A contractor performs renovation work that disturbs 8 square feet of lead-based paint in a pre-1978 home. What EPA RRP certification is required in Oregon?
Correct Answer
C) EPA RRP firm and renovator certification required
EPA RRP Rule requires certification for any work disturbing more than 6 square feet of lead-based paint per room in pre-1978 housing.
Why This Is the Correct Answer
The EPA Renovation, Repair, and Painting (RRP) Rule requires that both the renovation firm and the individual renovator be EPA-certified when work disturbs more than 6 square feet of lead-based paint per room in pre-1978 housing (or more than 20 square feet on exterior surfaces). At 8 square feet, this threshold is exceeded, so both firm certification and individual renovator certification are mandatory. Oregon enforces the federal RRP Rule through OHA.
Why the Other Options Are Wrong
Option A: Oregon DEQ notification only
Oregon DEQ notification alone is not sufficient. DEQ handles hazardous waste and environmental cleanup — the EPA RRP Rule, enforced through OHA in Oregon, governs renovation work in pre-1978 homes. DEQ notification does not replace certification requirements.
Option B: Homeowner waiver sufficient
A homeowner waiver is not a substitute for EPA RRP certification. Homeowner waivers existed under earlier interpretations but do not eliminate the certified firm and renovator requirements for work above the 6 sq ft threshold. The RRP Rule is a worker and occupant protection standard, not just a consumer choice.
Option D: No certification required - area is too small
8 square feet exceeds the 6-square-foot-per-room trigger. The area is not 'too small' — the correct threshold is 6 sq ft interior / 20 sq ft exterior. Any work above these limits requires full RRP certification regardless of the project's overall scope.
Memory Technique
Remember '6 inside, 20 outside' — 6 sq ft per room indoors triggers RRP; 20 sq ft on exterior. Since 8 > 6, certification is required. Six is less than a standard interior door width — surprisingly small!
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