Answer: While components to be reused rather that disposed of are not considered waste for the purposes of the Lead Renovation, Repair, and Painting (RRP) Rule, it is likely that, even if they do not contain lead-based paint, they are contaminated with dust or debris from the project. The renovation firm must use precautions to ensure that these components are free from dust and debris before they are removed from the work area. EPA also recommends that these materials be stored on-site or transported off-site in a way that prevents access to dust and debris or release of dust and debris. 

Question Number: 23002-13864

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