all examples of LBP activities that can only be performed by highly-trained and certified LBP professionals. Their work is primarily focused on LBP. On the other hand, renovations are performed in all sorts of housing, and are only regulated when done in pre-1978 situations. RRP rules are designed to prevent increasing the risk of disturbed LBP by companies and workers that do not routinely work with LBP.

What is on-going monitoring?

On-going monitoring consists of visual surveys conducted by property owners (or manager) and re-evaluations by risk assessors. On-going monitoring schedules will vary according to the level of Lead hazards identified in the dwelling and Lead hazard controls performed. The HUD Guidelines, Chapter 6, contains information and a table to assist LBP professionals in selecting on-going monitoring schedules and performing re-evaluation.

When is on-going monitoring required?

According to 40 CFR 745.227, Risk Assessors must include on-going monitoring schedules in risk assessment reports when they recommend encapsulant or enclosures as LBP abatement methods. LBP Supervisors must include on-going monitoring schedules in post LBP abatement reports when encapsulant or enclosures have been used as LBP abatement methods.

What are minor repair and maintenance activities?

252:110-15-1. Definitions
"Minor repair and maintenance activities" are activities, including minor heating, ventilation or air conditioning work, electrical work, and plumbing, that disrupt 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or restricted by 40 CFR § 745.85(a)(3) are used and where the work does not involve window replacement or demolition of painted surface areas.

When removing painted components, or portions of painted components, the entire surface area removed is the amount of painted surface disturbed. Jobs, other than emergency renovations, performed in the same room within the same 30 days must be considered the same job for the purpose of determining whether the job is a minor repair and maintenance activity.

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