My company only does emergency renovation work. According to your guidelines emergency projects are exempt from the warning sign, containment, waste handling, training, and certification requirements to the extent necessary to respond to the emergency. Emergency renovations are NOT exempt from the cleaning and cleaning verification requirements. Does this mean that my firm does not need to be certified and my company doesn't need a certified renovator? Does this also mean that my employees would only have to be trained on cleaning and cleaning verification guidelines?
No. Emergency renovations (other than interim controls performed in response to a child with an elevated blood lead level), are exempt from the training, certification, sign posting, waste handling and containment requirements of the RRP Rule only to the extent necessary to respond to the emergency. For example, most property management companies that do their own maintenance are likely to have at least one trained and certified renovator on staff to perform renovations, so these companies should be able to comply with the training and certification requirements on all renovations. A firm that performs only emergency renovation work by definition can anticipate the need to perform emergency renovations and should be able to comply with the training and certification requirements of the RRP Rule.