RRP Lead Paint Training Video

To view the most recent FAQ for the EPA’s RRP program, click the link below for a PDF version from the EPA website.

Source: http://epa.gov/lead/pubs/rrp-faq.pdf

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Renovation, Repair, and Painting (RRP) Rule
Frequent Questions
March 26, 2012
About the Lead Frequent Questions and Answers: This document presents the Agency’s preliminary
response to the issues presented in these questions. Accordingly, it is a living document and the
answers may be periodically revised and updated. Because the answers are subject to change, it is
recommended that users check back frequently and visit http://www.epa.gov/lead/pubs/rrp-faq.pdf for the
most up-to-date responses. The responses are intended solely for guidance and do not alter any
statutory or regulatory requirements. The document does not supersede any statutory or regulatory
provisions. Because the preliminary guidance provided in this document often addresses the very specific
circumstances stated in each question, the reader should also consult other applicable documents (e.g.,
15 U.S.C. 2681 et seq., 40 C.F.R. 745.80 et seq., the Preamble to the Final Rule, etc.). These responses
do not necessarily bind EPA or outside parties. EPA evaluates circumstances on a case by case basis,
and these answers may not apply to a specific situation.
Table of Contents
General Information about Lead ……………………………………………………………………………………………………. 2
Testing for Lead …………………………………………………………………………………………………………………………. 5
General Information about the Lead Renovation, Repair, and Painting (RRP) Rule …………………………… 10
Renovations Covered by the RRP Rule ………………………………………………………………………………………… 17
In General …………………………………………………………………………………………………………………………….. 17
Definition of “Renovation” ………………………………………………………………………………………………………… 19
Minor Repair and Maintenance Activities …………………………………………………………………………………… 25
Renovations for Compensation ………………………………………………………………………………………………… 29
Target Housing ……………………………………………………………………………………………………………………… 31
Child-Occupied Facilities …………………………………………………………………………………………………………. 36
Testing Painted Components …………………………………………………………………………………………………… 37
Emergency Renovations …………………………………………………………………………………………………………. 39
Opt-Out Provision ………………………………………………………………………………………………………………….. 40
Pre-Renovation Education ………………………………………………………………………………………………………….. 42
Work Practice Standards ……………………………………………………………………………………………………………. 51
Occupant Protection ………………………………………………………………………………………………………………. 51
Containing the Work Area ……………………………………………………………………………………………………….. 51
Prohibited and Restricted Practices ………………………………………………………………………………………….. 58
Waste from Renovations …………………………………………………………………………………………………………. 59
Cleaning the Work Area ………………………………………………………………………………………………………….. 60
Cleaning Verification ………………………………………………………………………………………………………………. 63
Recordkeeping and Reporting Requirements ………………………………………………………………………………… 64
Firm Certification ………………………………………………………………………………………………………………………. 66
Lead-Safe Certified Firm Logo …………………………………………………………………………………………………….. 76
Renovator Certification and Training ……………………………………………………………………………………………. 78
Authorized State and Tribal Programs ………………………………………………………………………………………….. 83
Training Provider Accreditation ……………………………………………………………………………………………………. 84
Enforcement and Inspections……………………………………………………………………………………………………… 86
Information for Do-It-Yourselfers ………………………………………………………………………………………………….. 90
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General Information about Lead
Question (23002-22416)
What is lead?
Answer
Lead is a toxic metal that was used for many years in products found in and around our homes. Lead
also can be emitted into the air from motor vehicles and industrial sources, and lead can enter drinking
water from plumbing materials. Lead-based paint is present in many homes built before 1978.
The federal government banned the use of lead-based paint in housing in 1978. To learn more about
lead, visit www.epa.gov/lead.
Question (23002-24471)
Where is lead found?
Answer
Many homes built before 1978 have lead-based paint. In general, the older your home, the more likely it
has lead-based paint. Soil around a home can contain lead from sources like deteriorated exterior paint,
past use of leaded gas in cars, or from past renovation activities. Household dust can pick up lead from
deteriorating lead-based paint, from past renovation projects, or from soil tracked into a home. If you
work with lead, you could bring it home on your hands or clothes. It is important to shower and change
clothes before going home. Launder your work clothes separately from the rest of your family’s clothes.
To learn more about sources of lead, visit http://www.epa.gov/opptintr/lead/pubs/leadinfo.htm#where.
Question (23002-18139)
I thought lead-based paint had been phased out. How many homes still contain lead-based paint?
Answer
HUD’s National Survey of lead and Allergens in Housing estimated that 38 million permanently occupied
housing units (40% of all housing units) in the United States contain some lead-based paint that was
applied before the residential use of lead-based paint was banned in 1978. “Housing units” include
single-family homes, manufactured housing, and multi-unit dwellings like apartments. Vacant housing,
group quarters (e.g., prisons, hospitals, and dormitories), hotels, motels, and other short-term housing,
military bases, and housing where children are not permitted to live (e.g., housing designated exclusively
for the elderly and those with zero-bedroom units) are not included in this number. More information on
these statistics is available from HUD.
Question (23002-21128)
What are some of the health effects of lead?
Answer
Lead is known to cause a range of health effects, from behavioral problems and learning disabilities, to
seizures and death. Children six years old and under are most at risk from exposure lead-based paint
because they crawl on the floor and they put their hands and other items which can have lead-based
paint dust on them into their mouths. Because their bodies are still growing, children tend to absorb more
lead than adults.
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Children exposed to lead can suffer from:
 Lowered IQ
 Damage to the brain and nervous system
 Learning and behavioral difficulties
 Slowed growth
 Hearing problems
 Headaches
Adults can suffer from:
 Reproductive problems (in both men and women)
 High blood pressure and hypertension
 Nerve disorders
 Memory and concentration problems
 Muscle and joint pain
To learn more about health effects of lead, visit http://www.epa.gov/lead/pubs/leadinfo.htm#health
Question (23002-23458)
What should I do if I am concerned about my family’s exposure to lead?
Answer
A blood test is the only way to find out whether you or a family member already has lead poisoning. Call
your doctor or local health department to arrange for a blood test. You can protect your family every day
by:
 Regularly cleaning floors, window sills, and other surfaces.
 Washing children’s hands, bottles, pacifiers, and toys often.
 Making sure children eat a healthy, nutritious diet consistent with the USDA’s dietary guidelines.
 Wiping off shoes before entering the house.
 Using an EPA-certified firm for renovations, or if you are doing the renovation yourself, using
lead-safe work practices (see http://www.epa.gov/lead for more information).
Question (23002-21997)
What information can I get about lead-based paint in a home before I buy or rent it?
Answer
Many houses and apartments built before 1978 have some lead-based paint. Lead from paint, chips, and
dust can pose serious health hazards if not taken care of properly. Federal law requires that individuals
receive certain information before renting or buying pre-1978 housing. Sellers and landlords must:
 Disclose information on known lead-based paint and lead-based paint hazards in the housing
being sold or rented;
 Provide buyers and renters with any available records or reports pertaining to lead-based paint or
lead-based paint hazards in the housing; and
 Provide buyers and renters with a copy of the pamphlet entitled “Protect Your Family from Lead in
Your Home.”
In addition, sellers must give potential buyers an opportunity to check the home for lead-based paint or
lead-based paint hazards. To learn more about the lead disclosure rule visit

http://www.epa.gov/lead/pubs/leadbase.htm.

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Question (23002-32411)
Building material reuse stores sometimes accept older materials which have been coated with lead-based
paint and could pose a lead poisoning hazard. In particular, older windows and doors are likely to contain
lead-based paint, and this paint can present very high risks due to friction and impacts causing the paint
to deteriorate and generate lead dust. How can employees of these stores and their customers manage
lead hazards associated with these older building materials?
Answer
As a preliminary matter, your state may have laws or regulations addressing the management, handling
or sale of materials containing lead-based paint. Therefore, building material reuse stores should contact
both their state health department (http://www.cdc.gov/mmwr/international/relres.html) and state
environmental agency (http://www.cicacenter.org/hwrlnew.cfm) for more specific direction. In addition to
complying with all state or local law and regulations, EPA recommends the following practices to help
minimize lead exposure to employees, volunteers, and customers.
At a minimum, EPA suggests that reuse stores label suspect items to indicate that they may contain lead,
educate staff about lead hazards, and provide outreach materials to customers about lead-safe work
practices. Some useful resources include: Renovate Right
(http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf), Steps to LEAD SAFE Renovation, Repair and
Painting (http://epa.gov/lead/pubs/brochure.htm), and Lead Paint Safety: A Field Guide for Painting,
Home Maintenance, and Renovation Work (http://www.epa.gov/lead/pubs/leadsafetybk.pdf). These can
be downloaded from EPA’s Web site or ordered from the National Lead Information Center at 1(800)424-
LEAD or http://epa.gov/lead/pubs/nlic.htm.
EPA suggests that re-use stores assume the presence of lead-based paint in pre-1978 residential
building materials and all other non-residential building materials, or have these materials tested. Lead
test kits that have been recognized by EPA (http://www.epa.gov/lead/pubs/testkit.htm #recognized) are
available at most hardware stores; alternatively, an XRF analyzer can be used to detect lead or a paint
chip can be sent to a laboratory for analysis.
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Testing for Lead
Question (23002-16836)
How do I know if my house has lead-based paint?
Answer
Older homes, child care facilities, and schools are more likely to contain lead-based paint. Homes that
contain lead-based paint may be single-family homes or apartments. They may be private, governmentassisted,
or public housing. They may be urban, suburban, or rural. You have the following options:
 Assume your home contains lead. Especially in older homes and buildings, this is the simplest
and safest approach. For example, 87% of homes built before 1940 have some lead-based
paint, while 24% of homes built between 1960 and 1978 have some lead-based paint.
 Test for lead using a lead test kit. EPA-recognized test kits are available at hardware stores.
Carefully follow the detailed instructions for their use. To learn more about EPA-recognized test
kits, visit http://www.epa.gov/lead/pubs/kits.htm).
 Hire a certified professional to check for lead-based paint. A certified inspector or risk assessor
can conduct an inspection to determine whether your home or a portion of your home has leadbased
paint and where it is located. This will tell you the areas in your home where lead-safe
work practices should be used for renovation, repair, or painting jobs. A certified risk assessor
can conduct a risk assessment telling you whether your home currently has any lead hazards
from lead in paint, dust, or soil. The risk assessor can also tell you what actions to take to
address any hazards. For help finding a certified risk assessor or inspector, call the National
Lead Information Center at 1-800-424-LEAD (5323).
Question (23002-20555)
The lead information pamphlet titled “Renovate Right” states there is a kit consumers can use to collect
samples to send to a lab if they suspect any lead hazards have been left after a renovation. Do samples
like these need to be taken by certified abatement personnel or a dust sampling technician?
Answer
No. When all the work is finished, if you want to know if your home, child care facility, or school has been
cleaned up properly. One way to check is a lead-dust test. Lead-dust tests are wipe samples sent to a
laboratory for analysis. You have the choice of having a lead-dust test done by a lead professional or
doing the testing yourself. If you choose to do the testing, some EPA-recognized lead laboratories will
send you a kit that allows you to collect samples and send them back to the lab for analysis. Contact the
National Lead Information Center at 1-800-424-LEAD (5323) for lists of qualified professionals and EPArecognized
lead labs. To learn more about making sure your home, child care facility, or school has been
cleaned properly after a renovation, visit http://www.epa.gov/opptintr/lead/pubs/renovaterightbrochure.pdf.
Question (23002-32338)
Is lead paint testing required under RRP?
Answer
No. A firm may always assume the presence of lead-based paint and proceed in accordance with all
RRP requirements.
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Question (23002-15211)
Do test results from a certified renovator using an EPA recognized test kit (40 CFR § 745.83) or
performing paint chip sampling (40 CFR § 745.82) become an official part of the lead-based paint testing
record for that house thus negating the need for a certified lead inspector or certified lead risk assessor to
conduct the inspection in that area of the house? Can a certified renovator conduct a complete leadbased
paint inspection and give the property owner as an inspection report?
Answer
The results of paint testing using test kits or paint chip sampling are part of the official lead-based paint
testing record for a home, and must be disclosed under EPA’s Real Estate Disclosure regulation (40 CFR
part 745, subpart F). However, EPA’s regulations only provide for a certified inspector or risk assessor to
conduct a lead-based paint inspection and to prepare a lead-based paint inspection report. Thus,
allowing renovators to test components does not negate the requirement that a certified inspector or risk
assessor follow the requirements set forth in § 745.227(b) when conducting a lead-based paint
inspection.
Question (23002-23865)
When testing a work area, does one spot-test kit or paint chip sample suffice for any single component?
What if a component’s surface area is extensive (i.e. a large wall)?
Answer
The certified renovator is only required to use one spot test kit or paint chip sample for each component,
even if the surface of the component is extensive (e.g., a large wall).
Question (23002-15694)
Does the RRP Rule apply to work on windows that have been installed within the last 20 years in a pre-
1978 housing unit? Would confirmation of the window installation based on property owner
documentation (i.e., receipts, warranty paperwork, contracts) and/or date of manufacture of the windows
be sufficient to exclude this work from the lead-safe work practices and other requirements?
Answer
The RRP Rule applies unless you have determined that all the components affected by the renovation,
including the windows, are free of paint or other surface coatings that contain lead equal to or in excess of
1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight. This determination must be made
either by a certified inspector or risk assessor, or by a certified renovator using an EPA recognized test kit
or performing paint chip sampling. You must keep records of any lead-based paint free determination
and make the records available to EPA if requested.
Question (23002-23701)
When a certified renovator uses an EPA-recognized test kit or performs paint chip sampling to determine
the presence of lead, can the results be grouped? For instance, may the certified renovator test just one
window sill in a room if all will be affected?
Answer
No. The certified renovator must test each component affected by the renovation. If the components
make up an integrated whole, such as the individual stair treads and risers of a single staircase, the
renovator is required to test only one of the individual components, unless the individual components
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appear to have been repainted or refinished separately. Multiple window sills are not integrated parts of a
whole. They are separate components and must be tested separately.
Question (23002-23255)
What lead test kits are recognized by EPA?
Answer
To date, EPA has recognized three lead test kits for use in complying with the false negative response
criterion of the RRP rule. They are the 3M LeadCheckTM kit (for use on ferrous metal, plaster, drywall and
wood), the State of Massachusetts kit (for use on drywall, plaster), and the D-Lead® kit (for use on wood,
drywall, plaster, and ferrous metal). If a substrate material is not listed above (such as stucco, or nonferrous
metals) then the recognized kits cannot be used on that substrate to comply with the testing
requirements of the RRP rule.
Question (23002-16393)
How can I obtain 3M LeadCheckTM test kits?
Answer
The 3M LeadCheckTM test kits can be purchased by calling the company directly. Their phone number is
available by going on their website, www.LeadCheck.com.
Question (23002-15505)
Does EPA recognize the 3M LeadCheckTM test kit for use on red paint?
Answer
Yes. EPA recognizes this kit for use on any color paint as long as the kit is used in accordance with the
manufacturer’s instructions.
Question (23002-18220)
If a certified renovator using an EPA-recognized test kit or paint chip sampling determines that the
components that will be affected by a renovation are free of lead-based paint, can a firm that does not
have RRP certification do the actual renovation work? What record-keeping requirements would apply?
Answer
Where a certified renovator performs paint chip sampling or uses an EPA-recognized test kit following the
kit manufacturer’s instructions, tests each component affected by the renovation, and determines that the
components are free of paint or other surface coatings that contain lead at regulated levels, the
renovation can be performed by a non-certified firm and without regard to the work practice standards or
record-keeping requirements of the RRP Rule. See 40 CFR 745.82(a)(2).
However, the certified renovator and firm performing the testing are still subject to the recordkeeping
requirements of 745.86(b)(1)(ii) and (iii), and 745.86(a) and (c). Specifically, the certified renovator must
prepare a record that states the brand of test kit used or the name and address of the NLLAP-recognized
entity performing the paint chip analysis, a description of the components tested including their location,
and results of the tests. The certified renovator’s firm must retain a copy of this record for three years.
EPA further recommends that the firm actually performing the renovation also retain a copy of these
records to demonstrate that compliance with the RRP Rule was not required.
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Question (23002-19098)
Is it true that the lead test kits currently recognized by EPA will no longer be recognized after September
1, 2010?
Answer
No, the currently recognized test kits did not automatically lose their recognition on September 1, 2010.
As discussed in the 2008 RRP rule, prior to September 1, 2010, manufacturers seeking recognition of
their test kit must meet only false negative response criterion, and that recognition of kits meeting this
criterion will last until EPA publicizes its recognition of a kit that passes both the false negative and the
false positive criteria.
Currently, EPA recognizes three test kits that pass only the false negative criterion: one manufactured by
3M, called 3M LeadCheckTM, one manufactured solely for use by the State of Massachusetts, and one
manufactured by ESCA Tech, Inc., called D-Lead®.
Question (23002-25349)
Will there be any Phase Two kits approved as a result of the recent ETV evaluations?
Answer
Based on the results of the recent ETV evaluations no new test kits were approved that meet both the
false negative and false positive performance criteria. However one kit did meet the false negative
performance criterion for drywall, plaster, ferrous metal and wood, and was recognized for use by certified
renovators on August 31, 2010. Thus, after September 1, 2010, EPA will continue to recognize
3M LeadCheckTM, the State of Massachusetts kit, and the newly recognized D-Lead® kit.
Question (23002-16390)
How can I obtain D-Lead® test kits?
Answer
The D-Lead® test kits are available for purchase from certain distributors and retail outlets. A list of
theses distributors and retailers can be found by going to http://www.esca-tech.com, emailing rrp@escatech.
com, or by calling (414) 962-3006.
Question (23002-31777)
My firm is not RRP-certified and does not employ an RRP-certified renovator. If we are asked to perform
a renovation in a pre-1978 home, we first test the home for the presence of lead using an EPA
recognized test kit. If lead is present, we decline the job. If lead is determined not to be present, we
accept and proceed normally. Can we perform these lead tests without being a certified renovator?
Answer
No. When performing a renovation in a pre-1978 home, a firm is excepted from the requirements of the
RRP Rule if a determination has been made that the surfaces affected by the renovation are free of paint
or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or .5% by weight.
However, in order for this exception to apply, the determination must be made by a certified lead
inspector or risk assessor, or by a certified renovator using an EPA recognized test kit and following the
kit manufacturer’s instructions.
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Question (23002-31778)
I am an EPA-certified lead risk assessor. Can I use an EPA recognized lead test kit (e.g. 3M
LeadCheckTM, D-Lead®, etc.) when assessing whether or not a pre-1978 home contains lead-based paint
for purposes of the RRP Rule?
Answer
Yes. In addition to a certified renovator, a person certified by EPA as a risk assessor or lead inspector
may use an EPA recognized test kit to determine that regulated lead-based paint is not present in a
home. Such a report can also be used to confirm that the RRP Rule would not apply to renovation
activities in that home. A list of currently recognized test kits is available at:

http://www.epa.gov/lead/pubs/testkit.htm.

Question (23002-32520)
Can a person who is color blind use the 3M LeadCheckTM test kits?
Answer
A certified renovator seeking to use a lead-test kit for RRP purposes must be able to use the kit, and
interpret the results, in accordance with the manufacturer’s instructions. A person who is unable to
accurately use the product due to some disability cannot, and should not, rely on any results for RRP
purposes.
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General Information about the Lead Renovation, Repair, and
Painting (RRP) Rule
Question (23002-22990)
What is the purpose of the RRP Rule?
Answer
The purpose of the RRP Rule is to minimize exposure from lead-based paint dust during renovation,
repair, or painting activities. This is a key efffort in reducing the prevalence of childhood lead poisoning,
particularly lead poisoning caused by housing contaminated by renovation activities. This will also
minimize exposure to older children and adults who are also adversely impacted by lead-based paint dust
exposure. Lead paint was used in more than 38 million homes prior to its ban for residential use in 1978.
This paint can form toxic dust when it is disturbed during normal home repair work. EPA’s Renovation,
Repair and Painting (RRP) program is designed to reduce lead contamination by training contractors in
relatively simple lead-safe work practices, and certifying contractors to make sure that they follow leadsafe
work practices. We also want consumers to choose firms that are certified. Given that lead
poisoning can cause a wide range of physical, intellectual, emotional, and behavioral issues with societal
and financial impacts, this program is prevention-based, cost-effective, and a long-term bargain.
Question (23002-21795)
What does the RRP Rule require?
Answer
The RRP Rule requires that renovators are trained in the use of lead safe work practices, that renovators
and firms be certified, that providers of renovation training be accredited, and that renovators follow
specific work practice standards. Additional information on this rule can be found at

http://www.epa.gov/lead/pubs/renovation.htm.

Question (23002-24685)
Who is covered by the RRP Rule?
Answer
The rule applies to all firms and individuals who are paid to perform renovation, repair, and painting
projects that disturb paint in pre-1978 housing and child-occupied facilities. This includes home
improvement contractors, maintenance workers, painters and other specialty trades.
Question (23002-19015)
Is it a violation of the RRP Rule for a homeowner to hire a firm that is not certified?
Answer
The RRP rule does not impose requirements on homeowners, unless they are performing renovations in
rental space. However, the hired firm would be in violation of the RRP Rule if it was uncertified and
performing a covered renovation.
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Question (23002-17725)
How much will it cost contractors to comply with the RRP Rule?
Answer
In order to comply with the RRP rule, renovators will incur costs for EPA certification and costs to take a
training course from an EPA-accredited training provider, as well as for supplies needed in order to carry
out the required lead-safe work practices designed to reduce exposure to lead dust from renovations.
Firm Certification and Training Costs: The rule requires renovation firms to become certified by EPA
or an EPA-approved state RRP program in order to perform renovation, repair or painting activities for
compensation in target housing or child-occupied facilities. EPA is required by law to charge firms a fee
that covers the government’s cost of administering the program. Firm certification is valid for 5 years.
The fee for most firms is $300, which is equivalent to a cost of $60 per year.
In addition, the rule requires that firms use trained certified renovators for certain key parts of the job,
such as containing the work area and conducting cleaning verification after the job’s completion. In most
cases, firms have at least one certified renovator on staff. To be a certified renovator, an individual must
take a training course from a private training provider accredited by EPA. The training is valid for 5 years.
The cost of the training course is set by the private training provider and varies, but on average is about
$200 (which is equivalent to a cost of $40 per year). The trained renovators can then provide on-the-job
training to their workers. Firms may also incur additional costs related to training and certification, such as
the time spent on the activities, and for traveling to and from the training. EPA estimates that this costs
$562 per person trained. This includes a tuition cost of $186, the value of time for the 8 hours the
renovator is in class ($253), the value of time for 2 hours traveling to and from class ($63), mileage costs
to drive to and from the training ($49), and lunch while at the training ($9).
Costs Associated with Lead-Safe Work Practices: Aside from the fixed costs for training and
certification, renovators will also incur costs that vary depending on the size, type, and number of jobs
performed.
Test kits. Renovators may choose to use spot-test kits to determine whether lead-based paint is present
before the start of the job. The total cost of the test kits used depends on the number components tested,
but is estimated to average $10 per job. The use of test kits is optional, but many renovators find the test
kits helpful for determining which parts of the job are subject to the rule’s work practice requirements.
Labor, equipment and supply costs. The rule also requires renovators to use work practices in order to
reduce exposure to lead dust. As part of the rulemaking process, EPA estimated the labor, equipment,
and supply costs for these work practices. To calculate the costs for the rule’s containment, cleaning,
and cleaning verification requirements, EPA considered nine categories of renovation events (kitchen
renovation, window replacement, painting, etc), for up to three sizes (small, medium, and large square
footage) in up to three different dwelling types (single-family owner, single family rental, and multi-family
rental) and in child-occupied facilities.
EPA first estimated an absolute cost of complying with the lead-safe work practices required by a rule if a
renovator did not use any containment, or perform any cleaning, or cleaning verification prior to the rule.
EPA estimated the labor and materials costs associated with each lead-safe work practice for the various
job types included in the analysis.
However, EPA heard from the industry that renovators had been taking steps to control dust from
renovations prior to the promulgation of the rule. Based on this input, EPA estimated an average
incremental cost of each lead-safe work practice by subtracting the cost already being incurred by
renovators for containment and cleaning from the estimate of the absolute cost of the rule’s requirements.
For typical jobs in single family homes, EPA estimated that the average absolute costs to comply with the
rule ranged from $35 to $376, depending on the size and nature of the job. The average incremental
costs of complying with the rule ranged from $8 to $124. For example:
12
For a large window replacement job in a single family home (12 windows), the average cost ranges
between $124 for contractors who already used some of the required work practices, to $376 for
contractors who did not use any of the required work practices.
For a medium sized job removing portions of a wall in a single family home (such as might be done to
repair water pipes or electrical wiring), the average cost ranges between $41 for contractors who already
used some of the required work practices, to $121 for contractors who did not use any of the required
work practices.
For an exterior painting job involving four exterior walls, the average cost ranges between $90 for
contractors who already used some of the required work practices, to $245 for contractors who did not
use any of the required work practices.
Finally, firms incur a cost for paperwork and recordkeeping, in order to demonstrate compliance with the
RRP rule’s training and work practice requirements.
Renovators conduct millions of jobs each year, ranging from simple drywall repairs to complete kitchen
and bath renovations, and from window replacements to building additions. While EPA estimated the
compliance costs for various general sizes and types of work, EPA’s cost model is a simplified
representation that cannot capture all of the variations from one job to another. EPA’s methodology does
not estimate the cost for any individual job performed by a particular renovator.
The cost for a particular contractor to comply with the rule may be considerably different from the sample
jobs EPA considered, depending on factors such as the size, configuration, or other conditions of the
work area; how the contractor uses his or her discretion to comply with the rule; and the prevailing local
wage rates. Furthermore, EPA only estimated the cost of the work practices required by the rule. Some
contractors may choose to take additional precautions beyond those required by the rule. These steps
may provide extra protection for residents and renovation workers, but they also increase the cost of the
work. And because EPA’s estimates reflect the cost to contractors, not the price paid by homeowners,
the estimates do not include the contractor’s mark-up for profits.
The purpose of EPA’s analysis was to compare the national cost of the rule’s requirements to the national
benefits of the rule. The analysis indicated that the requirements of the rule are not excessive or overly
burdensome in light of the importance of avoiding the potentially severe consequences of exposure to
lead-based paint hazards.
Question (23002-23391)
What records will my firm be required to keep?
Answer
The following records must be retained for three years following the completion of a renovation:
 Reports (if any) certifying that lead-based paint is not present
 Records relating to the distribution of the lead pamphlet
 Documentation of compliance with the requirements of the regulation (EPA has prepared a
sample form that is available at www.epa.gov/lead/pubs/samplechecklist.pdf).
Question (23002-25279)
Will insurance premiums go up for contractors covered by the rule that work in homes and child-occupied
facilities with lead-based paint?
13
Answer
The practice of carrying insurance to cover work in older homes from potential lead poisoning damages is
not new. The RRP Rule, because it sets a clear standard of care and allows contractors to demonstrate
that they meet that standard by taking appropriate training and using proper work practices, could
eventually lead to insurance premiums that reflect that proactive stance.
Question (23002-19407)
Is there one document available that includes the latest version of the RRP Rule, with all amendments
added to their associated locations, in complete form, and not including the preamble?
Answer
Yes. Visit the RRP Web site at http://www.epa.gov/opptintr/lead/pubs/lscp-renov-materials.htm and click
on Code of Federal Regulation Title 40: Protection of Environment; Part 745: Lead-Based Paint Poisoning
Prevention in Certain Residential Structures.
Question (23002-18597)
If there are differences among EPA’s, HUD’s, and my State’s requirements, which ones do I have to
comply with?
Answer
You must comply with all applicable requirements. The initial 8-hour renovator training course will teach
you how to perform lead-safe work practices safely and effectively in compliance with the EPA RRP Rule
and the HUD Lead Safe Housing Rule. The RRP Rule is not intended to supersede or preempt any more
stringent State or local laws.
Question (23002-19805)
My school district will be performing asbestos abatement in a kindergarten classroom that was built
before 1978. Do the asbestos abatement workers also need to comply with the RRP rule?
Answer
Yes, if the asbestos abatement disrupts over 6 square feet of painted surface per room in an interior, or
over 20 square feet of painted surface on an exterior, or involves window replacement or demolition of
painted surfaces. If so, the asbestos abatement will need to be performed by a firm certified under the
RRP rule. The firm will be required to assign an RRP-certified renovator to the project, and workers will
need to have been trained by a certified renovator. Of course, the asbestos abatement must be designed
and conducted by persons accredited in accordance with the Model Accreditation Plan.
In addition, the asbestos abatement will need to meet the RRP Rule work practice standards as well as
the standards for asbestos abatement. For each element of the job, the contractor will need to determine
which standards are more stringent and comply with those standards. Typically, the asbestos abatement
containment and waste handling requirements are more stringent than the RRP Rule provisions, so
compliance with the asbestos requirements will also serve as compliance with the RRP requirements.
However, both the asbestos air clearance and the RRP cleanup and verification requirements must be
performed. Because the air clearance process is performed with the critical barriers still in place, it must
be performed before RRP cleanup and verification.
14
Question (23002-15674)
Does the RRP Rule apply to states and local governments?
Answer
The RRP Rule requires that renovators are trained in the use of lead safe work practices, that renovators
and firms be certified, that providers of renovation training be accredited, and that renovators follow
specific work practice standards. After April 22, 2010 contractors (including renovation, repair and
painting workers, plumbers, electricians, HVAC professionals, etc.) working in pre-1978 homes, schools
and child-care facilities must be EPA certified and trained in lead-safe work practices when conducting
renovation, repair and painting activities that will disturb more than six square feet of painted surfaces on
the interior of a building or more than 20 square feet on the exterior. Window replacements are covered
activities.
Question (23002-18001)
I am a renovator and I want to comply with EPA’s Lead Renovation, Repair and Painting Rule. What do I
need to do?
Answer
EPA’s Lead Renovation, Repair and Painting (RRP) rule sets up new requirements for firms and
individuals performing renovations in pre-1978 housing and child-occupied facilities, such as schools
and daycares.
• Firms must be EPA certified. To become EPA certified, renovation contractors must submit an
application and fee payment to EPA (www.epa.gov/getleadsafe). Once certified, the firm will be able to
advertise that they are certified by EPA under the RRP program, and will also be given rights to use
EPA’s “Lead-Safe Certified Firm” logo.
• Renovations covered by the rule must be performed or directed by a Certified Renovator.
Individuals can become a lead-safe certified renovator quite easily. It requires successful completion of
a one-day training course in lead-safe work practices. The training courses are offered by EPA-approved
private training providers; there is no additional fee to EPA. You can find a training provider in your area
by using EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm.
Over 500 training firms have been accredited to provide the specialized, one-day lead-safe work practices
training. Many offer trainings in multiple states. Classes teach the specific work practices that
contractors need to protect themselves and their clients from lead contamination, and to allow them and
their firm to work legally. Certification is immediate upon successful completion of the training class.
Question (23002-18044)
I am planning to renovate my home. How can I find a lead-safe certified firm?
Answer
EPA has a searchable database to help you locate lead-safe certified firms near you at:
http://cfpub.epa.gov/flpp/searchrrp_firm.htm. In addition, you can call EPA’s lead hotline at 1-800-424-
LEAD (5323) if you have questions.
Question (23002-18095)
I have hired a firm to renovate my home, but now I am concerned about whether the firm is a lead-safe
certified firm. How can I find out?
15
Answer
EPA has a searchable database to help you locate lead-safe certified firms near you at:
http://cfpub.epa.gov/flpp/searchrrp_firm.htm. It is possible that your firm is not yet listed on EPA’s web
site, but is certified. If you do not find your firm on EPA’s web site, you should call EPA’s lead hotline at
1-800-424-LEAD (5323) and speak to an expert who can help you find out whether your firm is certified.
Question (23002-18140)
I took a class to be a Certified Renovator and my firm applied for firm certification before April 22, 2010,
but my firm does not have its certificate yet. What do we do?
Answer
In these circumstances, EPA does not intend to take enforcement actions against firms who applied for
firm certification before April 22 and have not received their certification. The certification requirement is
important to making sure that firms are protecting children and other residents while renovations are
ongoing, but EPA does not wish to disrupt ongoing renovations for those firms that submitted applications
on time. We expect that all of the applications filed before April 22 will be reviewed by June, and that the
applications submitted for the first 60 days after April 22 will be reviewed soon thereafter. Thus, it will only
be a short window of time when firms that applied are waiting to hear back from EPA.
Question (23002-17543)
How long will it take EPA to process my application to be a lead-safe certified firm?
Answer
EPA is required to process your application within 90 days of receipt. In most instances, properlycompleted
firm applications are processed in about one month.
Question (23002-21890)
What happens if my firm is in the middle of a renovation job on April 22, 2010? My firm is not certified
and none of my employees have taken the lead-safe certified renovator training. What should I do?
Answer
You should submit your application for renovation firm certification immediately. You should also arrange
for lead-safe certified renovator training for at least one of your employees as soon as possible, and you
should require at least one of your employees to review EPA’s online training materials at
http://www.epa.gov/lead/pubs/training.htm. In addition, you must follow the lead-safe work practices
required by the rule. Information on these work practices can be found at www.epa.gov/lead or obtained
from the National Lead Information Center at 1-800-424-LEAD (5323). For the first 60 days after April 22,
2010, EPA’s general approach for work initiated before that date will be, upon learning that a firm or
individual conducting a renovation is not certified or trained, to issue a notice without monetary penalties
to that firm or individual. This notice will state that the firm or individual needs to come into compliance as
quickly as possible. To correct the noncompliance, the individual or firm will need to provide a copy of an
accredited course completion certificate or firm certification to EPA within a reasonable time.
Question (23002-18000)
I am a renovation firm and I have contracted for a renovation in a pre-1978 home to begin on or after April
22, 2010. None of my people have taken the lead-safe certified renovator training yet. I found out the
Certified Renovator classes near me are all full until after April 22, 2010. What should I do?
16
Answer
You should hold off on starting work in any pre-1978 home or child-occupied facility until you have taken
the certified renovator training course from an EPA-accredited training provider. In addition, you should
make sure that your firm is EPA certified. You can find out more information at
www.epa.gov/getleadsafe. You can find an accredited training provider who is based near you by using
EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm. More than 340 EPA-accredited
training providers have indicated to EPA that they are willing to travel to offer training classes. You can
find a list of training providers, including those who are willing to travel, by using the same search tool.
Question (23002-17981)
I am a firm and there are no training providers offering classes near me. What do I do?
Answer
More than 340 EPA-accredited training providers have indicated to EPA that they are willing to travel to
offer training classes. You can find a list of training providers, including those who are willing to travel, by
using EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm.
Question (23002-18120)
I operate a renovation firm and I have heard that my state will adopt its own lead Renovation, Repair and
Painting program. Do I have to also be certified by EPA?
Answer
As of July, 2011, twelve states have their own RRP programs (Alabama, Georgia, Iowa, Kansas,
Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin). If
your firm is located in one of these states, you should contact them for information on their certification
requirements. If you work outside of one of those states, your firm needs to be certified by EPA.
17
Renovations Covered by the RRP Rule
In General
Question (23002-17496)
How is window repair or maintenance, as distinct from removal, treated under the RRP Rule? Would the
rule apply to a job that replaced parts or components of a window, such as broken or failed glass,
hardware, or balance systems, where some components might be painted, but the frame of the window
would remain?
Answer
Replacing a pane of glass or fixing a broken window balancer is not a window replacement. However,
this activity would be subject to the rule unless it meets the definition of minor repair and maintenance.
To be considered minor repair and maintenance, the renovation must not disrupt more than 6 square feet
of painted surfaces per room. Activities such as replacing a piece of glass in a window can disturb paint.
The glazing that holds the pane in place in older windows is painted, and this glazing has to be removed
for the pane to be replaced. Also keep in mind that when calculating the 6 square feet when a
component is being removed, it’s based on the surface area of the component.
Question (23002-15669)
Does the RRP rule apply to renovations done in an apartment between tenants? Does it matter if
children live in other apartments in the building?
Answer
Temporarily unoccupied or vacant housing rental is not exempt from the requirements of the RRP Rule.
Question (23002-19962)
Does the Renovation, Repair, and Painting (RRP) Rule prohibit the deconstruction and reuse of old
building materials containing lead-based paint?
Answer
No. The RRP Rule does not prohibit a firm from extracting, salvaging or reusing building materials that
contain lead-based paint. However, the requirements of the RRP Rule may apply to these activities if
they (1) occur in target housing or a child-occupied facility, and (2) disturb more than six square feet of
interior painted surface or more than twenty square feet of exterior painted surface.
Further, the RRP Rule only applies to renovations – the modification of an existing structure that results in
the disturbance of painted surfaces. Demolition of an entire property is not a renovation for RRP
purposes. Therefore, if deconstruction or salvage activities occur in conjunction with total demolition of
the property, the RRP Rule would not apply. Conversely, if only a portion of the property is
deconstructed, and the above two criteria are met, then the activity is a renovation and the requirements
of RRP Rule apply. In such a case, firms must establish containment before deconstruction, and ensure
that components to be reused are free of any lead-based paint dust or debris before they are removed
from the work area.
18
Question (23002-19754)
My firm is performing a renovation in an unoccupied home that will be put up for sale when work is done.
Does the RRP Rule apply to this renovation?
Answer
Yes. Temporarily unoccupied or vacant housing is not exempt from the requirements of the RRP Rule.
Question (23002-15688)
Does the RRP Rule apply to office buildings, stores, and other commercial buildings?
Answer
No, unless the renovation is taking place in a child-occupied facility that is located in a commercial
building. “Child-occupied facility’’ means a building, or portion of a building, constructed prior to 1978,
visited regularly by the same child, under 6 years of age, on at least two different days within any week
(Sunday through Saturday period), provided that each day’s visit lasts at least 3 hours and the combined
weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Child-occupied
facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.
Child-occupied facilities may be located in target housing or in public or commercial buildings.
With respect to common areas in public or commercial buildings that contain child-occupied facilities, the
child-occupied facility encompasses only those common areas that are routinely used by children under
age 6, such as restrooms and cafeterias. Common areas that children under age 6 only pass through,
such as hallways, stairways, and garages are not included. In addition, with respect to exteriors of public
or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only
the exterior sides of the building that are immediately adjacent to the child-occupied facility or the
common areas routinely used by children under age 6.
Areas of a building that fall outside this definition are not “child-occupied facilities” for purposes of the
RRP rule.
Question (23002-15684)
Does the RRP Rule apply to federal employees performing work on federal facilities?
Answer
Yes. Federal agencies and their employees must comply with all Federal, State, interstate, and local
requirements, both substantive and procedural, respecting lead-based paint in the same manner and to
the same extent as any non-governmental entity. In addition, the RRP Rule requires all renovations
performed after April 22, 2010, to be performed by a certified firm. The definition of “firm” includes federal
agencies. Therefore, if the employees of a federal agency are performing renovations, the agency must
be a certified firm and must follow the RRP Rule when performing the renovation.
Question (23002-15691)
Does the RRP Rule apply to renovations that disturb ceramic tile where the glaze on the tile contains lead
at regulated levels?
Answer
No. Ceramic tile glaze is neither a surface coating nor a painted surface. Therefore, renovations that
disturb ceramic tile glaze are not subject to the RRP Rule.
19
Question (23002-19759)
My firm repairs windows in which the glass has been cracked or broken by removing and replacing the
sash. For casement windows, we unscrew and remove the hinges on the old window, pull out the old
sash, and install the new sash. For double-hung windows, we release the jambliner, pull out the sash
with the damaged glass, and install the new sash. We may disturb paint on the hinges and screws, but
do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?
Answer
Replacement of a window sash by simply unscrewing hinges or releasing it from a jambliner does not
constitute “window replacement” for purposes of the RRP Rule. Therefore, such tasks may fit within the
definition of minor repair and maintenance i.e., activities that disturb six square feet or less of interior
painted surface, or twenty square feet or less of exterior painted surface.
If unscrewing a hinge or releasing a jambliner disturbs paint on the screws and/or hinges, but does not
otherwise disturb a painted surface on the window sash, frame, casing, sill, trim or surrounding walls,
then the activity likely disturbs less than six square feet of painted surface and would not be subject to the
RRP Rule.
Question (23002-32207)
I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of
painted wood siding that tested positive for lead. The underlying painted surface is greater than twentysquare
feet. Must I comply with the Rule when removing the aluminum siding?
Answer:
The work practices for exterior projects are based on a performance standard – if the activity disturbs a
painted surface (generally, by creating paint chips or dust) in excess of 20 square feet, the work area
must be contained so that dust or debris does not leave the work area while the renovation is being
performed. In this case, if the removal of the aluminum siding results in the disturbance of paint in excess
of 20 square feet, then the RRP Rule applies. However, if the removal activity could be performed in
such a way that does not disturb 20 square feet of painted surface, then the RRP Rule would not apply.
EPA recognizes that this may be difficult to determine in advance of the renovation activity. However, the
renovator is the person with the expertise and experience to make this determination on a case-by-case
basis. In such a situation, a renovator should consider how factors like the condition of the underlying
paint or the chosen method of removal may increase or decrease the likelihood for a disturbance of paint.
If there is still uncertainty, EPA recommends that renovators err on the side of caution and be prepared to
contain any dust and debris.
Definition of “Renovation”
Question (23002-22108)
What is a renovation?
Answer
The RRP Rule covers activities that modify an existing structure and that result in the disturbance of
painted surfaces. All types of repair, remodeling, maintenance, modernization, and weatherization
projects are covered, including projects performed as part of another Federal, State, or local program, if
the projects meet the definition of ‘‘renovation’’. The term “renovation” includes (but is not limited to):
20
 Removing, modifying or repairing painted surfaces or painted components. Examples include
modifying painted doors, surface restoration, window repair, and surface preparation activity like
sanding and scraping that may generate paint dust.
 Removing building components such as walls, ceilings, plumbing, or windows.
 Weatherization projects such as cutting holes in painted surfaces to install blown-in insulation or
to gain access to attics, or planing thresholds to install weather-stripping.
 Interim controls that disturb painted surfaces.
The RRP Program rule only applies to persons who perform renovations for compensation.
Question (23002-18426)
What is a “whole house gut rehabilitation project” for RRP purposes? What RRP requirements, if any,
apply during a whole house gut-rehabilitation project? If target housing has, at some point after 1978,
been gut-rehabbed, would the RRP Rule apply to subsequent renovations on the property?
Answer
The phrase “gut rehabilitation” may have different meanings across the construction industry. EPA,
however, used the phrase “whole house gut rehabilitation” in a very limited sense to describe only those
activities that demolish and rebuild a structure to a point where it is effectively new construction. At a
minimum, these activities include the removal and replacement of all interior and exterior painted
surfaces, including windows. The term should not be confused with a comprehensive renovation as
described in FQ 23002-23415.
If an activity meets these narrow criteria (i.e., if a firm demolishes and rebuilds a structure to the extent
that it is effectively new construction), then the activity is not a renovation for purposes of the RRP Rule
and therefore not subject to any RRP requirements.
If, after 1978, target housing has been demolished and rebuilt to the extent that it is effectively new
construction, subsequent renovations on the property would also not be subject to the RRP Rule. In other
words, if target housing has been demolished and rebuilt to the extent that it is effectively new
construction, it is no longer target housing. Conversely, if only a portion of the target housing has
undergone a post-1978 modification (e.g., an overhaul of a kitchen or bathroom), then a subsequent
renovation would still be covered under the RRP Rule.
Question (23002-23415)
What RRP requirements apply to a comprehensive renovation project involving the removal and
replacement of all interior painted surfaces from target housing or a child-occupied facility?
Answer
A project that involves the removal and replacement of all interior painted surfaces but leaves all exterior
painted surfaces intact is considered a renovation for RRP purposes. Therefore, all requirements of the
RRP Rule apply including, but not limited to, those for firm and renovator certification, containment, waste
disposal, cleaning and verification, and recordkeeping. The type of activity described in the question
should not be confused with a “whole house gut-rehabilitation project” that effectively results in new
construction as discussed in FQ 23002-18426.
EPA has recognized the fact that there may be circumstances where it is impossible for firms to meet all
of the requirements under the RRP Rule. To the extent that performance of an RRP requirement would
be impossible, the firm is excused from compliance. However, impossibility of one work practice does not
21
excuse a firm from complying with other requirements. EPA further recommends that the firm document
and keep records of the specific circumstances surrounding the impossibility.
With respect to the comprehensive renovation activities described in the question, impossibilities may be
more prevalent. For example, during removal of a floor, covering the floor surface with taped-down
plastic sheeting as required by 40 CFR 745.85(a)(2)(i)(D) would be impossible. As described above, the
firm would be excused from this requirement. Nevertheless, the firm must still ensure that the work area
is properly contained. Windows, doors and ducts in the work area must be closed and covered.
Precautions must be taken to ensure that all personnel, tools, and other items are free of dust and debris
before leaving the work area. At the conclusion of each work day and at the conclusion of the renovation,
waste that has been collected from renovation activities must be stored under containment, in an
enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents
access to dust and debris, and disposed of properly.
Following the renovation, the work area must also be cleaned until no dust, debris or residue remains. If
no more painted surfaces will be disturbed, then cleaning may take place after either removal of all
components, or after all new surfaces have been installed. Further, should cleaning or verification be
impossible to achieve (for example, due to the nature of the surfaces), a firm must still make their best
effort to collect and remove all paint chips, dust, debris and residue. See FQ 23002-15872.
Question (23002-13885)
Are DOE weatherization projects covered under the RRP Rule?
Answer
The RRP Rule defines “renovation” to include weatherization projects such as cutting holes in painted
surfaces to install blown-in insulation or to gain access to attics, and planing thresholds to install weather
stripping. Other types of weatherization projects, such as window replacement, are also be covered if
they fall within the definition of “renovation.”
Question (23002-15670)
When a home or an apartment unit is repainted in preparation for a new tenant, is the painting activity
always considered a “renovation” for purposes of the pre-renovation education requirements even if no
surface preparation activity is performed prior to painting?
Answer
No. The primary determinant of whether a given activity constitutes a “renovation” under the RRP Rule is
whether that activity disturbs a painted surface. The practice of recoating painted surfaces in preparation
for new tenants would not constitute “renovation” unless accompanied by activities that disturb the
painted surface and create paint dust such as sanding, scraping, or other surface preparation activities.
Minor “spot” scraping or sanding can be considered “minor repair and maintenance activities” if no more
than 6 square feet of paint is disturbed in any room or no more than 20 square feet of paint on any
exterior to be painted, and the work does not involve practices prohibited by the Rule, such as power
sanding without a high-efficiency particulate air (HEPA) filter attachment. Washing walls or other
components prior to painting likely would not result in a disturbance of painted surface.
22
Question (23002-15672)
Does the RRP Rule apply where no paint at all is present, such as in a 100 year old unfinished
basement?
Answer
No. The RRP Rule applies to activities that result in the disturbance of painted surfaces. Where there is
no paint to disturb, the RRP Rule does not apply.
Question (23002-18485)
If I am painting a wall on which there are multiple coats of latex paint over the old lead-based paint and
the paint is not peeling down to the lead paint level must I comply with the new regulations?
Answer
Yes, if the painted surface of the wall will be disturbed by the renovation.
Question (23002-15680)
Does the RRP Rule apply to demolishing and disposing of:
 An entire pre-1978 home or building?
 An entire, non-attached free-standing structure on the same property such as a garage, shed, or
gazebo?
 An attached but segregated section of pre-1978 home or building such as a sunroom, addition,
two-story porch, or garage attached by a breezeway?
Answer
The RRP Rule covers renovations, which are defined as modifications of existing structures or portions of
structures. The rule does not apply to demolitions of an entire free-standing building or structure.
The RRP Rule does apply to renovation activities that modify portions of existing structures. Waste from
these activities must be contained to prevent releases of dust and debris before the waste is removed
from the work area for storage or disposal. If a chute is used to remove waste from the work area, it must
be covered.
At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected
from renovation activities must be stored under containment, in an enclosure, or behind a barrier that
prevents release of dust and debris out of the work are and prevents access to dust and debris.
When the firm transports waste from renovation activities, the firm must contain the waste to prevent
release of dust and debris.
Question (23002-14867)
Can you list specific activities deemed a disturbance of painted surfaces?
Answer
As a general matter, EPA believes that activities that create dust or paint chips are activities that disturb
paint. There is no definitive list of activities that disturb painted surfaces. Some examples that can
disturb painted surfaces include, but are not limited to:
23
 Making cut-outs in walls.
 Replacing a window from the inside or outside.
 Removing paint with a heat gun.
 Scraping paint.
 Removing kitchen cabinets.
 Removing paint by abrasive sanding.
 Removal of large structures, including demolition of interior plaster walls.
 Window replacement.
 HVAC repair or replacement, including duct work.
 Repairs resulting in isolated small surface disruptions, including drilling and sawing into wood and
plaster.
 Scuff-sanding.
These activities and other activities which disturb paint could be relevant to many trades, such as (but not
limited to) renovation, remodeling, general repair, general maintenance, plumbing, electrical work,
carpentry, window installation, painting, weatherization work, and more.
Question (23002-18541)
I am repainting relatively new siding on a pre-1978 home. The siding was installed after 1978, but was
been nailed over top of the old lead-based exterior paint. Must I comply with the Rule?
Answer
The RRP Rule only applies when a painted surface is disturbed. If the repainting activity disturbs a
painted surface, such as by sanding or scraping in preparation of painting, then the RRP Rule applies.
The same is true even if you do not believe the old lead-based paint is disturbed when the new siding is
prepared and repainted.
You also have the option to test the new siding to determine that it is free of paint or other surface
coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5%
by weight. This determination can be made by a certified inspector or risk assessor or by a certified
renovator using an EPA-recognized test kit. If such a determination is made, then the RRP Rule does not
apply.
Question (23002-15683)
My firm is removing and replacing a furnace. The surface area of the old furnace exceeds six square
feet. Does the RRP Rule apply to this activity?
Answer
The RRP Rule applies to modifications of an existing structure, or portions thereof, that result in the
disturbance of painted surfaces. Fixtures such as furnaces, radiators and heating elements, as opposed
to personal property, are part of existing structures for RRP purposes.
In this case, if the surface coating of the furnace will not be disturbed when the furnace is removed, then
the RRP Rule does not apply. If the surface coating will be disturbed, then the RRP Rule applies absent
a determination pursuant to 40 CFR 745.82(a) that the furnace is free of lead-based paint.
Question (23002-18301)
If a homeowner removes all the painted surfaces in a room and then hires a certified firm to remodel the
room, does the renovator need to follow the RRP Rule?
24
Answer
No. Projects that do not disturb a painted surface are not subject to the RRP Rule.
Question (23002-19760)
My firm replaces garage doors. We unbolt the door from its hardware and remove it without penetrating,
scraping, or removing paint. Is this work subject to the RRP Rule?
Answer
If unbolting and removing the door does not disturb a painted surface in the hinges, door, or frame, the
RRP Rule does not apply. For more information on what types of activities disturb paint, see Question
6666.
Question (23002-14025)
Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been
painted?
Answer
The RRP Rule applies to work that disturbs painted surfaces. Therefore, renovations that disturb stucco
are subject to the RRP Rule only if the stucco has been painted.
Question (23002-23787)
When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but
we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work?
Answer
The RRP Rule applies to work that disturbs painted surfaces. If hammering painted components, even
on the unpainted side, disturbs paint, creating dust or chips, the RRP Rule applies.
Question (23002-15689)
Does the RRP Rule apply to removing a roof that is not painted?
Answer
The RRP Rule applies to work that disturbs painted surfaces. Where there is no paint to disturb, the RRP
Rule does not apply.
Question (23002-19751)
My firm installs replacement doors. We simply remove the hinge bolts, take away the old door, unscrew
and remove the hinges, and install the new door and hinges. We may disturb paint on the hinges and
bolts but do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?
Answer
Because doors are not cut-outs, the entire surface area is not counted for purposes of calculating the 6
sq. ft. threshold of minor maintenance and repair—unless removing the door also disturbs any paint on
the door (e.g., because of the deteriorated condition of the paint or any dust-generating activities).
Therefore, if unbolting and unscrewing a door disturbs paint only on the bolts, screws and/or hinges, but
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does not otherwise disturb a painted surface on the door, frame, trim or surrounding walls, then the
activity likely disturbs less than six square feet of painted surface and would not be subject to the RRP
Rule.
Question (23002-31781)
My firm has been hired to replace windows in a home built before 1978. The existing windows are milfinish
(ie: not painted) aluminum. We plan to use the “insert” method of replacement where we remove
the existing sash and attach the new window’s frames inside the old frames. Because we will not disturb a
painted surface (our work remains inside the mil finished aluminum), is this activity subject to the RRP
ruling?
Answer
No. The activity described above does not disturb a painted surface. Therefore, the requirements of the
RRP Rule do not apply.
Minor Repair and Maintenance Activities
Question (23002-18381)
If a renovator disrupts 6 square feet or less of painted surface per room in several rooms inside one
property, does the RRP Rule apply?
Answer
No, as long as no prohibited work practices are used and the work does not involve window replacement
or demolition of painted surfaces. The exception to the RRP rule for work that disrupts 6 square feet or
less of painted surface applies to each individual room and is inclusive of all work done in the room in any
30-day period.
Question (23002-18379)
If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of
one property, does the RRP Rule apply?
Answer
Yes. To qualify for the exception for minor repair and maintenance activities, the total amount of exterior
paint disrupted must be 20 square feet or less. In addition, the job must not use prohibited practices or
involve window replacement or demolition of painted surfaces.
Question (23002-19749)
My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the
new carpet, but sometimes there is. How do I know when I need to comply with the RRP Rule?
Answer
If when installing the carpet you disrupt 6 square feet or less of painted surface per room, the job is not
covered by the RRP Rule.
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Question (23002-18484)
If I am insulating a multi-family building, does the standard for interiors of 6 square feet or less of
disrupted painted surface, or the standard for exteriors of 20 square feet or less of disrupted painted
surface apply to the whole building or can it be applied to each separate unit?
Answer
For interiors, the exception for work that disrupts 6 square feet or less of painted surface applies to each
individual room and is inclusive of all work done in the room in any 30-day period. For exteriors, to qualify
for the exception for minor repair and maintenance activities, the total amount of exterior paint disrupted
must be 20 square feet or less. In addition, the job must not use prohibited practices or involve window
replacement or demolition of painted surfaces.
Question (23002-15677)
Does the minor maintenance exception mean that if I drill 1-inch holes in a painted surface to blow
insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior
before I had to comply with the RRP Rule? Or does it mean that the work is covered by the RRP Rule
once I insulate more than 6 square feet of interior wall area (basically 1 hole) or more than 20 square feet
of exterior wall area?
Answer
The exception is based on the area of paint disrupted, which in this example is based on the combined
areas of the holes drilled in the wall.
Question (23002-18429)
If an electrician or plumber, working in a different room from the contained renovation project, needs to
drill or cut a hole six square feet or less in size to chase a wire or pipe, does the RRP rule apply to that
work?
Answer
As long as 6 square feet or less of painted surface in that room is disrupted with 30 days, including the
work done by the electrician or plumber, and the job does not use prohibited practices or involve window
replacement or demolition of painted surfaces, the minor repair and maintenance exception to the RRP
rule applies.
Question (23002-18383)
If a renovator removes less than 6 square feet of crown molding, is that considered demolition? Does it
matter whether the molding will be discarded, replaced with new molding, or reinstalled?
Answer
It depends on how the molding is removed. If a renovation activity removes or otherwise disrupts a
painted component in a way that destroys or ruins the component, the activity is a demolition.
Question (23002-18515)
If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
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Answer
Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to
make the hole is demolition of the surface, so the minor repair and maintenance exception does not
apply. Making the hole using a cut-out technique that does not destroy the section of the wall that is
removed is not demolition, and the minor repair and maintenance exception would apply.
Question (23002-19724)
My company installs new or replacement seamless gutters. We install the gutters using self-tapping 3/16”
to ¼” screws and the cumulative size of the total number of holes is only a couple of square inches. If the
job does not involve sanding, scraping, repainting, repair, replacement or reconditioning of the fascia
surface, is it covered by the RRP Rule?
Answer
Minor repair and maintenance activities are not subject to the requirements of the RRP Rule. For exterior
renovations, minor repair and maintenance activities are those activities that disrupt 20 square feet or
less of painted surface, and do not use prohibited practices or involve window replacement or demolition
of painted surfaces.
If the job described, when combined with other renovation work on the exterior of the building, does not
disrupt more than 20 square feet of painted surface, and does not use prohibited practices or involve
window replacement or demolition of painted surfaces, it is a minor repair and maintenance activity that is
not subject to the requirements of the RRP rule.
Question (23002-19163)
Is replacing a pane of glass or fixing a broken window balancer a renovation covered by the RRP Rule?
Answer
It depends. Replacing a pane of glass or fixing a broken window balancer can disturb paint. If the job
disrupts more than 6 square feet of painted surface per room, the job is not considered minor repair and
maintenance and it is covered by the RRP Rule. When removing a component, calculate the 6 square
foot area based on the surface area of the component.
Question (23002-15404)
Does drilling holes in window frames to install window treatments such as shades and shutters qualify as
minor repair and maintenance?
Answer
Yes, as long as the installation does not disturb more than six square feet of painted surface per room
within a 30 day period.
Question (23002-14294)
As a floor covering installer I use an undercut saw to remove a small amount of wood at the bottom of
baseboards and door casings. I am only disturbing the paint in the 1/8 inch cut of the blade. How do I
calculate the area of the paint that is affected for purposes of the minor repair and maintenance
provision?
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Answer
A job is considered minor repair and maintenance, rather than a renovation covered by the RRP Rule, if it
disrupts 6 square feet or less of painted surface per room in a 30 day period. Calculate the area of
painted surface disrupted based on the surface area of the component that is disrupted. For example,
cutting a 1-inch strip off a door that is 36 inches wide would disrupt 36 square inches of painted surface,
regardless of the width of the cut made by the saw blade.
Question (23002-23857)
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine
whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of
painted surface disrupted using the standard for interior renovations (6 square feet or less in the room
where the door is located) or for exterior renovations (20 square feet or less)?
Answer
If replacing the door and frame disrupts more than 6 square feet of interior painted surface in the room
where the door is located, or more than 20 square feet on the exterior of the building, the job does not
qualify as a minor repair and maintenance activity, and the RRP Rule applies. Calculate the area of
painted surface disrupted based on the surface area of the component that is disrupted. In addition, to
qualify as a minor repair and maintenance activity, the job must not use prohibited practices or involve
window replacement or demolition of painted surfaces.
Question (23002-31779)
My firm removes and replaces garage doors. The garage doors are typically made up of multiple panels,
each of which has an exterior painted surface area of less than 20 square feet. Aggregated, the exterior
painted surface area of all the panels exceeds 20 square feet. If we disturb the paint on just one of the
door panels, is that activity subject to the RRP Rule?
Answer
An activity that disturbs less than 20 square feet of exterior painted surface and otherwise meets the
definition of minor repair and maintenance is not subject to the RRP Rule. However, the RRP Rule
provides that when removing painted components, or portions of painted components, the entire surface
area removed is the amount of painted surface disturbed.
In this case, application of the RRP Rule is dependent on how much of the garage door your firm intends
to remove and replace. If you disturb a painted surface on a single panel while removing and replacing
the entire garage door (i.e., all the panels), you must aggregate the surface area of all the panels.
Similarly, if you disturb a painted surface on a single panel while removing and replacing more than one
panel, you must aggregate the surface area of those panels being removed to determine whether or not
the RRP Rule applies. If, however, you disturb a painted surface on a single panel while removing and
replacing only that panel, and the activity disturbs less than 20 square feet of exterior painted surface and
otherwise meets the definition of minor repair and maintenance (e.g., not demolition or using prohibited
practices), such an activity would be considered minor repair and maintenance, and therefore would not
be subject to the RRP Rule.
Question (23002-32366)
Please provide guidance on how the Agency will interpret the term “minor repair and maintenance
activities.” Is the replacement of a window measuring less than 6 square feet considered minor repair
and maintenance? If I use a torch to burn off less than 20 square feet of paint on exterior fixtures, is that
considered minor repair and maintenance? What does EPA mean by demolition? How is the size of the
29
disrupted surface calculated? If I sand 5 square feet of paint on one wall on one day, and 5 square feet
on a different wall in the same room on the next day, are both projects considered minor repair and
maintenance?
Answer
“Minor repair and maintenance” is defined in 40 CFR 745.83 as activities that disrupt less than 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 § 745.85(a)(3) are used
and where the work does not involve window replacement or demolition of painted surface areas. Even if
an entire window measures less than 6 square feet, the replacement of any size window is a renovation,
not minor repair and maintenance, because it is specifically excluded from the definition of “minor repair
and maintenance.” Similarly, because torch burning is prohibited by 745.85(a)(3), no activity involving
torch burning can be considered minor repair and maintenance. For the purposes of the definition of
minor repair and maintenance, EPA considers demolition to be an activity that removes or otherwise
disrupts a painted component in a way that destroys or ruins the component.
The definition of “minor repair and maintenance” provides some guidance on how to measure the surface
disrupted: “When removing painted components, or portions of painted components, the entire surface
area removed is the amount of painted surface disturbed.” In other cases, when painted surfaces are
being disturbed or disrupted, but not completely removed, the disrupted surface area is the area being
actively disturbed. For example, when spot sanding to prepare a surface for painting, the area of the
surface that was actually sanded is the surface area disrupted.
Finally, the definition of “minor repair and maintenance” states that “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.” Therefore,
sanding 5 square feet of paint in the same room on two different days within the same 30 day period must
be considered the same job, which would be a renovation because it does not meet the definition of
“minor repair and maintenance.”
Renovations for Compensation
Question (23002-32214)
Is work done by friends, a brother-in-law, or volunteers covered by the RRP Rule if no one is
compensated?
Answer
No. The RRP Rule only applies to renovations performed for compensation. Compensation includes pay
for work performed, such as that paid to contractors and subcontractors; wages, such as those paid to
employees of contractors, building owners, property management companies, child-occupied facility
operators, State and local government agencies, and non-profits; and rent for target housing or public or
commercial building space.
Even if you are not required to comply with the RRP Rule, it is important to be aware that renovation
activities can create hazardous lead dust and chips. The key to protecting yourself and your family during
renovation is to use lead-safe work practices. Information on these practices is available in the EPA Small
Entity Compliance Guide to Renovate Right, available in English and Spanish by visiting

http://www.epa.gov/lead/pubs/renovation.htm

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Question (23002-19773)
My non-profit home repair organization performs renovations using mostly volunteers. We do some
painting and scraping but we do mostly roof repair and interior work (bathrooms, kitchens, etc.).
Obviously, we want to be in compliance with the law and we want our volunteers, staff and homeowners
to be safe. Equally, we want to make sure that we are able to continue to offer this valuable service to
our community. Is my organization’s work covered by the RRP Rule?
Answer
The RRP rule covers renovations performed for compensation. If the organization is compensating
anyone for the work (for example, a paid supervisor), then the renovation is covered by the RRP Rule.
This is the case even though the organization has non-profit status.
The organization may also need to become certified as a firm. Beginning April 22, 2010, an organization
that performs, offers, or claims to perform renovations covered by the RRP Rule must be certified by
EPA. A non-profit organization that offers to renovate the property of a third party for compensation, or
that performs the renovation, must be certified as a firm. The organization must comply with all the
requirements of the rule that apply to firms performing renovations. This includes having a certified
renovator direct the work and provide on-the-job training to all uncertified workers, including volunteers.
Question (23002-17957)
How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for
example, to church groups who, as part of their missionary work, are making improvements for lowincome
residents?
Answer
The RRP Rule applies to renovations performed for compensation. Compensation includes pay for work
performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees
of contractors, building owners, property management companies, child-occupied facility operators, State
and local government agencies, and non-profits; and rent for target housing or public or commercial
building space. Donations, including donations of materials or of the time of volunteers, are not
compensation. If the organization is compensating anyone for the work (for example, a paid supervisor),
then the renovation is covered by the RRP Rule. This is the case even though the organization has nonprofit
or not-for-profit status.
The organization may also need to become certified as a firm. Beginning April 22, 2010, an organization
that performs, offers, or claims to perform renovations covered by the RRP Rule must be certified by
EPA. A non-profit organization that offers to renovate the property of a third party for compensation, or
that performs the renovation, must be certified as a firm. The organization must comply with all the
requirements of the rule that apply to firms performing renovations. This includes having a certified
renovator direct the work and provide on-the-job training to all uncertified workers, including volunteers.
Question (23002-18382)
If a renovator is only reimbursed for materials, would that be considered compensation?
Answer
No. Compensation includes pay for work performed, such as that paid to contractors and subcontractors;
wages, such as those paid to employees of contractors, building owners, property management
companies, child-occupied facility operators, State and local government agencies, and non-profits; and
rent for target housing or public or commercial building space. Reimbursement for the cost of materials is
not compensation.
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Question (23002-23856)
When repainting rental housing, if the landlord supplies the paint and materials, and the tenant does the
labor without receiving money, credit toward rent, or other compensation, does the RRP Rule apply?
Answer
No. The RRP Rule only applies to renovations performed for compensation.
Question (23002-19765)
My local community has formed a “Long Term Recovery Committee” to assist in the rebuilding and
recovery efforts following a natural disaster. The committee, which is a coalition of member agencies
from the faith community, nonprofit agencies, government programs, businesses and individual donors,
gathers monetary and material donations and provides assistance to families with unmet needs via
volunteer work crews and/or contracted skilled labor. Are the rebuilding and recovery efforts organized
by this committee subject to the RRP Rule?
Answer
It depends. Renovation activities that are performed for free by committee volunteers are not covered
under the Rule because they are not “renovations performed for compensation.” Donations, such as
donations of materials or of the time of volunteers, are not compensation. Conversely, renovation
activities that are performed by renovators or firms who are compensated for their services are subject to
all requirements under the Rule. This applies if the committee is compensating anyone for the work (ex.
a paid supervisor), even if the committee has non-profit or not-for-profit status.
Question (23002-32412)
I have a for-profit business where I purchase houses or apartments and renovate them. I initially try to
find tenants for the property, but if I can’t find tenants, then I try to sell the property. I pay for and perform
all of the work myself, and keep all profits from the sale or lease. Is my renovation work covered by
RRP?
Answer
Yes. Persons who are in the business of buying, renovating, and selling or leasing homes for a profit are
performing renovations for compensation and would be subject to all requirements under the Rule.
Target Housing
Question (23002-17116)
How does a firm or renovator document or confirm the age of the structure? Is a signed statement by the
occupant sufficient? Can publicly available information such as tax records, etc. be sufficient?
Answer
Renovation firms are responsible for determining the age of the property. The property owner is likely to
be a good source of information on the age of a home or other building, but the firm may not rely on the
statement of the property owner as to the construction date of the building if there is evidence to the
contrary. If in doubt, renovation firms can use tax assessments, property records, and similar information
to determine the date of construction. Finally, the renovation firm may always assume that a home or
child-occupied facility was constructed before 1978.
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Question (23002-15716)
Does the term “target housing” mean just low income housing, or any home built before 1978 regardless
of the financial status of the occupants?
Answer
“Target housing” means any housing constructed prior to 1978, except housing for the elderly or persons
with disabilities (unless any child who is less than six years of age resides or is expected to reside in such
housing) or any 0-bedroom dwelling. The income of the occupants of the housing is not relevant.
Question (23002-18146)
I understand that the RRP Rule does not apply to housing for the elderly. Does this term refer to specific
built houses in 55+ communities or does it refer to all residential homes with this demographic living
there?
Answer
“Housing for the elderly” means retirement communities or similar types of housing reserved for
households composed of one or more persons 62 years of age or more at the time of initial occupancy.
Housing for the elderly is not subject to the RRP Rule unless a child who is less than six years of age
resides or is expected to reside in the housing.
Question (23002-18144)
I understand that the RRP rule does not apply to dormitories. Does the rule apply to a unit of student
housing made up of two bedrooms, a living room, and kitchen?
Answer
Yes. While the RRP rule does not apply to zero-bedroom housing, the type of housing described is not
zero-bedroom housing. Zero-bedroom housing means a residential dwelling in which the living area is
not separated from the sleeping area. Examples include efficiencies, studio apartments, and dormitory
housing. In the example given, the bedrooms provide sleeping areas that are separate from the living
area, so the housing does not meet the definition of zero-bedroom housing and the RRP rule applies.
Question (23002-17978)
I am a contractor a couple years from retirement and I am closing down my business. I do not plan to
become certified under the RRP Rule. My understanding is that I can continue working on homes built
after 1978?
Answer
The RRP Rule does not apply to renovations in housing built in 1978 or later.
Question (23002-19840)
Older hotels built before 1978 are knocking down walls, combining two hotel rooms, and making their
units two-room or even three-room suites. My understanding has been that single hotel rooms are
considered zero-bedroom dwellings. Does the RRP Rule apply when one-room units are converted to
two-room suites?
33
Answer
Yes. A renovation performed for the purpose of converting a building, or part of a building, into target
housing or a child-occupied facility is a renovation for purposes of the RRP Rule.
Hotel suites that provide a sleeping area that is separate from the living area are covered by the RRP
Rule because they are not zero-bedroom dwellings. A zero-bedroom dwelling is a residential dwelling in
which the living area is not separated from the sleeping area. The term includes efficiencies, studio
apartments, dormitory housing, military barracks, and rentals of individual rooms in residential dwellings.
Question (23002-22024)
What is “housing for persons with disabilities”?
Answer
“Housing for persons with disabilities” means housing that is designed to meet the special needs of
persons with disabilities and that is reserved for such persons. A person with a disability may include a
person who has a disability attributable to a mental or physical impairment, or a person with a chronic
mental illness. EPA recommends that you check with state or local housing authorities if it is unclear
whether a particular property meets this definition.
Question (23002-22148)
What is a studio apartment?
Answer
A studio apartment is an apartment in which the living area is not separated from the sleeping area.
Question (23002-18378)
If a renovation is taking place in a home built in 1950, but in an addition that was built in 1980, does the
RRP Rule apply to the renovation?
Answer
Yes. The RRP Rule applies to a renovation in target housing unless it has been determined that the
components affected by the renovation are free of paint or other surface coatings that contain lead equal
to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight.
For purposes of the RRP Rule, only a certified renovator, inspector or risk assessor can make this
determination. Certified renovators must base their findings on the results of an EPA-recognized test kit
or paint chip sampling. See 40 CFR 745.82(a)(2) and (3). Certified inspectors or risk assessors may also
base their findings on the results of an EPA-recognized test kit, or can use the additional testing
methodologies (ex. XRF analysis, etc.) allowed under their certifications. See 40 CFR 745.82(a)(1).
Notably, certified inspectors and risk assessors may determine that a component does not contain leadbased
paint because it has been replaced after 1978.
Any firm performing paint chip sampling or testing for the presence lead-based paint for RRP purposes
must keep a copy of the written determination and make the records available to EPA if requested.
34
Question (23002-14024)
Are renovations in short-term lodgings, such as hotels and motels, time share properties, and homeless
shelters, covered by the RRP Rule?
Answer
Yes, if the property renovated is not a zero-bedroom dwelling. A zero-bedroom dwelling is a residential
dwelling in which the living area is not separated from the sleeping area. The term includes efficiencies,
studio apartments, dormitory housing, military barracks, and rentals of individual rooms in residential
dwellings.
The short-term nature of a property’s occupancy does not in itself exempt it from the RRP Rule.
Question (23002-15690)
Does the RRP Rule apply to renovations in mobile homes?
Answer
Yes, if the mobile home meets the definition of target housing. “Target housing” is any housing
constructed before 1978, except housing for the elderly or persons with disabilities (unless any child who
is less than six years of age resides or is expected to reside in the housing), or a zero-bedroom dwelling.
A zero-bedroom dwelling is a residential dwelling in which the living area is not separated from the
sleeping area.
Question (23002-31782)
Are renovations performed on detached garages, sheds and other detached outbuildings on the property
subject to the RRP Rule?
Answer
Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the
residential portion of the property, and (2) associated with the residential use of the property. As a
practical matter, the entire property of most urban and suburban residential lots is normally considered to
be associated with residential use.
In the case of real property that is used for nonresidential as well as residential purposes, a judgment
should be made as to which part of the property is associated with residential use. For example, if the
structure is in such close proximity that the renovation would pose a risk to those using the property for
residential purposes, the structure would be considered associated with the residential use of the property
and the RRP Rule would apply.
Question (23002-31783)
My firm plans on doing renovation work on a storage building which is detached from, but a part of, an
apartment complex. The apartment complex was constructed prior to 1978 and would be considered
target housing. The storage building, however, was constructed after 1978. Will our work on the storage
building be covered under the RRP Rule?
Answer
The RRP Rule does not apply to renovations of a detached post-1978 building or structure, even if the
building or structure is located on the residential portion of the property or associated with the residential
use of the property.
35
Question (23002-32492)
Are prison facilities and juvenile detention centers built before 1978 considered target housing?
Answer
Target housing means any housing constructed prior to 1978. Certain parts of prison facilities and
juvenile detention centers that house incarcerated persons are housing. However, as a practical matter,
EPA believes that the most parts of prisons and juvenile detention centers that would be considered
housing are also zero bedroom dwellings (i.e. a residential dwelling in which the living area is not
separated from the sleeping area) and therefore not subject to the RRP Rule.
Question (23002-32518)
Does zoning affect the target housing determination? For example, would a pre-1978 house that is
zoned for commercial or office use, but used for residential purposes be considered target housing?
Answer
In determining whether a pre-1978 property is target housing, it is the actual or intended use of the
property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended
to be used as a residence, even if only temporary, is target housing regardless of its zoning classification.
The actual or intended use of a property is often made apparent by the type of building features it
contains. Residential use, for example, is likely when the building contains a kitchen, bathroom(s),
bedroom(s), living room, etc.
Question (23002-32519)
How would RRP classify a pre-1978 property that is used for both residential and non-residential
purposes? For example, would RRP apply to renovations in a pre-1978 house that is partially used as a
residence and partially used as a legitimate commercial business?
Answer
EPA has interpreted target housing to include pre-1978 buildings or structures that are (1) located on the
residential portion of the property, and (2) associated with the residential use of the property. In other
words, if a portion of residential property is used for nonresidential purposes, the portion will nonetheless
be considered target housing if it is associated with residential use. The portion would be considered
associated with the residential use of the property if it is in such close proximity that the renovation would
pose a risk to those using the property for residential purposes.
In the above example, if the room or structure containing the commercial business was (1) on the
residential portion of the property, and (2) was in such close proximity to the residential use of the
property that a renovation would pose a risk to the residents, the room or structure would be considered
target housing and the RRP Rule would apply.
Question (23002-33291)
Are sleeping areas in building built before 1978, such as those in fire and police stations, considered
target housing?
36
Answer
Firehouses and police stations are not target housing. Therefore places of temporary rest for employees
in these buildings, such as sleeping rooms, are not subject to the RRP Rule.
Child-Occupied Facilities
Question (23002-18778)
Is a health care facility or hospital covered under the RRP Rule if it meets the definition of a childoccupied
facility?
Answer
Yes. The RRP Rule defines a child-occupied facility as a building, or portion of a building, constructed
prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days
within any week (Sunday through Saturday period), provided that each day’s visit lasts at least three
hours and the combined weekly visits last at least six hours, and the combined annual visits last at least
60 hours.
Question (23002-18212)
If a building contains a child-occupied facility, must all renovations in the building follow the RRP Rule?
Answer
Not necessarily. “Child-occupied facility’’ means a building, or portion of a building, constructed prior to
1978, visited regularly by the same child, under 6 years of age, on at least two different days within any
week (Sunday through Saturday period), provided that each day’s visit lasts at least 3 hours and the
combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Childoccupied
facilities may include, but are not limited to, day care centers, preschools and kindergarten
classrooms. Child-occupied facilities may be located in target housing or in public or commercial
buildings.
With respect to common areas in public or commercial buildings that contain child-occupied facilities, the
child-occupied facility encompasses only those common areas that are routinely used by children under
age 6, such as restrooms and cafeterias. Common areas that children under age 6 only pass through,
such as hallways, stairways, and garages are not included. In addition, with respect to exteriors of public
or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only
the exterior sides of the building that are immediately adjacent to the child-occupied facility or the
common areas routinely used by children under age 6.
Areas of a building that fall outside this definition are not “child-occupied facilities” for purposes of the
RRP rule.
Question (23002-15688)
Does the RRP Rule apply to office buildings, stores, and other commercial buildings?
Answer
No, unless the renovation is taking place in a child-occupied facility that is located in a commercial
building. “Child-occupied facility’’ means a building, or portion of a building, constructed prior to 1978,
visited regularly by the same child, under 6 years of age, on at least two different days within any week
(Sunday through Saturday period), provided that each day’s visit lasts at least 3 hours and the combined
37
weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours. Child-occupied
facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms.
Child-occupied facilities may be located in target housing or in public or commercial buildings.
With respect to common areas in public or commercial buildings that contain child-occupied facilities, the
child-occupied facility encompasses only those common areas that are routinely used by children under
age 6, such as restrooms and cafeterias. Common areas that children under age 6 only pass through,
such as hallways, stairways, and garages are not included. In addition, with respect to exteriors of public
or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only
the exterior sides of the building that are immediately adjacent to the child-occupied facility or the
common areas routinely used by children under age 6.
Areas of a building that fall outside this definition are not “child-occupied facilities” for purposes of the
RRP rule.
Question (23002-22691)
What is the definition of a child under 6 years of age?
Answer
A child under six years of age is a child that is less than 72 months old.
Question (23002-13611)
A child’s consecutive visits to a particular building (such as a hospital) can technically qualify that building
as a child-occupied facility, even if the visits were an isolated or rare event. How long does such a
building remain a child-occupied facility?
Answer
A building, or portion of a building, is defined as a child-occupied facility when visited regularly by the
same child, under 6 years of age, on at least two different days within any week, provided that each day’s
visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual
visits last at least 60 hours. The determination of whether a building is a child-occupied facility (i.e.
whether a child under age six regularly visits the building as set forth above) requires an accounting of
annual visits. Therefore, whenever a building meets the definition of a child-occupied facility, it remains
so for at least a period of one year. After that period, it may be determined that the building no longer
meets the definitions of a child-occupied facility.
Testing Painted Components
Question (23002-18782)
Is a lead-based paint inspection, performed by a certified inspector or risk assessor, that includes a
written determination that various building components are free of paint or other surface coatings
containing lead equal to or in excess of 1.0 milligrams per square centimeter (mg/cm2) or 0.5% by weight
sufficient to determine compliance with requirements of the RRP rule?
Answer
The RRP Rule does not apply to target housing where a certified inspector or risk assessor has
determined that the components affected by the renovation are free of regulated lead-based paint or that
a property is free of lead-based paint for the purposes of the Lead Disclosure Rule.
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The RRP Rule does not require certified inspectors or certified risk assessors to test each and every
component that will be affected by a renovation. Certified inspectors or risk assessors are free to conduct
representative sampling, so long as the components to be tested are chosen in accordance with
documented methodologies, such as the HUD Guidelines. However, because certified renovator training
does not cover representative sampling protocols, certified renovators using EPA-recognized test kits or
performing paint chip sampling to determine the applicability of the RRP Rule must test each and every
component that will be affected in order to determine that the RRP Rule does not apply to a particular
renovation.
Question (23002-18015)
I am an owner/agent for an apartment community built prior to 1978. In 2004, testing of a random sample
of units was completed by a certified testing firm. The results were negative for lead paint but positive for
lead dust. With the positive lead dust result, are we required to comply with the RRP Rule?
Answer
No. As long as the determination that the units are free of lead-based paint was made by an inspector or
risk assessor certified by EPA or by an authorized State or Tribal program, renovations in the building are
not covered by the RRP Rule.
Question (23002-32215)
When testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized
test kit, must I test every component affected by the renovation?
Answer
Yes. Because certified renovator training does not cover sampling protocols, certified renovators using
EPA-recognized test kits or performing paint chip sampling to determine the applicability of the RRP Rule
must test each and every component that will be affected in order to determine that the RRP Rule does
not apply to a particular renovation.
Question (23002-18218)
If a certified inspector or risk assessor determines that a component was installed post-1978 and is
therefore free of lead-based paint, can the renovation firm rely on this determination?
Answer
Yes, as long as the renovation firm has obtained a copy of the determination. The firm must retain a copy
of the determination for three years after completion of the renovation.
Question (23002-18347)
If a property is tested by a certified renovator, inspector, or risk assessor and found to be free of leadbased
paint, does any testing need to be done again if work is done on the property several years later?
Answer
Where a certified renovator uses an EPA-approved test kit or performs paint chip sampling to determine
that a component is free of lead-based paint, or a lead-based paint free determination is made by a
certified inspector or risk assessor, firms performing renovations on the same components may rely on
these results as long as the records are still available. Lead-based paint free determinations by a
39
certified inspector or risk assessor are valid for both the tenant disclosure exemption from 1018 and the
RRP Rule and they do not expire.
Emergency Renovations
Question (23002-32367)
What is an “emergency renovation” for purposes of the RRP Rule?
Answer
Emergency renovations are those performed in response to situations necessitating immediate action to
address safety or public health hazards or threats of significant damage to equipment and/or property.
The need for immediate action relieves firms from the pre-renovation education requirements. Likewise,
emergency renovations are exempt from the warning sign, containment, waste handling, training, and
certification requirements to the extent necessary to respond to the emergency. The cleaning, cleaning
verification, and recordkeeping requirements still apply.
Once the portion of the repair that addresses the source of the emergency is completed, however, the
justification for the exemption from the rule is no longer operative; therefore, any additional renovation
activity needed to return the renovation work area to its pre-emergency condition would be subject to the
requirements of the rule. Thus, for example, repairing a hole in a wall after a broken water pipe has been
repaired would be subject to the rule, as would repainting any water-stained walls or ceilings resulting
from the pipe break.
Question (23002-16822)
How do I know if a child has an EBL prior to my work if they haven’t had their blood lead tested recently?
Answer
It is never the renovation firm’s responsibility to determine whether a child has an elevated blood lead
(EBL) level.
Question (23002-15678)
Does the RRP rule apply to contractors working on homes damaged by a hurricane or other natural
disaster?
Answer
Damage from a major storm or other natural disaster could result in the need for emergency renovations.
Certain requirements of the RRP Rule do not apply to emergency renovations, which are renovation
activities that were not planned but result from a sudden, unexpected event that, if not immediately
attended to, presents a safety or public health hazard, or threatens equipment and/or property with
significant damage. The information distribution requirements do not apply to emergency renovations.
Weather-based emergency renovations are also exempt from the warning sign, containment, waste
handling, training, and certification requirements to the extent necessary to respond to the emergency.
These emergency renovations are not exempt from cleaning requirements, cleaning verification
requirements, or recordkeeping requirements.
40
Question (23002-19734)
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?
Answer
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.
Opt-Out Provision
Question (23002-32216)
What was the “opt-out” provision and when was it revoked?
Answer
On April 22, 2010, EPA issued a Final Rule revoking the opt-out provision of the 2008 RRP Rule. The
Rule was published in the Federal Register on May 6, 2010, and took effect on July 6, 2010.
As originally published in 2008, the RRP Rule allowed homeowners to “opt out” of the requirement to hire
a trained renovator who follows the RRP work practices if the homeowner certifies that (1) the renovation
will occur in the owner’s residence, (2) no child under age 6 or pregnant women resides there, (3) the
housing is not a child-occupied facility, and (4) the owner acknowledges that the renovation firm will not
be required to use the work practices contained in the RRP Rule.
Under the 2010 RRP Rule, homeowners are no longer permitted to “opt out” of having a renovation
performed without the RRP work practices.
Question (23002-19755)
My firm is replacing windows in a condominium. The owner of the condominium in which we are working
has signed the opt-out agreement. Is this type of exterior work considered work in a common area, and if
so, must other owners and occupants be informed about the job and given the opportunity to “opt-in”?
Answer
Exterior renovations of multi-unit target housing are considered renovations of a common area. A
common area is a portion of a building that is generally accessible to all residents or users of the building.
Renovations in common areas of owner-occupied multi-unit target housing, such as condominiums, must
be performed in accordance with the requirements of the RRP Rule unless the renovation firm obtains a
signed statement from each occupant with access to the common area.
41
Question (23002-18578)
If the home owner lives out of state and is not available to sign the opt-out statement, can the contractor
act as the agent for the home owner and sign the statement?
Answer
No. Only the owner of the housing can sign the opt-out statement. In addition, for the opt-out to be
available, the renovation must occur in the owner’s residence.
Question (23002-19761)
My firm started a renovation job before July 6, 2010 and the homeowner “opted-out”. Since the opt-out
provision was removed, what happens on July 6, 2010 (if the renovation activities are still ongoing but the
opt-out is no longer available)? Do I have to start following the rule requirements or can I still rely on the
opt-out statement from the owner?
Answer
EPA notes that “renovation” under the rule is defined, in general, as the modification of any existing
structure, or portion thereof, that results in the disturbance of painted surfaces. Thus, if all the paint
disturbing activities on a job have been completed before July 6, 2010, even though the job itself isn’t
finished, the requirements of the rule would not be triggered.
Generally, on or after July 6, 2010, activities that disturb painted surfaces must be performed in
accordance with the work practice standards and training requirements of the Renovation, Repair, and
Painting Rule. EPA believes that it is important that you minimize exposure of your clients and their
family to lead-paint dust.
However, EPA recognizes that in some cases it may be infeasible for a renovator with an opt-out to stage
a project in a manner that ensures completion of paint disturbing activities prior to July 6, 2010. In such
circumstances of infeasibility, EPA believes that renovators should be able to conclude paint disturbing
activities with the benefit of the opt-out even if the work continues briefly after July 6. However, any such
work that is not in full compliance with the rule requirements must be completed as expeditiously as
possible after July 6.
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Pre-Renovation Education
Question (23002-18832)
Is an electronic version of the lead information pamphlet sent to the customer via e-mail an acceptable
means of distributing the information?
Answer
The distribution of the lead information pamphlet (40 CFR § 745.83) via e-mail is an acceptable means of
distributing the pamphlet as long as the requirements of the Electronic Signatures in Global and National
Commerce Act (“Act”) (15 U.S.C. § 7001 et seq.) are met. The Act requires that the recipient of the
pamphlet, among other things, consents electronically to email delivery and in a manner that
demonstrates that the recipient can access the information in the form it will be provided. In addition, the
recipient must be allowed to withdraw this consent and be informed of the procedures for withdrawing
consent. Further, the recipient must be provided with a statement of the hardware and software
requirements for accessing and retaining the pamphlet.
Question (23002-21374)
What are the pre-renovation education requirements for a vacant apartment?
Answer
Firms performing renovations must provide pre-renovation education to the owner of the unit and to an
adult occupant. If the unit is not occupied, providing pre-renovation education to the owner of the unit is
sufficient. For additional information on these requirements, visit

http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf.

Question (23002-19756)
My firm performs renovations in large apartment complexes that often consist of several separate
buildings. If a renovation is to be performed in a common area in one building, are we required to provide
pre-renovation education to all tenants in all buildings?
Answer
When renovations are to be performed in common areas of multi-unit target housing, the RRP Rule
requires that the firm notify in writing both the owner of the building and each “affected unit.” See
745.84(b)(1) and (2). Common areas are those portions of a property generally accessible to
residents/users, and can exist on both the interior and exterior of the building.
Generally, the exterior of a building in a multi-building complex is likely to be accessible to all
residents/users in all buildings. Therefore, if a renovation is to be performed on an exterior common area,
all units would probably be “affected units” and require notification. Conversely, the interior of a building
is likely only to be accessible to the residents/users of that particular building. If a renovation is to be
performed in an interior common area of one building in a multi-building complex, then only the units
located in that building would be “affected” and require notification.
Firms may choose to comply with this requirement by mailing or hand delivering the “Renovate Right”
pamphlet and information to each “affected unit,” or by posting informational signs while the renovation is
ongoing describing the general nature and location of the renovation and anticipated completion date.
For additional information on these options, visit http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf.
As a practical matter, when “affected units” are difficult to determine, it may be easier or more efficient for
43
firms to meet the pre-renovation education requirements by posting informational signs in the appropriate
locations.
Question (23002-18349)
When multiple contractors are involved in a single renovation, must every contractor provide prerenovation
education? Can a certified firm assign its responsibility to a property management company?
Answer
All firms performing, offering or claiming to perform renovations are responsible for ensuring compliance
with the pre-renovation education requirements of the RRP Rule. However, it is unnecessary for the
same notifications and information to be given out repeatedly during a single renovation. Accordingly, a
firm may discharge the task by reaching agreement on who will provide the required pre-renovation
education, including an agreement to assign the task to a property management company. However,
even with such an agreement in place, each firm remains responsible for ensuring that the pre-renovation
education requirements are met.
Note: Firms may reach a similar agreement on who will prepare, retain and make available the necessary
records. See FQ 23002-18287.
Question (23002-23854)
When renovating a common area in an apartment building, must my firm provide pre-renovation
education to all tenants?
Answer
Yes. Firms performing renovations in common areas of multi-unit housing must comply with the
information distribution requirements before beginning renovation activities. The firm must provide the
owner of the common area being renovated (generally the building owner) with the “Renovate Right”
pamphlet and obtain a written acknowledgement of receipt. The firm must also provide the occupant of
each individual unit affected by the renovation with information describing the general nature and
locations of the renovation and the anticipated completion date. The firm may comply with this
requirement either by mailing or hand-delivering the pamphlet and information to each unit, or by posting
informational signs while the renovation is ongoing describing the general nature and locations of the
renovation and the anticipated completion date. For additional information on these requirements, visit

http://www.epa.gov/lead/pubs/sbcomplianceguide.pdf.

Question (23002-17773)
How can a firm comply with the pre-renovation education requirements if the owner desires that the
renovation begin immediately?
Answer
If the renovation is taking place in a owner-occupied dwelling unit, a firm must simply provide the owner
with a copy of the pamphlet, and either (1) obtain, from the owner, a written acknowledgement that the
owner has received the pamphlet, or (2) obtain a certificate of mailing at least 7 days prior to the
renovation.
If the owner does not occupy the dwelling unit (ex. the unit is leased), the firm must also provide an adult
occupant with a copy of the pamphlet, and either (1) obtain from the adult occupant a written
acknowledgement that the adult occupant has received the pamphlet, or (2) obtain a certificate of mailing
at least 7 days prior to the renovation. If an adult occupant is unavailable for signing an acknowledgment,
44
a firm may employ the self-certification procedures described in 40 CFR 745.84(a)(2)(i), which require the
firm to sign and date a statement attesting to the unavailability of the occupant and to the delivery of the
pamphlet to the dwelling.
As a reminder, if the work to be performed is an “emergency renovation,” as defined in 40 CFR 745.82(b),
the firm need not comply with the pre-renovation education requirements.
Question (23002-15799)
EPA’s pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care
Providers and Schools is currently not published in a Braille format. If working in target housing occupied
by persons who are blind, how should a firm comply with the pre-renovation information distribution
requirements?
Answer
In addition to distributing the regular pamphlet, a firm working in such an environment should take extra
precaution to ensure that the owner and occupants are aware of and understand the various dangers
associated with lead. If necessary, a firm should be prepared to verbally convey the information in the
pamphlet. Furthermore, because posted signs are not likely to warn blind occupants, a firm should also
take necessary steps to inform them of the location of the work area and advise them to stay outside of
the work area until the renovation is complete. Finally, a firm must prepare, sign and date a statement
describing the steps performed to notify occupants of the renovation and to provide them with the
pamphlet and information therein.
Question (23002-19753)
My firm is going to perform renovations in a school during the students’ summer break. During the
regular school year, the work area would fall under the definition of a child-occupied facility. However, no
children under age 6 will be present during this multiple month break period. Do we still have to comply
with the pre-renovation education requirements? If so, how should the information be distributed?
Answer
Yes. Even though the renovations will be taking place during a time when no children will be present, the
building (or portion of the building) will remain a child-occupied facility. Breaks, such as those for summer
or winter, are mere temporary disruptions in regular visits by children.
To provide the required information to the parents and guardian of children using the child-occupied
facility, a firm must either (1) mail or hand deliver the pamphlet and the renovation information to each
parent or guardian of a child using the child-occupied facility or (2) post informational signs describing the
general nature and locations of the renovation and the anticipated completion date. These signs must be
posted in areas where they can be seen by the parents or guardians of the children. The signs must also
be accompanied by a posted copy of the pamphlet or information on how interested parents or guardians
can obtain a free copy from the renovation firm.
Question (23002-18346)
If a project disturbs six square feet or less of interior surface or twenty square feet or less of exterior
surface, is it necessary for a firm to comply with the pre-renovation education requirements, such as
distributing the pamphlet?
Answer
No. A project that disturbs six square feet or less of interior painted surface or twenty square feet or less
of exterior painted surface is not considered a “renovation” under the Rule. It is considered a minor
45
maintenance and repair activity. As long as this type of disturbance does not involve any prohibited work
practice, window replacement or demolition of painted surfaces, a firm need not comply with the prerenovation
education requirements.
Question (23002-32354)
I regularly perform renovations and repairs to common areas in a large apartment complex. Must I
provide separate notice to the tenants for each one of these activities or is there any way to avoid such
duplication?
Answer
EPA recognizes that neither residents nor owners/managers/renovators are well-served if duplicative
notifications are frequently issued for similar renovation activities. There are several options
owners/managers/renovators may use to most efficiently provide residents in both single-family and multifamily
housing with the necessary information.
(A) Informational Signs – Owners/managers/renovators may provide notice of renovation
activities in common areas to affected tenants by posting signs. Signs must be posted while the
renovation is ongoing and they must describe the general nature and locations of the renovation
and the anticipated completion date. These signs must be posted in areas where they are likely
to be seen by the occupants of all of the affected units. The signs must be accompanied by a
posted copy of the “Renovate Right” pamphlet or information on how interested occupants can
review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to the
occupants.
(B) Category Notices – When renovation activities fall within distinct categories which are
performed on a cyclical or recurring basis (e.g., hallway painting), they may be grouped into a
single notice which describes the categories and provides a description of the locations affected.
To fulfill the requirement for providing timing information for the renovations,
owners/managers/renovators may either list the expected starting and ending dates, or employ
one of the other methods for meeting the timing requirements described below.
(C) Bi-monthly Notices – Section 745.84(a) of the RRP Rule requires that notifications be given
no more than 60 days before renovation activities begin. To minimize the number of notices
required, owners/managers/renovators may group all of the renovation activities expected to
occur over a 60-day period into a single notice distributed bi-monthly (every other month).
Renovation activities which were expected to occur within a given 60-day period, but which were
canceled or postponed, would simply be addressed in the subsequent bimonthly notice.
Including renovation notices in, or as an attachment to, a pre-existing newsletter is acceptable
provided that the cover of the newsletter prominently indicates that lead-based paint renovation
notices are contained in or attached to the newsletter.
Descriptions of Renovation Timing — Section 745.84(b)(2) of the RRP Rule requires that notices contain
the “expected starting and ending dates” of the proposed common area renovations. Although providing
specific dates is preferable wherever possible, the Agency is aware that unexpected events or
circumstances often result in delays and/or cancellations of planned renovation activities. To provide
sufficient flexibility without unduly compromising residents’ rights to information on the timing of
renovations in common areas, owners/managers/renovators may employ the following terminology to
address the following timing scenarios to avoid the needing to issue supplemental notices:
–“On or about” — acceptable when the expected starting or ending dates occurs one week before
or after the date given.
–“Early [insert month name]” – acceptable when the expected starting or ending dates occurs
during the first half of the specified month.
46
–“Late [insert month name]” — acceptable when the expected starting or ending dates occurs
during the second half of the specified month.
–“Ongoing for the 12-month period beginning [insert month name]” – acceptable when the
renovation commences within 60 days of the issuance of the notice and continues throughout the
12-month period. If an interruption of more than 60 days occurs anytime after commencement of
such activity, a new notice will be required before the activity may restart.
Descriptions of Renovation Ending Dates – Due to the inherent difficulties in estimating the duration of
many renovation activities, owners/managers/renovators are encouraged to make allowances for
unexpected delays when providing descriptions of ending days under Section 745.84(b)(2) of the RRP
Rule. Any estimated ending date with a rational basis is acceptable.
Question (23002-32355)
Must notifications for common area renovations always be provided to every unit in a multifamily housing
complex?
Answer
Not necessarily. When renovations are to be performed in common areas of multi-family housing (i.e.,
those portions of the property generally accessible to all residents/users), the RRP Rule requires that
each “affected unit” be notified in writing. See 745.84(b)(2). As a general matter, all units in the housing
are “affected unit(s)” and therefore must be provided with notice of a common area renovation.
However, in a minority of cases, certain areas of a property that meet the definition of common area may
in fact be used almost exclusively by an identifiable subset of tenants. For example, a common area
inside one building of a multi-building apartment complex is likely to be used exclusively by tenants of
only that building. See FQ 23002-19756. If a renovation is to be performed on such a common area,
EPA believes it appropriate to provide notice only to the truly affected units: the subset of tenant users.
Firms may notify residents/users either by distributing written notice to each affected unit or by posting
informational signs. Signs must be posted while the renovation is ongoing and they must describe the
general nature and locations of the renovation and the anticipated completion date. These signs must be
posted in areas where they are likely to be seen by the occupants of all of the affected units. The signs
must be accompanied by a posted copy of the pamphlet or information on how interested occupants can
review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to occupants.
Question (23002-32356)
The RRP Rule requires delivery of the “Renovate Right” pamphlet to the owner and occupants of target
housing. My firm was hired to perform a renovation in a pre-1978 apartment building. Is delivery of the
pamphlet to the property manager sufficient for purposes of delivery to the owner of the building?
Answer
Yes. Property managers are acting in the capacity of agents for the building owners. For this reason, a
property manager may receive, and acknowledge receipt of, the lead hazard pamphlet on behalf of the
owner.
In situations where property managers or their employees are performing the renovations themselves,
they are acting both as a “firm performing the renovation” and as agents for the owner. Documents in the
possession of an agent are also deemed to be in the possession of the person or entity represented by
47
the agent. Thus, no separate action is required to satisfy the requirement to deliver the “Renovate Right”
pamphlet to the owner.
Question (23002-32357)
May I use the pamphlet “Protect Your Family From Lead in Your Home” to meet my obligations for prerenovation
education under the RRP Rule?
Answer
No. As of December 22, 2008, only the pamphlet “Renovate Right” may be used to comply with the prerenovation
education requirements of the RRP Rule. “Protect Your Family” is still available for use during
real-estate sales and lease transactions and for general information.
Question (23002-32358)
If a renovation is to be performed on a private balcony of a single unit in a multi-unit target housing
building, does that activity trigger the common area notification requirements?
Answer
A determination of whether the balcony renovation falls within a common area depends upon the scope of
the renovation activity. A common area is a portion of a building that is generally accessible to all
residents/users. Thus, if the work area established to contain dust and debris from the renovation activity
is entirely within the confines of the private balcony, then the renovation is not generally accessible to
residents/users, not within a common area, and therefore not subject to the common area notification
requirements. However, if the work area is not entirely within the confines of the balcony (e.g., the
renovation will result in the release of dust, paint chips, or other construction debris to the ground beneath
the balcony), the firm must comply with the pre-renovation education requirements for common area
renovations.
Question (23002-32359)
Can notices for multi-family housing common area renovations be delivered to the mailboxes of dwelling
units, or only to the actual units themselves?
Answer
Should a firm decide to comply with the pre-renovation education requirements by hand delivering or
mailing “Renovate Right” pamphlets and notices, they may do so either through delivery of the notices
directly to tenant units or through delivery to tenant mailboxes. If mailbox delivery is used, both hand
delivery and delivery via U.S. mail are acceptable; however, U.S. mail deliveries must be sent 7 days prior
to the commencement of renovations and documented with a certificate of mailing.
As a practical matter, it may be easier or more efficient to provide notice of renovations in multi-family
housing common areas by posting signs. Signs must be posted while the renovation is ongoing and
describe the general nature and locations of the renovation and the anticipated completion date. These
signs must be posted in areas where they are likely to be seen by the occupants of all of the affected
units. The signs must be accompanied by a posted copy of the pamphlet or information on how
interested occupants can review a copy of the pamphlet or obtain a copy from the renovation firm at no
cost to occupants.
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Question (23002-32360)
If a firm completely blocks access to a common area for the duration of a renovation, does the renovator
still have to provide notifications to all tenants?
Answer
When tenant accessibility to a work site within a common area can be precluded for the duration of a
renovation, EPA considers that work site to be temporarily excluded from the common area of the
building for pre-renovation education purposes because it is not accessible to the residents and users of
the building. To qualify for this exclusion, however, the work site must be in an area which is enclosed by
a wall, fence, or other permanent or temporary physical barrier which truly prevents access by tenants
and other building users. Rope, tape lines, pylons, and similar work area designation devices which can
be easily surmounted or bypassed are not acceptable barriers for this purpose.
Question (23002-32361)
Does a renovator need to attempt personal delivery of the lead information pamphlet to a tenant more
than one time before utilizing the “self-certification of pamphlet delivery” option?
Answer
Personal delivery of the lead information pamphlet is preferable, wherever possible, because EPA
believes that tenants will be more likely to read the information if it is handed directly to them. It also
affords tenants an opportunity to raise concerns and ask questions about the renovation. EPA
recognizes, however, that personal delivery will not always be a viable option, especially when a
renovation needs to be commenced on short notice and an adult occupant of the apartment is not
available. Thus, the RRP Rule permits the person delivering the pamphlet to “self-certify” the delivery (40
C.F.R. 745.84(a)(2)(i)). Although it is recommended that delivery be attempted on more than one
occasion, a single good faith delivery attempt is acceptable for purposes of the RRP Rule.
NOTE: the self certification provisions apply only to pamphlet deliveries to rental units; renovators cannot
self-certify a pamphlet delivery to the owner of the dwelling unit. Pamphlet deliveries to unit owners must
be made directly to the owner, an agent of the owner, or via mailing.
Question (23002-32362)
In a typical co-operative apartment building, occupants do not own the individual units; rather they “own”
an undifferentiated share in the entire building and then “rent” back a specific unit from the co-operative
corporation. Similarly, in a typical condominium building, owners of individual units jointly own the
common areas of the building. For purposes of the pre-renovation education requirements, who are the
“owners” in such situations?
Answer
EPA recognizes that co-operative apartments (“co-ops”) and condominiums (“condos”) can be structured
in a variety of ways. For example, in the case of co-ops, a corporation (sometimes referred to as a “co-op
association”) is often established and owns all the units and common areas comprising the co-op; in such
circumstances, individual unit “shareholders” own shares in the corporation and also own occupancy
rights or lease a unit from the corporation. In the case of many condos, individuals hold title to their
individual units, and all condo unit owners jointly own the common areas (with a condo association
established to represent the interests of all the unit owners).
For purposes of the pre-renovation education requirements, the following general principles will be
applied:
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(a) If title to a building is held by a corporation which leases back dwelling units to individual corporation
shareholders, as in typical co-op apartment buildings, the corporation/association will generally be
considered to be the “owner” of the entire building, and individual resident shareholders, or persons who
rent from individual shareholders, will generally be considered to be tenants.
(b) In buildings where individuals hold title to specific dwelling units and jointly hold title to common areas
of the building, as in typical condo buildings, the individual owners each will be considered to be the
owners of his/her individual units, and the association (or its equivalent body composed of, or
representing, the group of owners) will be considered the owner of the common areas of the building.
See the table below for more specific guidance on meeting the pre-renovation education requirements as
they relate to various renovation scenarios in co-ops and condos.
COMPLIANCE WITH RRP PRE-RENOVATION EDUCATION REQUIREMENTS
FOR COOPERATIVE APARTMENTS AND CONDOMINIUMS
RENOVATION
LOCATION
RULE REQUIREMENT COMPLIANCE FOR
CO-OPS
COMPLIANCE FOR
CONDOS
Renovations inside
Individual Unit
1. Deliver Pamphlet to
Owner
§745.84(a)(1)
2. Deliver Pamphlet to
Adult Occupant
(Tenant)
§745.84(a)(2)
1. Deliver Pamphlet to
Co-op Corp./Assoc.
or Property Manager
2. Deliver Pamphlet to
Resident Co-op Share
holder or Adult
Occupant
1. Deliver Pamphlet to
Condo Unit Owner
(Or Agent of Owner)
2. If Condo is Leased,
Deliver Pamphlet to
Adult Occupant
Renovations in a
Common Area
1. Deliver Pamphlet to
Owner
§745.84(b)(1)
2. Deliver Notice to
Each Unit
§745.84(b)(2)
1. Deliver Pamphlet to
Co-op Corp./Assoc.
or Property Manager
2. Deliver Notice to
Each Unit
1. Deliver Pamphlet to
Condo Association
or Property Manager
2. Deliver Notice to
Each Unit
Notice of renovation activities in common areas can also be provided by posting signs. Signs must be
posted while the renovation is ongoing and they must describe the general nature and locations of the
renovation and the anticipated completion date. These signs must be posted in areas where they are
likely to be seen by the occupants of all of the affected units. The signs must be accompanied by a
posted copy of the pamphlet or information on how interested occupants can review a copy of the
pamphlet or obtain a copy from the renovation firm at no cost to occupants.
Question (23002-32363)
I am planning on sending the pamphlet via the United States Postal Service’s certificate of mailing
delivery method to a tenant who occupies a unit scheduled to be renovated. Does the tenant’s name
need to be addressed on the mailing, or is it acceptable to address the envelope to Attn:
Tenant/Occupant?
Answer
The tenant’s name and address must be indicated on the mailing. The RRP Rule requires a renovator to
provide the “Renovate Right” pamphlet to an adult in each unit. Therefore, the name and address of an
adult occupant in each unit must be indicated on the mailing. The renovator must also retain a receipt of
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a certificate of mailing from the Post Office at least 7 days before any renovation activities and retain a
record of notification for 3 years. See 40 CFR 745.84(a)(2) and 745.84(a)(2)(ii).
Question (23002-32364)
Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the
owner or occupant. What is the difference between a certificate of mailing and certified mail?
Answer
A certificate of mailing is a receipt showing evidence of mailing, while certified mail provides proof of
mailing and delivery of mail. When using the certificate of mailing option, no record is kept at the mailing
office and a receipt is not obtained when mail is delivered to the addressee. In contrast, the certified mail
option provides a receipt to the sender and a record of delivery is maintained by the Postal Service. For
additional information on sending the pamphlet via mail see FQ 23002-32363. If an individual chooses to
mail the pamphlet, a certificate of mailing is the minimum requirement (see 745.84(a)(1)(ii) and
745.84(a)(2)(ii)). An individual utilizing the mailing option also has the option to use the certified mail
process instead of the certificate of mailing.
Question (23002-32365)
If a renovation is to be performed on a common area in a pre-1978 building that contains a mix of studio
apartments (0-bedroom dwellings) and apartments with 1 or more bedrooms, what pre-renovation
education requirements would apply?
Answer
With respect to apartments with 1 or more bedrooms, the renovator must provide written notification to an
adult occupant of each dwelling no more than 60 days before any renovation activity commences. See
40 CFR 745.84(b)(2). As a reminder, notice of renovation activities in common areas may be provided to
affected tenants by posting signs. Signs must be posted while the renovation is ongoing, describe the
general nature and locations of the renovation and the anticipated completion date, and be posted in
areas where they are likely to be seen by the occupants of all of the affected units. The signs must be
accompanied by a posted copy of the pamphlet or information on how interested occupants can review a
copy of the pamphlet or obtain a copy from the renovation firm at no cost to occupants.
The studio apartments, however, are exempt from the RRP Rule because they fall under the definition of
a 0-bedroom dwelling: a residential dwelling in which the living area is not separated from the sleeping
area. Therefore, the renovator is not required provide the studio apartment occupants with notice of the
common area renovation.
As a practical matter, occupants of 0-bedroom dwelling are likely to receive notice anyways, given the
preference for providing notification for common area renovations by posting signs.
51
Work Practice Standards
Occupant Protection
Question (23002-23855)
When renovating the exterior of a high-rise building, does the requirement to close and seal doors and
windows within 20 feet of the renovation include closing those openings two-plus floors above the floor
where work is to be performed?
Answer
Not necessarily. When establishing containment for an exterior renovation on a multi-story building, you
must close all doors and windows within 20 feet of the renovation on the same floor as the renovation,
and close all doors and windows on all floors below that are the same horizontal distance from the
renovation. In certain situations, the renovation firm must take extra precautions in containing the work
are to ensure that dust and debris from the renovation does not contaminate other areas of the property.
The conditions at your renovation site may be such that closing and sealing doors and windows on floors
above the renovation is necessary to prevent these areas from being contaminated by dust and debris.
Question (23002-18093)
I have heard that if I use the warning signs EPA recommends in its model course I will be in violation of
OSHA rules. Is this true?
Answer
The picture of a warning sign in the EPA model course is not intended to satisfy OSHA’s requirements.
However, a firm subject to both rules can satisfy both the OSHA requirements and the RRP Rule
requirements by posting only the OSHA sign.
Firms must post signs clearly defining the work area and warning occupants and other persons not
involved in renovation activities to remain outside of the work area. To the extent practicable, these signs
must be in the primary language of the occupants. These signs must be posted before beginning the
renovation and must remain in place and readable until the renovation and the post-renovation cleaning
verification have been completed.
Containing the Work Area
Question (23002-32337)
What is the “work area?”
Answer
The “work area” is the area established by a certified renovator to contain the dust and debris generated
from a renovation. In other words, the work area is defined by the containment measures established by
the certified renovator. While a renovator has some discretion in setting up a sufficient amount of work
area containment, the RRP Rule sets forth minimum requirements for both interior and exterior
renovations.
For interior renovations, cover the floor surface, including installed carpet, with taped-down plastic
sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces
undergoing renovation or a sufficient distance to contain the dust, whichever is greater. Floor containment
52
measures may stop at the edge of the vertical barrier when using a vertical containment system
consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints
with the floor, ceiling and walls.
For exterior renovations, cover the ground with plastic sheeting or other disposable impermeable material
extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to
collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground
covering. Ground containment measures may stop at the edge of the vertical barrier when using a vertical
containment system. If the renovation will affect surfaces within 10 feet of the property line, the renovation
firm must erect vertical containment or equivalent extra precautions in containing the work area to ensure
that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent
properties. Vertical containment or equivalent extra precautions in containing the work area may also be
necessary in other situations in order to prevent contamination of other buildings, other areas of the
property, or adjacent buildings or properties.
Question (23002-32217)
In exterior containment if a large tree or shrub is within the work area can the plastic be placed around the
base and would the plant, however large, need to be covered also need to be covered?
Answer
The RRP Rule does not specifically address containment of trees or shrubs, but if dust, debris, or residue
remains in the tree or shrub at the conclusion of the job, the site will not pass visual inspection. The work
practices for exterior projects are based on a performance standard — the certified renovator or a worker
under the direction of the certified renovator must contain the work area so that dust or debris does not
leave the work area while the renovation is being performed. In addition, at the end of the job, a certified
renovator must perform a visual inspection to determine whether dust, debris or residue is still present on
surfaces in and below the work area, including windowsills and the ground. If dust, debris or residue is
present, these conditions must be eliminated and another visual inspection must be performed.
Question (23002-23220)
What is your recommendation if work has started and it begins to rain? What do we do with the water
that is on the plastic in the containment area?
Answer
Before beginning the renovation, the firm must isolate the work area so that no dust or debris (including in
the waste water) leaves the work area while the renovation is being performed. In addition, the firm must
maintain the integrity of the containment by ensuring that any plastic or other impermeable materials are
not torn or displaced and taking any other steps necessary to ensure that no dust or debris, including
water, leaves the work area while the renovation is being performed.
Some recommended options to prevent contaminated water from leaving the work site include:
Stop work and clean up the work site before rain begins. Proceed with interior work only.
Cover the area with a tarp to deflect the rainwater away from the work site.
Collect the water and dispose of it. Check with your local water treatment authority for local requirements
for handling and disposing of waste water.
Question (23002-23297)
What mil plastic is considered impermeable?
53
Answer
The regulation does not specify a particular thickness of plastic sheeting considered to be impermeable,
but rather includes a performance standard. The performance standard requires firms to isolate the work
area, prevent dust and debris from exiting, and ensure plastic sheeting is not torn or displaced. Certain
guidance materials recommend the use of 6 mil plastic sheeting, such as HUD’s Guidelines for the
Evaluation and Control of Lead-Based Paint in Hazards in Housing. However, for the purpose of
Renovation, Repair, and Painting regulation, a contractor should choose one or more layers of plastic
sheeting of a sufficient thickness to prevent puncture based on the circumstances of the particular project.
Question (23002-15162)
Do I need to cover a closet door with plastic?
Answer
Yes, if the door is inside the work area. When containing the work area during an interior renovation, the
firm must close windows and doors in the work area. Doors must be covered with plastic sheeting or
other impermeable material.
Question (23002-21413)
What are the requirements for covering doorways used to access the work area?
Answer
Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable
material in a manner that allows workers to pass through while confining dust and debris to the work area.
Question (23002-18246)
If a door is outside the work area but used by workers to enter and exit the room, does the door need to
be covered with plastic?
Answer
If the work area is smaller than the entire room, and the door is not within the work area, you do not need
to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of
containers of waste, must be free of dust and debris when leaving the work area.
Question (23002-19009)
Is interior containment required as well as exterior containment for an exterior window removal?
Answer
Yes, if exterior window removal creates dust and debris on the interior of the building. Before beginning
the renovation, the firm must isolate the work area so that no dust or debris leaves the work area while
the renovation is being performed. If removing windows from the exterior creates dust and debris on the
interior as well as the exterior of the building, then the firm must follow the requirements in the RRP Rule
for both interior and exterior containment. Window replacement typically disturbs paint on both the
interior and exterior of a building.
54
Question (23002-23847)
When must scaffolding and vertical shrouding be used on an exterior renovation when other buildings are
in close proximity to the work area?
Answer
The certified renovator or a worker under the direction of the certified renovator must contain the work
area so that dust or debris does not leave the work area while the renovation is being performed. The
certified renovator must be on site while the containment is established and is responsible for ensuring
that dust or debris does not spread beyond the work area. The extent to which scaffolding and vertical
shrouding are needed to meet this standard will depend on the conditions at the work site.
When performing exterior renovations you must cover the ground with plastic sheeting or other
disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing
renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property
line prevents 10 feet of such ground covering. Ground containment measures may stop at the edge of
the vertical barrier when using a vertical containment system. If the renovation will affect surfaces within
10 feet of the property line, the renovation firm must erect vertical containment or equivalent extra
precautions in containing the work area to ensure that dust and debris from the renovation does not
contaminate adjacent buildings or migrate to adjacent properties. Vertical containment or equivalent
extra precautions in containing the work area may also be necessary in other situations in order to
prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties.
Question (23002-32218)
The rules require exterior containment. At what point is the wind too strong to allow work to continue?
Answer
The work practices for exterior projects are based on a performance standard — the certified renovator or
a worker under the direction of the certified renovator must contain the work area so that dust or debris
does not leave the work area while the renovation is being performed. The certified renovator is
responsible for determining when the wind is so strong that no form of containment is adequate to keep
dust or debris from leaving the work site, and therefore work must stop until conditions improve such that
containment can be maintained.
Question (23002-18508)
If I paint without disturbing the surface of the existing paint, can I use a tarp instead of 6 mil plastic?
Answer
Yes. Projects that do not disturb a painted surface are not subject to the RRP Rule.
Question (23002-19908)
Plastic can be a slip hazard in some jobs, such as handling granite counter tops. This creates a more
immediate safety concern than protecting the floor from dust. Can’t I just clean the floor at the end of the
job?
Answer
No. For interior renovations, before beginning the renovation the renovation firm must cover the floor
surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the
55
work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to
contain the dust, whichever is greater.
You must comply with this requirement unless it is impossible to do so, for example, during portions of a
renovation project that involve removing flooring, sanding a hardwood floor, or removing or installing
carpeting. However, the RRP Rule allows you to place another, less slick, disposable surface (such as
paper) on top of the plastic sheeting as long as the plastic sheeting remains intact. Remove and dispose
of both surfaces at the completion of the job.
Even when plastic is used to cover the floor, you must also clean the floor at the end of the job.
Thoroughly vacuum using a HEPA vacuum. The HEPA vacuum must be equipped with a beater bar
when vacuuming carpets and rugs. Mop uncarpeted floors thoroughly, using a mopping method that
keeps the wash water separate from the rinse water, such as the 2-bucket mopping method, or using a
wet mopping system.
Question (23002-16472)
How can I use plastic sheeting in exterior renovations without creating a safety hazard? Moisture on the
plastic from precipitation can cause plastic sheeting to become slippery.
Answer
For exterior renovations, cover the ground with plastic sheeting or other disposable impermeable material
extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to
collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground
covering. Ground containment measures may stop at the edge of the vertical barrier when using a vertical
containment system. However, the RRP Rule allows you to place another, less slick, disposable surface
(such as paper) on top of the plastic sheeting as long as the plastic sheeting remains intact. Remove and
dispose of both surfaces at the completion of the job.
Question (23002-15754)
During exterior power washing, instead of plastic, can landscaping fabric or a similar material be used to
capture any paint chips or other debris, but permit the water to seep through?
Answer
No. Landscaping fabric is not an impermeable material.
Question (23002-18677)
In Chapter 4 of the EPA Certified Renovator Initial course, there is a PowerPoint slide showing plastic
sheeting being taped to the floor at several corners, but not around the entire perimeter of the plastic.
Must the plastic be “sealed” to the floor on all four edges by tape or just “secured or held” to the floor by
tape at several locations?
Answer
It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the
floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in
the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to
contain the dust, whichever is greater Floor containment measures may stop at the edge of the vertical
barrier when using a vertical containment system consisting of impermeable barriers that extend from the
floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls. It is up to the certified
renovator to determine how to cover the floor in such a way that dust and debris are captured by the
containment and the site can be cleaned at the end of the job.
56
Question (23002-15698)
Does the RRP rule require people working on a renovation to wear respirators, Tyvek(R) suits or other
personal protective equipment (PPE)?
Answer
EPA would like to clarify the requirements for personal protective equipment. The Occupational Safety
and Health Administration (OSHA) has requirements for personal protective equipment, EPA does not.
For many years, EPA has recommended the use of personal protective equipment as a way to protect
workers and to help ensure that leaded dust and debris does not leave renovation or abatement work
sites. EPA recommends that renovators make use of the minimum respiratory protection recommended
by the National Institute of Occupational Safety and Health (NIOSH) for environments where lead is
present, but respiratory protection is not required by the EPA regulations. In addition, disposable
clothing, if removed and disposed of before the workers leave the work site, can provide additional
protection for workers’ families by ensuring that no leaded dust or debris is carried home on worker
clothing. However, EPA does not require this and allows renovators to use other methods to ensure that
dust and debris does not leave the work area, including the HEPA vacuuming of clothing, tools, and other
items before they leave the work area.
Question (23002-19757)
My firm is replacing windows on the second floor of a 90 year old home. The windows are built into a bay
that projects out from a steeply pitched slate roof. When setting up exterior containment for this job, does
the RRP Rule require me to install plastic on the roof under the windows?
Answer
No. The RRP Rule does not require you to install plastic sheeting on the roof. You must cover the
ground with plastic sheeting or other disposable impermeable material in accordance with the
containment requirements at 40 CFR 745.85(a)(2).
Question (23002-23858)
When replacing an unpainted roof, sometimes sections of paint-covered lumber under the roof need to be
removed as well. If my firm removed damaged lumber from only certain sections of the roof, does only
this area need to be contained while we fix the lumber?
Answer
Yes. The renovation firm is responsible for containing the work area so that no dust or debris resulting
from the disturbance of a painted surface leaves the work area while the renovation is being performed.
Containment is not required for portions of the renovation outside this area that do not disturb painted
components. For exterior renovations, cover the ground with plastic sheeting or other disposable
impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a
sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10
feet of such ground covering. Ground containment measures may stop at the edge of the vertical barrier
when using a vertical containment system. If the renovation will affect surfaces within 10 feet of the
property line, the renovation firm must erect vertical containment or equivalent extra precautions in
containing the work area to ensure that dust and debris from the renovation does not contaminate
adjacent buildings or migrate to adjacent properties. Vertical containment or equivalent extra precautions
in containing the work area may also be necessary in other situations in order to prevent contamination of
other buildings, other areas of the property, or adjacent buildings or properties.
57
Question (23002-20687)
To avoid harming the homeowner’s grass and landscaping, may my firm fold up the plastic sheeting used
for containment at night and re-use it the next day?
Answer
Yes, as long as your firm does so in a way that contains any dust and debris on the plastic. One way to
accomplish this is to collect and remove the paint chips and debris from the plastic sheeting at the end of
each day, mist the sheeting, and fold it dirty side inward.
Question (23002-23786)
When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and
completely enclose the interior area in which I physically work. If these barriers are set up at a distance
less than six feet from the perimeter of the work surface, must I still extend the containment on the floor
beyond the vertical barrier to meet the six foot requirement?
Answer
No, provided that the vertical containment system consists of impermeable barriers that extend from the
floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls (40 CFR §
745.85(a)(2)(i)(D)). This type of vertical containment acts as the functional equivalent of a wall for
purposes of defining the work area. If the vertical containment meets these criteria the floor containment
measures may stop at the edge of the vertical barrier.
Unlike permanent walls, however, vertical containment barriers are subject to all containment cleaning
requirements including misting, inward folding, sealing, and proper disposal following the renovation. A
firm must also thoroughly clean an additional two feet beyond the vertically-contained work area. Finally,
during ingress or egress from the vertical enclosure, a firm must take precaution to ensure that dust and
debris on personnel, tools, and other items do not escape the work area.
Question (23002-23675)
What, if any, additional requirements or liabilities exist if a homeowner independently removes the
protective barriers and containment measures implemented by the firm during a renovation?
Answer
Before a firm begins a renovation, they are required to comply with all information distribution
requirements under the Rule and to post signs that clearly define the work area and warn occupants and
other persons not involved in renovation activities to remain outside of the work area. A firm that fails to
comply with these requirements is liable under the Rule.
If, however, a firm does comply with these requirements and a homeowner or other person nevertheless
removes the barriers, a firm must cease renovations until the necessary containment measures are reestablished.
A firm should also take additional steps to warn occupants or other persons of the dangers
of entering the work area or removing barriers.
Question (23002-19758)
My firm removes and replaces windows from the exterior of a building or residence. To contain dust in
the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and
58
affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior,
from which the window is removed and replaced. All removal and replacement work is performed from
the exterior, and we still apply the exterior containment measures as provided in the Rule. Does the
interior containment method described meet the requirements under the Rule?
Answer
No. Although EPA encourages your firm to continue to use this method of supplemental containment, the
minimum requirements of the RRP rule must still be met. Specifically, the floor surface must be covered
with taped down plastic sheeting or other impermeable material 6 feet the perimeter of the work surface,
or a distance sufficient to contain the dust, whichever is greater. Alternatively, your firm can install vertical
containment measures as described more fully in FQ 23002-23786.
Question (23002-18500)
If I mist and HEPA vacuum the plastic sheeting used by my firm for interior containment, can I move and
re-use plastic sheeting on the same day and job?
Answer
No. The Rule does not contemplate a permissible method of moving and re-using plastic sheeting used
for interior containment.
Question (23002-32208)
My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground
containment in a way that would enable our renovators to perform the work and still effectively contain
dust. In these cases we lay the ground containment, but also use vertical containment measures to
completely enclose the area in which we work. Is this a permissible method of exterior containment? If
the vertical containment is set up at a distance of less than ten feet from the work surface, must we still
extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?
Answer:
The work practices for exterior projects are based on a performance standard — the work area must be
contained so that dust or debris does not leave the work area while the renovation is being performed.
EPA recognizes that proper use of exterior vertical containment measures may be a more effective
method for containing the work area than use of the traditional ground containment alone, as outlined in
the regulations.
With proper techniques, a firm may meet the performance standard by using vertical containment in
conjunction with ground containment. Vertical containment means a vertical barrier consisting of plastic
sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of
containing the work area (40 CFR § 745.83). Properly constructed vertical containment, for example, might
consist of a rigid box-like framework wrapped in impermeable plastic sheeting and anchored to the
ground and home. When placed on top of ground containment, such containment should effectively limit
the travel of dust and debris to the interior of the enclosure. Whatever construction techniques are used,
the containment must completely isolate the work area and prevent any dust and debris from leaving the
work area to satisfy the performance standard.
If exterior vertical containment is erected at a distance of less than ten feet from the work surface, the
ground containment need not necessarily extend the full ten feet. Ground containment measures may
stop at the edge of the vertical barrier when using a vertical containment system.
59
Prohibited and Restricted Practices
Question (23002-17026)
How do RRP requirements apply to pressure washing? What containment and other preparation are
required?
Answer
Pressure washing is not a prohibited practice under the RRP Rule. Pressure washing is subject to the
same containment requirements as other permissible work practices. Before beginning the renovation,
the firm must isolate the work area so that no dust or debris (including in the waste water) leaves the work
area while the renovation is being performed. In addition, the firm must maintain the integrity of the
containment by ensuring that any plastic or other impermeable materials are not torn or displaced and
taking any other steps necessary to ensure that no dust or debris leaves the work area while the
renovation is being performed. The firm must also ensure that containment is installed in such a manner
that it does not interfere with occupant and worker egress in an emergency.
In addition, it is important to properly dispose of waste water used during pressure washing. Check with
your local water treatment authority for more information.
Question (23002-19748)
My firm drills a series of 1/2 inch diameter holes in sheet rock to dry it out where rooms have been
flooded. Is drilling these holes a prohibited practice?
Answer
No. The requirement for HEPA exhaust control does not apply to the use of all power tools. Specifically,
HEPA exhaust control is not required when using a power drill to drill holes in sheetrock. When using a
power drill with a drill bit to cut through sheetrock, the speed associated with the contact between the bit
and the paint is not of the same magnitude as the contact speed generated by the machines identified in
the regulation. The RRP Rule prohibits the use of machines designed to remove paint or other surface
coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive
blasting, or sandblasting, is prohibited on painted surfaces unless such machines have shrouds or
containment systems and are equipped with a HEPA vacuum attachment to collect dust and debris at the
point of generation. These machines must be operated so that no visible dust or release of air occurs
outside the shroud or containment system. .
Waste from Renovations
Question (23002-24833)
Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed of under
the RRP Rule?
Answer
The RRP Rule requires the renovation firm to use precautions to ensure that all personnel, tools, and
other items are free of dust and debris before leaving the work area. Workers with contaminated clothing
can take that contamination home to their own children, and taking contaminated equipment to another
jobsite could potentially create a lead hazard at a new site. There are several ways of ensuring that
gloves and other clothing are free of dust and debris before leaving the work area. For example, tacky
mats may be put down immediately adjacent to the plastic sheeting covering the work area floor to
remove dust and debris from the bottom of the workers’ shoes as they leave the work area. If workers
60
wear shoe covers, they may remove them as they leave the work area. Clothing and materials may be
wet-wiped and/or HEPA-vacuumed before they are removed from the work area. While the rule does not
specifically address gloves, if they are contaminated with lead dust or debris that cannot be removed,
EPA recommends that they not be removed from the work site during the job and that they be disposed of
as part of final cleanup.
Question (23002-20763)
Under the RRP Rule, what type of container is adequate for on-site storage of debris? Must the container
be covered and locked? Must it be placed behind a locked barrier?
Answer
At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected
from renovation activities must be stored under containment, in an enclosure, or behind a barrier that
prevents release of dust and debris out of the work area and prevents access to dust and debris. Using a
covered container is one way to prevent release of dust and debris. Locking the container and placing it
behind a locked barrier are good examples of ways to prevent access to the dust and debris.
Question (23002-14730)
Can non-certified workers transport debris off site under the RRP Rule if they have had documented onthe-
job training in this activity by the certified renovator?
Answer
Yes. The RRP Rule requires the certified renovator to regularly direct the work being performed by other
individuals to ensure that the work practices are being followed, including ensuring that dust or debris
does not spread beyond the work site. The certified renovator is responsible for providing training to noncertified
workers on the work practices they will be using in performing their assigned tasks, including
transporting waste off site.
Question (23002-17804)
How should I dispose of contaminated water used in two-bucket mopping?
Answer
EPA recommends contacting your local water treatment authority and asking about local requirements for
handling and disposing of waste water.
Cleaning the Work Area
Question (23002-20634)
The RRP rule requires HEPA vacuums to be used for cleaning up the dust created by renovations. What
should I look for when purchasing a HEPA vacuum?
Answer
According to the definition in 40 CFR 745.83:
HEPA vacuum means a vacuum cleaner which has been designed with a high-efficiency
particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of
capturing particulates of 0.3 microns with 99.97% efficiency. The vacuum cleaner must be
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designed so that all the air drawn into the machine is expelled through the HEPA filter with none
of the air leaking past it. HEPA vacuums must be operated and maintained in accordance with
the manufacturer’s instructions.
Therefore, renovation firms should look for a vacuum cleaner that was designed to be operated with a
HEPA filter, rather than a shop vacuum that can be fitted with a HEPA filter in place of the original basic
filter. A vacuum retrofitted with a HEPA filter is not necessarily properly sealed or designed so that all of
the intake air goes through the HEPA filter. EPA also recommends that renovation firms ask the
manufacturer or retailer whether the machine has been tested to ensure that it achieves the high
efficiency required of a HEPA filter (capturing 99.97% of 0.3 micron particles).
Question (23002-20761)
Under the RRP Rule, do paint chips and debris need to be removed from protective sheeting prior to
misting, removing, folding and sealing the sheeting even if such chips and debris can be effectively
contained by the sheeting or the sealed container the sheeting is contained in for disposal?
Answer
Yes. After the renovation has been completed, the firm must clean the work area until no dust, debris, or
residue remains. The first cleaning step required by the RRP rule is to collect all paint chips and debris
and, without dispersing any of it, seal this material in a heavy-duty bag. The purpose of this step is to
prevent accidental spreading of lead-contaminated paint chips and dust off of the protective sheeting.
Only when this step is completed may you remove the protective sheeting, following the directions
specified in the rule.
Question (23002-18385)
If a renovator uses the required practices to remove containment and clean a work area, then performs
successful cleaning verification, can the balance of the project then be done using uncertified workers
and without reference to the work practices required by the RRP Rule?
Answer
Yes, as long as the balance of the project can be completed without disturbing a painted surface.
Question (23002-23884)
When waste from renovations has been removed from the work area and placed in on-site storage, may
the waste be stored in a covered waste container or must it all be bagged for disposal?
Answer
Properly implemented, either option can meet the requirements of the RRP Rule. At the conclusion of
each work day and at the conclusion of the renovation, waste that has been collected from renovation
activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of
dust and debris out of the work area and prevents access to dust and debris. Storing the waste in a
covered waste container is one way to meet this requirement if the waste container prevents release of
dust and debris. Containing the waste in closed trash bags can also prevent release of dust and debris.
Locking the dumpster and placing it behind a locked barrier are good examples of ways to prevent access
to the dust and debris.
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Question (23002-13864)
Are components removed from the home to be cleaned up and reused subject to the waste handling
requirements in the rule?
Answer
While components to be reused rather that disposed of are not considered waste for the purposes of the
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 (23002-24718)
Who is responsible for controlling dust and debris from renovation waste once the waste container or
truck used to transport the waste leaves the renovation site?
Answer
When a renovation firm transports waste from renovation activities, the firm must contain the waste to
prevent release of dust and debris. The RRP Rule does not address the responsibilities of other entities.
EPA recommends consulting with state and local waste disposal authorities to learn about any additional
requirements.
Question (23002-15872)
For purposes of cleaning the work area following a renovation, is the interior floor of a garage considered
interior or exterior space?
Answer
In general, the interior floor of a garage is considered an interior space for purposes of post-renovation
cleanup. EPA recognizes the fact that it may occasionally be impossible for firms to meet all of the
cleaning and verification requirements under the Rule for garage floors such as those that are composed
of dirt or gravel. In such a case, EPA recommends that a firm document and keep records of the specific
circumstances surrounding the impossibility. A firm must also make their best effort to collect and remove
all paint chips, dust, debris and residue. Furthermore, a firm must still comply with all feasible work
practice standards and take precautions to ensure that the work area is properly contained.
Question (23002-31780)
My firm has signed a contract to replace the windows on a pre-1978 home. We have tested for the
presence of lead based paint and found the results to be positive. However, the homeowner has already
scraped and repainted their house but did not follow lead safe work practices. The result of their activity
is paint chips scattered throughout the landscaping. How best should I proceed?
Answer
A firm working on a property that is already contaminated with paint chips, dust, debris and residue must
proceed by containing the work area for the renovation, and complying with all cleaning requirements
under the Rule for that work area. Paint chips, dust, debris and residue that fall within the work area must
be eliminated. If paint chips, dust and debris exist beyond the work area, but were not a product of the
firm’s window replacement activities, EPA recommends that the firm document and keep record of the
conditions.
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Cleaning Verification
Question (23002-20755)
Typically, interior clearance is achieved by means of dust wipe sampling by a certified inspector or risk
assessor using single surface dust wipes. This is required on all HUD jobs. EPA rules at 40 CFR
745.227(e)(8)(ii) allow for composite sampling in clearance testing. Under the RRP Rule, is composite
sampling acceptable for clearance in lieu of cleaning verification?
Answer
Yes. Under the RRP Rule, cleaning verification need not be performed if the contract between the
renovation firm and the person contracting for the renovation or another Federal, State, Territorial, Tribal,
or local law or regulation requires:
 The renovation firm to perform dust clearance sampling at the conclusion of a renovation covered
by this subpart.
 The dust clearance samples are required to be collected by a certified inspector, risk assessor, or
dust sampling technician.
 The renovation firm is required to re-clean the work area until the dust clearance sample results
are below the clearance standards in 40 CFR 745.227(e)(8) or any applicable State, Territorial,
Tribal, or local standard.
Clearance must be performed following the procedures in 40 CFR 745.227(e)(8), which allow the use of
composite sampling. Not all laboratories will analyze composite samples, so check with your laboratory
before collecting them.
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Recordkeeping and Reporting Requirements
Question (23002-18219)
If a certified renovator is an employee of the certified firm, can the firm maintain all required records
(those required of the firm and of the certified renovator); understanding that the certified renovator must
also keep a copy of his certification as well as employee training records/documentation on the jobsite?
Answer
The renovation firm is the entity responsible for retaining and making available to EPA all records
necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of
the renovation. The certified renovator is responsible for preparing the records demonstrating that the
renovation was conducted in compliance with the work practice standards.
Certified renovators must have with them at the work site copies of their initial course completion
certificate and their most recent refresher course completion certificate. Certified renovators are also
responsible for providing training to non-certified workers on the work practices they will be using in
performing their assigned tasks. The renovation firm must keep records showing what training was
provided to workers, but these records need not be available at the work site.
Question (23002-32219)
What records must a subcontractor keep?
Answer
If the certified renovator assigned to the project is assigned by the subcontractor, the certified renovator is
responsible for preparing the records demonstrating that the renovation was conducted in compliance
with the work practice standards, including training provided to non-certified workers. All renovation firms
involved in a project are jointly responsible for retaining and making available to EPA all records
necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of
the renovation.
Question (23002-32220)
Can the required records and documentation be stored electronically rather than as paper copies?
Answer
Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary
to demonstrate compliance with the RRP Rule for a period of 3 years following completion of the
renovation. The RRP Rule does not specify the format in which records must be kept.
Question (23002-32221)
Can the certified renovator comply with the rules by keeping records regarding his certification and
employee training electronically, provided he can display them on a hand held device or laptop on the job
site?
Answer
Yes. The RRP Rule does not specify the format in which these documents must be kept, but they must
be available at the work site. Documents are not available if they cannot be viewed. Certified renovators
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must have with them at the work site copies of their initial course completion certificate and their most
recent refresher course completion certificate.
Certified renovators are also responsible for providing training to non-certified workers on the work
practices they will be using in performing their assigned tasks. The renovation firm must keep records
showing what training was provided to workers, but these records need not be available at the work site.
Question (23002-18103)
I hear new recordkeeping requirements will take effect soon. What are they and when must my firm
begin to comply with them?
Answer
Beginning July 6, 2010, when the final invoice for the renovation is delivered, or within 30 days of the
completion of the renovation, whichever is earlier, the renovation firm must provide information
demonstrating compliance with the training and work practice requirements of the RRP Rule to the owner
of the building being renovated and, if different, to the occupants of the renovated housing or the operator
of the child-occupied facility. For renovations in common areas of target housing, the renovation firm
must provide the occupants of the affected housing units with instructions on how to review or obtain this
information from the renovation firm at no charge to the occupant. These instructions must be included in
the pre-renovation education notice provided to each affected unit or on the signs posted in the common
areas. Similar requirements apply for renovations in child-occupied facilities. The renovation firm is
required to provide interested parents or guardians of children using the child-occupied facility instructions
on how to review or obtain a copy of these records at no cost to the parents or guardians. This could be
accomplished by mailing or hand delivering these instructions, or by including them on the signs posted
as part of pre-renovation education.
Question (23002-18287)
If a general contractor and one or more subcontractors are involved in a single renovation project, which
persons or entities are responsible for preparing, retaining and making available the necessary records?
Answer
The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for
preparing the records demonstrating that the renovation was conducted in compliance with the work
practice standards, including training provided to non-certified workers.
All renovation firms involved in a project must retain and, if requested, make available to EPA all records
necessary to demonstrate compliance with the RRP Rule for a period of 3 years following completion of
the renovation.
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Firm Certification
Question (23002-19747)
My firm acts as a general contractor – we subcontract the entire renovation job to other companies rather
than using our own employees. Does my firm need to be a certified firm under the RRP Rule?
Answer
Yes. Beginning April 22, 2010, no firm may perform, offer, or claim to perform renovations covered by the
RRP Rule without certification from EPA. A general contractor that subcontracts the entire renovation job
to other firms must be certified as a firm for two reasons. First, the contractual agreement between the
general contractor and the subcontractor is based on the general contractor’s offer to renovate the
property of a third party for compensation. The RRP Rule requires a contractor that makes such an offer
to be certified as a firm. Second, once the offer is accepted, the general contractor is obligated to
perform a renovation in accordance with the terms of the contract, whether written or oral. Even if the
general contractor chooses to fulfill its obligation to perform the renovation by hiring subcontractors, the
general contractor is performing a renovation for purposes of the RRP rule and must comply with all the
requirements of the rule that apply to firms performing renovations.
Question (23002-14295)
My firm acts as a general contractor – we subcontract the entire renovation job to other companies rather
than using our own employees. Does my firm need to have a certified renovator at the job site?
Answer
Not necessarily. All firms performing renovations, including general contractors, must ensure that all
individuals performing renovation activities on behalf of the firm are either certified renovators or have
been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement
by hiring another certified firm that also takes responsibility for ensuring that all individuals performing the
renovation activities are either certified renovators or have been trained by a certified renovator. With
respect to assigning a certified renovator who is responsible for any OJT and regularly directing other
workers, a firm acting as a general contractor my satisfy this requirement by hiring another certified firm
that in turn assigns a certified renovator to the job. However, this does not discharge the general
contractor’s liability to ensure compliance with the RRP Rule.
Question (23002-18512)
If I rent out apartments built before 1978, do I need to get firm and renovator certification if I do my own
work on it? What if I hire a renovation firm to do the work?
Answer
With respect to landlords, EPA believes that there are two circumstances where work being done in pre-
1978 apartment is for compensation such that the landlord must be a certified firm and use (or be) a
certified renovator. First, if the landlord does the renovation him or herself, then the landlord must have
firm and renovator certification. Second if an employee of the landlord does the renovation work, then the
landlord must have firm certification and the employee must be a certified renovator. However, if the
landlord hires a renovation firm to perform the renovation, the landlord does not need firm or renovator
certification, but the firm hired by the landlord must be certified and must perform the renovation using a
certified renovator that directs and provides on-the-job training to any workers that are not certified
renovators.
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Question (23002-13650)
A property management company performs most of the clerical functions of the business, and hires
plumbers, electricians, carpenters, etc., for its renovation needs. Does the property management
company need firm certification?
Answer
A property management company acts as an agent for the landlord and has the same responsibilities as
the landlord under the RRP Rule. Therefore, if the property management company uses its own
employees to do the work, the property management company must be a certified firm and one of the
employees must be a certified renovator. If the property management company hires a renovation firm to
perform the renovation, the property management company does not need firm or renovator certification,
but the firm the property management company hires must be certified and must perform the renovation
using a certified renovator that directs and provides on-the-job training to any workers that are not
certified renovators.
Question (23002-17957)
How will the RRP Rule affect the work of non-profit or not-for-profit groups? Will the rule apply, for
example, to church groups who, as part of their missionary work, are making improvements for lowincome
residents?
Answer
The RRP Rule applies to renovations performed for compensation. Compensation includes pay for work
performed, such as that paid to contractors and subcontractors; wages, such as those paid to employees
of contractors, building owners, property management companies, child-occupied facility operators, State
and local government agencies, and non-profits; and rent for target housing or public or commercial
building space. Donations, including donations of materials or of the time of volunteers, are not
compensation. If the organization is compensating anyone for the work (for example, a paid supervisor),
then the renovation is covered by the RRP Rule. This is the case even though the organization has nonprofit
or not-for-profit status.
The organization may also need to become certified as a firm. Beginning April 22, 2010, an organization
that performs, offers, or claims to perform renovations covered by the RRP Rule must be certified by
EPA. A non-profit organization that offers to renovate the property of a third party for compensation, or
that performs the renovation, must be certified as a firm. The organization must comply with all the
requirements of the rule that apply to firms performing renovations. This includes having a certified
renovator direct the work and provide on-the-job training to all uncertified workers, including volunteers.
Question (23002-15340)
DOE provides weatherization grants to states, which in turn provide grants to non-profit sub-grantees.
These sub-grantees fall into one of three categories:
1. The sub-grantee uses its own employees to perform all the weatherization services in the home,
2. The sub-grantee uses a combination of its own employees and contractors to perform
weatherization services, or
3. The sub-grantee has no employees that perform weatherization services; instead, every service
is performed by a hired contractor.
Must these sub-grantees be RRP-certified firms?
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Answer
Beginning April 22, 2010, no firm may perform, offer, or claim to perform renovations covered by the RRP
Rule without certification from EPA. Sub-grantees that use their own employees to perform any or all of
the weatherization services in the home, such as the sub-grantees in the first two categories, must be
RRP certified firms.
As to the sub-grantee in the third category, the need for certification depends on whether the sub-grantee
offers, through the grant proposal, to renovate the property of a specific homeowner or other third-party.
In this case, the sub-grantee is an offeror and grant money is “compensation” for RRP purposes. Once
the offer is accepted (i.e., the grant is issued) a contract is formed under which the sub-grantee is
obligated to perform the renovation. Even if the sub-grantee chooses to fulfill its obligation to perform the
renovation by contracting out the work, the sub-grantee is “offering to perform a renovation” for purposes
of the RRP rule. Accordingly, the sub-grantee must be a certified firm and comply with all other
applicable RRP requirements.
Conversely, if the sub-grantee does not “perform, offer, or claim to perform” a renovation – through a grant
proposal or otherwise – the sub-grantee need not be certified. For example, a grant proposal would not
constitute an “offer” if the issuance of the grant would not obligate the sub-grantee to renovate the
property of a specific third-party. If the grant proposal is not a legally binding offer, the sub-grantee
becomes a mere purchaser of renovation services when it uses the grant money to hire a renovation firm.
In such a case, only the renovation firm – the offeror – must be certified
Question (23002-21691)
What do you need to do to become a certified firm?
Answer
Firm certification is easy and straightforward – you need only submit a short application, and submit it with
fee to EPA. The form, and associated material, is available on EPA’s website at
http://epa.gov/lead/pubs/toolkits.htm#renovator. You should complete and submit this form without delay.
Certified firms will be able to advertise that they are certified by EPA under the RRP program, and will
also be given rights to use EPA’s new “Lead-Safe Certified Firm” logo.
Remember, to fully comply with this regulation, certain of your key employees may need to obtain
individual certification (by taking a one-day certification course) in addition to your firm certification. Visit
http://www.epa.gov/lead/pubs/renovation.htm#contractors to learn how to become a certified renovator.
Question (23002-18528)
If my firm already has abatement certification, is separate RRP certification necessary?
Answer
RRP firm certification is not required to perform lead abatements. However, if your firm performs, offers,
or claims to perform renovations as well as abatements, after April 22, 2010 it must be a certified
renovation firm.
Question (23002-18123)
I own a sole proprietorship, and I plan to get trained and certified as a certified renovator. Will that be
sufficient since I have no employees?
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Answer
No. Beginning April 22, 2010, all firms performing renovations covered by the RRP rule must be certified.
“Firm” means a company, partnership, corporation, sole proprietorship or individual doing business,
association, or other business entity; a Federal, State, Tribal or local government agency; or a nonprofit
organization.
Question (23002-20758)
Can a certified renovator supervise workers of a different company, or must each firm involved in a
project furnish a certified renovator?
Answer
All firms performing renovations must ensure that all individuals performing renovation activities on behalf
of the firm are either certified renovators or have been trained by a certified renovator. The RRP Rule
does not prohibit firms from reaching agreement on which will supply the certified renovator who is
responsible for ensuring compliance with the RRP Rule and who directs and trains non-certified workers.
All firms remain liable for ensuring compliance with the RRP Rule.
Question (23002-14050)
Are state and local government employees who often do renovation work required to be certified?
Answer
If the state or local government uses its own employees to do the work, the state or local government
must be a certified firm and at least one of the employees assigned to each job must be a certified
renovator. If the state or local government hires a renovation firm to perform the renovation, the state or
local government does not need firm or renovator certification, but the firm the state or local government
hires must be certified and must perform the renovation using a certified renovator that directs and
provides on-the-job training to any workers that are not certified renovators.
Question (23002-18288)
If a general contractor hires a subcontractor to work at a renovation site, does the subcontractor need to
be a certified firm if the subcontractor does not disturb any paint?
Answer
Firms performing tasks that disturb no painted surfaces whatsoever do not need to be certified. However,
since conditions at the job site may be difficult to predict, EPA strongly recommends that all firms involved
in the renovation be certified and use properly trained and certified personnel. For example, a firm hired
to install an HVAC system after demolition of painted surfaces has taken place may find that to complete
the job painted surfaces need to be disturbed. The HVAC firm may not engage in activities that disturb
painted surfaces if it is not certified.
As every renovation job is different, it is up to the firm acting as the general contractor to determine what
activities are within the scope of the renovation and to ensure that other firms are properly trained and
certified for the tasks they will be performing. All firms, including the firm acting as the general contractor,
are responsible for making sure the renovation is performed in accordance with the work practice
standards, including keeping containment intact and making sure lead dust and debris do not leave the
worksite. General contractors should keep in mind that if a firm hires a subcontractor that fails to follow
the work practice standards or otherwise violates the RRP rule, the firm that hired the subcontractor is
also responsible for the violation.
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Question (23002-21581)
What changes in a renovation firm’s status require an amendment of certification and how much will it
cost?
Answer
In accordance with § 745.89(c), any change to the information reported to EPA in a firm’s most recent
certification application must be reported in an amended certification application. There is no fee
associated with the submission of an amended certification.
Question (23002-18350)
If a property owner and a property management company have entered in to a consent agreement
related to Section 1018 (lead hazard disclosure) that does not admit an actual violation, is the property
management company required to acknowledge a lead-based paint violation when completing the
application for firm certification?
Answer
No.
Question (23002-18573)
If the demolition, cleanup, and cleaning verification portion of a renovation project is performed under the
direction of a certified renovator using trained workers, can uncertified workers complete the job if further
disturbances of painted surfaces will not occur? For example, a certified firm establishes containment
and removes wall and ceiling board to the rough framing members. Cleaning and verification take place
and containment is removed and properly disposed of. At that point, can non-certified firms perform
electrical, plumbing, HVAC, or drywall work?
Answer
Yes. Activities that do not disturb paint, such as applying paint to walls that have already been prepared,
are not regulated by the RRP Rule if they are conducted after post-renovation cleaning verification has
been performed.
Question (23002-15697)
Does the RRP Rule require a certified state lead inspector or risk assessor, who does not do renovation
work, to become a certified renovation firm in order to take dust wipe samples?
Answer
No. A certified inspector or risk assessor may make determinations regarding the presence of leadbased
paint at a renovation site without becoming certified as a renovation firm.
Question (23002-19197)
Is the fee for firm certification waived for self- employed individuals or landlords?
Answer
No. Congress requires EPA to impose a fee on certified contractors that is sufficient to recover the costs
of administering and enforcing the RRP Rule. All applicants for firm certification must submit the $300 fee
as part of their application. A firm’s certification is effective for 5 years.
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Question (23002-14558)
Can contractors submit their application to EPA before they complete the required training, or must the
application be submitted after the training is complete? Is there a proof of training required by the EPA in
order for the contractor’s application to be approved?
Answer
To become a certified renovator, you must successfully complete a renovation training course taught by
an accredited training provider. The course completion certificate serves as your proof of certification –
no application to EPA is necessary. If you are a sole proprietorship or individual doing business as a
renovation firm, you must also become a certified firm by submitted a completed “Application for Firms”
with the correct amount of fees. As part of your application, you will be required to certify that your firm
will comply with the requirements of the RRP Rule, including ensuring that all individuals performing
renovations activities on behalf of the firm are either certified renovators or have been trained by a
certified renovator.
No proof of training is required at the time you submit your application.
Question (23002-19659)
Must maintenance workers at kindergartens and elementary schools become certified renovators if they
perform renovations covered by the RRP Rule in the portions of the school that are child-occupied
facilities? Are the schools or school systems then required to become certified renovation firms?
Answer
On or after April 22, 2010, all renovations covered by the RRP Rule must be directed by certified
renovators and must be performed by certified renovators or individuals trained by a certified renovator.
The RRP rule requires any firm, including a local government agency, that performs, offers, or claims to
perform renovations to be certified by EPA.
Question (23002-18285)
If a firm does business in several states, must they become certified in all states in which they manage a
target property or is this requirement satisfied by certifying the firm in the state in which they are
headquartered?
Answer
The RRP Rule applies in states and tribal areas that are not operating EPA-authorized programs. A firm
with Federal certification under the RRP Rule may perform, offer, or claim to perform renovations in any
of these states. In states and tribal areas with EPA-authorized programs, check with the state or tribal
agency administering the program to learn about the certification requirements in that state or tribal area.
EPA encourages authorized state and tribal programs to accept certifications issued under the Federal
program and under other state and tribal programs, but this is not required.
Question (23002-19776)
My non-profit organization receives grants to arrange for renovations in older housing, such as
weatherization projects or general modernization. Typically, these grants come with eligibility conditions
for properties and/or property owners and tenants, but specific properties or projects are not identified.
My organization is responsible for locating eligible properties and recipients and hiring firms to perform
the eligible renovations. Must my non-profit organization become an RRP-certified firm?
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Answer
No, as long as your organization does not perform covered renovations using its own employees or offers
to renovate the properties of specifically-identified third parties in exchange for a grant, your organization
does not need to become an RRP-certified firm. You should make sure that any firms you hire are
certified renovation firms.
Question (23002-19775)
My non-profit organization applies for and receives grants to renovate older homes. We do not perform
the renovations ourselves, we hire renovation contractors to perform them on our behalf. We identify the
properties to be renovated and the specific projects in the grant application. If we are successful in
obtaining the grant, the funding would obligate us to arrange for the renovation of the specific properties
named in the grant application. Must my non-profit organization become an RRP-certified firm?
Answer
Yes, even though your organization’s employees do not actually perform the renovation activities, your
organization must be an RRP-certified renovation firm because your organization, through the grant
process, is offering to perform renovations for compensation, i.e., the grant.
Question (23002-17979)
I am a facilities manager for a church with daycare and preschool programs. I recently became a certified
renovator. If my staff and I do our own painting and remodeling work, do we need to be a certified firm?
Answer
Yes, if you perform, offer, or claim to perform renovations in a portion of the building that is a childoccupied
facility. The RRP Rule defines a child-occupied facility as a building, or portion of a building,
constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two
different days within any week (Sunday through Saturday period), provided that each day’s visit lasts at
least three hours and the combined weekly visits last at least six hours, and the combined annual visits
last at least 60 hours.
With respect to common areas in public or commercial buildings that contain child-occupied facilities, the
child-occupied facility encompasses only those common areas that are routinely used by children under
age 6, such as restrooms and cafeterias. Common areas that children under age 6 only pass through,
such as hallways, stairways, and garages are not included. In addition, with respect to exteriors of public
or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only
the exterior sides of the building that are immediately adjacent to the child-occupied facility or the
common areas routinely used by children under age 6.
Areas of a building that fall outside this definition are not “child-occupied facilities” for purposes of the
RRP rule.
Question (23002-18001)
I am a renovator and I want to comply with EPA’s Lead Renovation, Repair and Painting Rule. What do I
need to do?
Answer
EPA’s Lead Renovation, Repair and Painting (RRP) rule sets up new requirements for firms and
individuals performing renovations in pre-1978 housing and child-occupied facilities, such as schools
and daycares.
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• Firms must be EPA certified. To become EPA certified, renovation contractors must submit an
application and fee payment to EPA (www.epa.gov/getleadsafe). Once certified, the firm will be able to
advertise that they are certified by EPA under the RRP program, and will also be given rights to use
EPA’s “Lead-Safe Certified Firm” logo.
• Renovations covered by the rule must be performed or directed by a Certified Renovator.
Individuals can become a lead-safe certified renovator quite easily. It requires successful completion of
a one-day training course in lead-safe work practices. The training courses are offered by EPA-approved
private training providers; there is no additional fee to EPA. You can find a training provider in your area
by using EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm.
Over 500 training firms have been accredited to provide the specialized, one-day lead-safe work practices
training. Many offer trainings in multiple states. Classes teach the specific work practices that contractors
need to protect themselves and their clients from lead contamination, and to allow them and their firm to
work legally. Certification is immediate upon successful completion of the training class.
Question (23002-18140)
I took a class to be a Certified Renovator and my firm applied for firm certification before April 22, 2010,
but my firm does not have its certificate yet. What do we do?
Answer
In these circumstances, EPA does not intend to take enforcement actions against firms who applied for
firm certification before April 22 and have not received their certification. The certification requirement is
important to making sure that firms are protecting children and other residents while renovations are
ongoing, but EPA does not wish to disrupt ongoing renovations for those firms that submitted applications
on time. We expect that all of the applications filed before April 22 will be reviewed by June, and that the
applications submitted for the first 60 days after April 22 will be reviewed soon thereafter. Thus, it will only
be a short window of time when firms that applied are waiting to hear back from EPA.
Question (23002-17543)
How long will it take EPA to process my application to be a lead-safe certified firm?
Answer
EPA is required to process your application within 90 days of receipt. In most instances, properlycompleted
firm applications are processed in about one month.
Question (23002-21890)
What happens if my firm is in the middle of a renovation job on April 22, 2010? My firm is not certified
and none of my employees have taken the lead-safe certified renovator training. What should I do?
Answer
You should submit your application for renovation firm certification immediately. You should also arrange
for lead-safe certified renovator training for at least one of your employees as soon as possible, and you
should require at least one of your employees to review EPA’s online training materials at
http://www.epa.gov/lead/pubs/training.htm. In addition, you must follow the lead-safe work practices
required by the rule. Information on these work practices can be found at www.epa.gov/lead or obtained
from the National Lead Information Center at 1-800-424-LEAD (5323). For the first 60 days after April 22,
2010, EPA’s general approach for work initiated before that date will be, upon learning that a firm or
74
individual conducting a renovation is not certified or trained, to issue a notice without monetary penalties
to that firm or individual. This notice will state that the firm or individual needs to come into compliance as
quickly as possible. To correct the noncompliance, the individual or firm will need to provide a copy of an
accredited course completion certificate or firm certification to EPA within a reasonable time.
Question (23002-18000)
I am a renovation firm and I have contracted for a renovation in a pre-1978 home to begin on or after April
22, 2010. None of my people have taken the lead-safe certified renovator training yet. I found out the
Certified Renovator classes near me are all full until after April 22, 2010. What should I do?
Answer
You should hold off on starting work in any pre-1978 home or child-occupied facility until you have taken
the certified renovator training course from an EPA-accredited training provider. In addition, you should
make sure that your firm is EPA certified. You can find out more information at
www.epa.gov/getleadsafe. You can find an accredited training provider who is based near you by using
EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm. More than 340 EPA-accredited
training providers have indicated to EPA that they are willing to travel to offer training classes. You can
find a list of training providers, including those who are willing to travel, by using the same search tool.
Question (23002-18225)
If a company has several legal entities, does each entity have to become a certified firm?
Answer
Yes, if the corporate structure is such that the parent company is not liable for actions of the separate
legal entities.
Question (23002-19722)
My company has two stores in different states. Must each store be a separate certified firm?
Answer
It depends on the company’s structure. If each store is a separate legal entity, then each store must be a
certified firm. If the parent company retains liability for the actions of each store, the parent company’s
firm certification covers both stores.
Question (23002-18047)
I am the owner of my renovation firm, but I am not a certified renovator. May I be the “attesting individual”
named on the RRP firm certification application?
Answer
Yes. The attesting individual need not be a certified renovator.
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Question (23002-31784)
My firm performs renovations covered by the RRP rule, but solely in the capacity of a subcontractor. If
the general contractor is a certified firm, does my firm also have to be certified, or can we just provide the
certified renovator?
Answer
All firms performing, offering, or claiming to perform renovations covered by the RRP rule must be
certified. In this case, both the general contractor and subcontractor must become certified firms.
Question (23002-33318)
What is the difference between Abatement (LBP) Certification and Renovation (RRP) Certification?
Answer
LBP activity (or abatement) certification is a specialized type of certification for firms who specifically want
to work with lead-based paint. This includes abatement firms as well as risk assessment and inspection
firms. Abatement is the intentional and permanent elimination of lead-based paint and lead-based paint
hazards. Those who remove lead-based paint simply as a consequence of doing other work do not need
LBP/Abatement certification.
RRP (or renovation, repair, and painting) certification is for all firms who may disturb paint in pre-1978
residences and child-occupied facilities. It covers a broad range of firms including renovators, carpenters,
painters, electricians, plumbers, handymen, and more.
76
Lead-Safe Certified Firm Logo
Question (23002-16813)
How do I get my Lead-Safe Certified Firm Logo?
Answer
EPA will send instructions for downloading your Logo to the e-mail address you list on your firm
certification application. The instructions will include a password. To download your Logo, visit
www.RRPFirmlogos.org. Enter your User ID, which is your application ID number found on your
certification letter. Enter the password included in the instructions. You will then find a download button
and instructions on how to save your file.
Question (23002-18061)
I don’t have an e-mail account. Can I have a CD mailed to me?
Answer
No. If you don’t have an e-mail account, please call 1-800-424-LEAD with your firm certification number
and they will assist you with obtaining your password. You can use your password, with the application
ID number found on your firm certification letter, to download your Logo from www.RRPFirmlogos.org.
Question (23002-16027)
How and where can I use the Lead-Safe Certified Firm Logo?
Answer
The Lead-Safe Certified Firm Logo must be reproduced so that all of its components are legible, including
your firm’s certification number. The Logo must not be altered or distorted in any way.
You MAY –
 Use the Logo to identify your firm as an RRP-certified firm. Firms that are not RRP-certified may
not use the Logo.
 Use the Logo in brochures, advertisements, Web sites, proposals, bills, signs, uniforms, vehicles
and other materials promoting or identifying your firm.
 Use the Logo on documents or other materials in black and white or color (2-color or 4-color
versions are available).
You MAY NOT –
 Use the Logo in any manner that would imply EPA endorsement of a company, its products or
services.
 Reduce the Logo to a size smaller than one inch wide by 0.687 inches in height.
 Allow a firm that is not RRP-certified (including your subcontractors) to use the Logo.
EPA will monitor the use of all Logos. If necessary, EPA will address failure to comply with these Logo
Guidelines. To report a non-compliant use of the Logo, please contact EPA at 1-800-424-LEAD.
Question (23002-14639)
Can I get the Lead-Safe Certified Firm Logo file in different resolution or in black and white?
77
Answer
Yes, please e-mail EPARRPFirmLogo@battelle.org for the file. If you don’t have an e-mail account,
please call 1-800-424-LEAD.
Question (23002-18056)
I can’t open the Lead-Safe Certified Firm Logo file I have been sent. What format is it in?
Answer
The Logo is in a standard .jpg file. It is approximately 900KB to ensure clarity. If this size is too large, or
a different format is needed, please call National Lead Information Center and provide your firm
certification number and e-mail address. They will submit the request to EPA for you.
Question (23002-14652)
Can I receive an .eps, .ai, .ait or modifiable format of the Lead-Safe Certified Firm Logo?
Answer
No, EPA will only send formats that cannot be manipulated (i. e. .bmp, .pdf, .tif etc.)
Question (23002-14618)
Can I change the colors of the Lead-Safe Certified Firm Logo to match my company’s current materials?
Answer
No, the Lead-Safe Certified Firm Logo may only be presented in Pantone 362C (green) and Pantone
660C (blue), or in black and white.
Question (23002-18113)
I need my password, or am having technical issues with the site to download the Lead-Safe Certified Firm
Logo.
Answer
Please e-mail EPARRPFirmLogo@battelle.org. If you don’t have an e-mail account, please call 1-800-242-LEAD.
78
Renovator Certification and Training
Question (23002-14050)
Are state and local government employees who often do renovation work required to be certified?
Answer
If the state or local government uses its own employees to do the work, the state or local government
must be a certified firm and at least one of the employees assigned to each job must be a certified
renovator. If the state or local government hires a renovation firm to perform the renovation, the state or
local government does not need firm or renovator certification, but the firm the state or local government
hires must be certified and must perform the renovation using a certified renovator that directs and
provides on-the-job training to any workers that are not certified renovators.
Question (23002-23546)
What training requirements apply to non-certified workers who have previous EPA/HUD lead-safe work
practices training or accredited abatement supervisor or worker training?
Answer
The RRP Rule requires certified renovators to provide on-the-job training (OJT) to non-certified workers
on the work practices they will be using in performing their assigned tasks. The amount of OJT needed
and the topics that need to be covered depend on the knowledge and experience of each worker. OJT
for a worker who has successfully completed prior EPA/HUD lead-safe work practices training, accredited
abatement supervisor or worker training, or HUD’s Lead Maintenance course training, might not have to
cover basic lead-safe work practices information. It likely would need to address project-specific
information (such as the worker’s tasks on the job, the operation of new equipment the worker is to use,
work area exit locations, and waste disposal locations), as well as any new lead-safe work practices
information that was not covered in the worker’s course training and that is pertinent to the worker’s tasks.
The certified renovator is responsible for ensuring compliance with the work practice standards at all
renovations to which he or she is assigned. The certified renovator is also responsible for preparing the
records demonstrating that the renovation was conducted in compliance with the work practice standards,
including the requirement to provide OJT to non-certified workers. The renovation firm must keep records
showing what training was provided to workers. It would be advisable for the records to reflect any prior
training non-certified workers had taken.
Question (23002-18088)
I have completed an 8-hour lead safe work practices training course, but my certificate has expired. What
training do I need to take to become a certified renovator?
Answer
If you have taken one of certain EPA/HUD lead-safe work practices training courses, or accredited
abatement supervisor or worker training, before October 4, 2011, regardless of whether this training has
expired you may become a certified renovator by taking a 4-hour renovator refresher course in lieu of the
8-hour initial renovator course. EPA is requiring that you complete at least the 4-hour refresher course in
order to ensure that you are acquainted with how to use test kits to determine whether lead-based paint is
present on a component and how to perform cleaning verification. For a list of the eligible EPA/HUD
courses, go to http://www.epa.gov/lead/pubs/trainerinstructions.htm#refresher or call 1-800-424-LEAD.
79
Question (23002-19615)
Must a certified lead abatement professional also become trained and certified to do renovation or repair
work?
Answer
Yes. Because some skills are different (such as cleaning verification), RRP training and certification is
required even if someone already has abatement certification. Please note that if you previously
completed an eligible renovation training course before October 4, 2011, you may take the 4-hour
refresher course instead of the 8-hour initial course from an accredited training provider to become a
certified renovator. For a list of eligible courses, visit

http://www.epa.gov/opptintr/lead/pubs/trainerinstructions.htm#refresher.

Question (23002-16220)
How can I find an accredited renovation trainer?
Answer
The list of accredited training providers is available on EPA’s RRP Web site at
http://cfpub.epa.gov/flpp/searchrrp_training.htm, or from the National Lead Information Center, 1-800-
424-LEAD. New training providers are being accredited weekly.
Question (23002-20530)
The certified renovator is required to have proof of their certification at the work site. If the certified
renovator provides on-the-job training to workers, does there need to be documentation of that training at
the work site too?
Answer
No. Certified renovators must have with them at the work site copies of their initial course completion
certificate and their most recent refresher course completion certificate. Certified renovators are also
responsible for providing training to non-certified workers on the work practices they will be using in
performing their assigned tasks. The renovation firm must keep records showing what training was
provided to workers, but these records need not be available at the work site.
Question (23002-19182)
Is the certified renovator assigned to a specific project responsible for the work practices of other
contractors on the project if the certified renovator is an employee of the general contractor of the project?
Answer
All firms performing renovations must ensure that all individuals performing renovation activities on behalf
of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a
general contractor may satisfy this requirement by hiring another certified firm that takes responsibility for
ensuring that all individuals performing the renovation activities are either certified renovators or have
been trained by a certified renovator. With respect to assigning a certified renovator who is responsible
for any OJT and regularly directing workers who are not certified renovators, a firm acting as a general
contractor my satisfy this requirement by hiring another certified firm that in turn assigns a certified
renovator to the job. However, this does not discharge the general contractor’s liability to ensure
compliance with the RRP Rule.
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Question (23002-20939)
What about a situation where the home owner is acting as their own general contractor and hires multiple
companies to do different portions of the work? In this situation, would each business participating be
required to follow the rules and assign a separate certified renovator to supervise their portion of the work
including separate containment?
Answer
While the homeowner may be performing the role of general contractor by hiring firms and organizing
their work, the homeowner is not performing, offering, or claiming to perform a renovation and therefore
does not need to be a certified firm. The firms hired by the homeowner to perform renovation tasks are
responsible for complying with all aspects of the RRP Rule that are applicable to their work, including firm
certification. The RRP Rule does not prohibit firms from reaching agreement on which will supply the
certified renovator who is responsible for ensuring compliance with the RRP Rule and who directs and
trains non-certified workers. However, all firms share liability for ensuring compliance with the RRP Rule.
Question (23002-14757)
Can renovator training courses, both initial and refresher courses, be taught online or via distance
learning?
Answer
The final Renovation, Repair and Painting regulation, like the abatement program, permits the use of
alternative training techniques (e.g., video training, computer-based training) as a supplement to the
hands-on skills assessment, or as a substitute for the lecture portion of the training course requirements
outlined in § 745.225.
In addition, § 745.225 of the final rule requires all training programs, including those using alternative
training methods, to meet the minimum hourly requirements for hands-on activities in their training
courses. Under § 745.225, all training programs are also required to administer a course test and conduct
a hands-on skills assessment.
To ensure the quality of such alternative programs, the final rule requires training providers who opt to
use alternative techniques to submit all materials as specified in § 745.225 as a part of their application
for accreditation. These materials include copies of the course agenda, and student and instructor
manuals.
The accreditation of alternative training programs will be based on EPA’s review of the training materials
submitted under § 745.225, including the course agenda and manuals. In its review, the Agency will
consider on a case-by-case basis the provisions made by a training program to ensure the quality of its
course materials. Based on that review, the Agency may accredit programs offering alternative training
and instructional methods.
Question (23002-19659)
Must maintenance workers at kindergartens and elementary schools become certified renovators if they
perform renovations covered by the RRP Rule in the portions of the school that are child-occupied
facilities? Are the schools or school systems then required to become certified renovation firms?
Answer
On or after April 22, 2010, all renovations covered by the RRP Rule must be directed by certified
renovators and must be performed by certified renovators or individuals trained by a certified renovator.
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The RRP rule requires any firm, including a local government agency, that performs, offers, or claims to
perform renovations to be certified by EPA.
Question (23002-18377)
If a remodeling company that is a certified firm uses all contractual workers rather than employees, must
each contractual worker be a certified renovator, or can the workers be trained on the job by a certified
renovator employed by the firm?
Answer
Firms hiring contractual workers may provide the certified renovator that oversees the renovation project
and provides on-the-job training to contractual workers and other non-certified workers.
Question (23002-18001)
I am a renovator and I want to comply with EPA’s Lead Renovation, Repair and Painting Rule. What do I
need to do?
Answer
EPA’s Lead Renovation, Repair and Painting (RRP) rule sets up new requirements for firms and
individuals performing renovations in pre-1978 housing and child-occupied facilities, such as schools
and daycares.
• Firms must be EPA certified. To become EPA certified, renovation contractors must submit an
application and fee payment to EPA (www.epa.gov/getleadsafe). Once certified, the firm will be able to
advertise that they are certified by EPA under the RRP program, and will also be given rights to use
EPA’s “Lead-Safe Certified Firm” logo.
• Renovations covered by the rule must be performed or directed by a Certified Renovator.
Individuals can become a lead-safe certified renovator quite easily. It requires successful completion of
a one-day training course in lead-safe work practices. The training courses are offered by EPA-approved
private training providers; there is no additional fee to EPA. You can find a training provider in your area
by using EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm.
Over 194 training firms have been accredited to provide the specialized, one-day lead-safe work practices
training. Classes teach the specific work practices that contractors need to protect themselves and their
clients from lead contamination, and to allow them and their firm to work legally. Certification is
immediate upon successful completion of the training class.
Question (23002-17981)
I am a firm and there are no training providers offering classes near me. What do I do?
Answer
More than 340 EPA-accredited training providers have indicated to EPA that they are willing to travel to
offer training classes. You can find a list of training providers, including those who are willing to travel, by
using EPA’s search tool at http://cfpub.epa.gov/flpp/searchrrp_training.htm.
82
Question (23002-32128)
May I as a training provider issue a certificate without a picture to a trainee who has successfully
completed the course but objects to having his or her picture taken (or objects to possessing a
photograph of him/herself) on religious grounds?
Answer
Yes. Training providers may provide a person who objects to having his or her picture taken because of
sincerely held religious beliefs with the equivalent of a certificate without a picture. Specifically, the
training provider may provide an “Acknowledgement of Completion” that the person has successfully
completed the training (containing all the information that a certificate would except for a picture). EPA
recommends that training providers include the phrase “photo exception” in the normal place for a picture.
Further, training providers should use special coding when assigning Part 5 of the unique certificate
number. See for example, R-I-56789-10-E0025. Part 5 (“E0025” in the example) represents the unique
number assigned by the trainer. The number is sequential and will always begin with the letter E. The
first number E0001 should be assigned to the first “photo exception” student completing training in a
given calendar year. More general information about creating the unique identification number is
available at: http://epa.gov/lead/pubs/trainerinstructions.htm#certificate.
EPA further recommends that training providers document the trainee’s objection by having the trainee
sign a statement containing the following: “My refusal to be photographed is grounded upon a sincerely
held religious belief. I understand that if challenged, I may be found in noncompliance unless I can
demonstrate the sincerity of my religious beliefs.” Training providers should submit a copy of this
statement to EPA in lieu of a photograph. For anyone who can demonstrate that his or her refusal to be
photographed is grounded upon a sincerely held religious belief this acknowledgement will be treated as
the equivalent of a certificate.
NOTE: Training providers may now use CDX to submit post-training notifications to EPA that contain the
above-described numbering protocol.
83
Authorized State and Tribal Programs
Question (23002-18511)
If I received renovator certification in an authorized state, what do I need to do to work in EPAadministered
jurisdictions?
Answer
There are no additional requirements. To become a certified renovator or certified dust sampling
technician, an individual must successfully complete the appropriate course accredited by EPA or by an
EPA-authorized State or Tribal program. The course completion certificate serves as proof of
certification.
EPA renovator certification allows the certified individual to perform renovations covered by this section in
any State or Indian Tribal area that does not have a renovation program that is authorized under subpart
Q of this part.
Question (23002-19752)
My firm is certified by an authorized state. Does this certification allow my firm to work in EPAadministered
jurisdictions?
Answer
No. You must apply for and receive EPA certification before offering, performing, or claiming to perform
renovations covered by the RRP Rule in EPA-administered jurisdictions.
Question (23002-19132)
Is my EPA renovator certification accepted in all states and tribal areas?
Answer
Not necessarily. Whether to accept certification from another jurisdiction is up to the individual state or
tribal area. EPA cannot compel states or tribes to adopt programs identical to the Federal program or to
establish reciprocity provisions. However, EPA continues to encourage states and tribes that may be
considering establishing their own renovation programs to keep reciprocity in mind as they move forward.
Question (23002-18120)
I operate a renovation firm and I have heard that my state will adopt its own lead Renovation, Repair and
Painting program. Do I have to also be certified by EPA?
Answer
As of July, 2011, twelve states have their own RRP programs (Alabama, Georgia, Iowa, Kansas,
Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin) .
If your firm is located in one of these states, you should contact them for information on their certification
requirements. If you work outside of one of those states, your firm needs to be certified by EPA.
84
Training Provider Accreditation
Question (23002-15092)
Do all renovation course instructors need to be approved as principal instructors? For example, to reach
a 6:1 student-to-instructor ratio with 18 people in the class, may we have one principal instructor who
teaches the entire lecture and is assisted by two additional hands-on instructors (who are not approved
as principal instructors)?
Answer
Every accredited training program must employ a qualified training manager, and it is the job of the
training manager to designate a qualified principal instructor for each course. The principal instructor is
responsible for the organization of the course and oversees the teaching of all course material. The
training manager may designate expert guest instructors as needed to provide instruction specific to the
lecture, hands-on activities, or work practice components of a course. In this case, where the principal
instructor will teach the entire course, qualified guest instructors may assist with the hands-on aspects of
the course material.
Question (23002-18403)
If a student in a renovator training course is unable to read and understand English, may the exam be
read to them in their native language?
Answer
No. Separate course accreditations are required for each renovation course a training provider offers that
is in a language other than English. Courses presented in a language other than English must use
instructor manuals, exams, and other course materials in that language that have been reviewed by EPA
as part of the accreditation process for the course.
Question (23002-19568)
May renovator training providers provide reasonable accommodations to people with disabilities?
Answer
Yes. However, to pass the course an individual must successfully complete the hands-on skills
assessment and receive a passing score on the course test.
Question (23002-19573)
May the renovator training provider give the exam orally?
Answer
Yes. There is no requirement that the course test be conducted in writing. Each individual must
successfully complete the hands-on skills assessment and receive a passing score on the course test to
pass any course.
Question (23002-32491)
Is it permissible for a training provider to employ more than one training manager?
85
Answer
Yes. The Rule requires that a training provider employ a training manager that meets the qualifications in
40 CFR 745.225(c)(1). EPA does not interpret this to be a limitation on the permissible number of training
managers. Therefore, a training provider may employ more than one training manager so long as each
person meets all qualifications in 40 CFR 745.225(c)(1). New training providers seeking accreditation for
more than one training manager can do so by duplicating the application pages for “Applicant
Information,” “Qualifications of Training Program Manager” and “Certification Statement” (Sections B, C
and I) – and attaching them with the rest of the application. An accredited training provider wishing to add
an additional training manager can do so by checking the “Amending Accreditation” box in Section A and
completing the application accordingly. In either case, the training provider should make it clear to EPA in
the application that they are seeking accreditation with multiple training managers.
86
Enforcement and Inspections
Question (23002-24814)
Who would be liable for the fine if a state or local government that was not a certified firm hired a
contractor that was not certified?
Answer
The hired firm would be in violation of the RRP Rule if it was uncertified and performing a covered
renovation.
Question (23002-18140)
I took a class to be a Certified Renovator and my firm applied for firm certification before April 22, 2010,
but my firm does not have its certificate yet. What do we do?
Answer
In these circumstances, EPA does not intend to take enforcement actions against firms who applied for
firm certification before April 22 and have not received their certification. The certification requirement is
important to making sure that firms are protecting children and other residents while renovations are
ongoing, but EPA does not wish to disrupt ongoing renovations for those firms that submitted applications
on time. We expect that all of the applications filed before April 22 will be reviewed by June, and that the
applications submitted for the first 60 days after April 22 will be reviewed soon thereafter. Thus, it will only
be a short window of time when firms that applied are waiting to hear back from EPA.
Question (23002-21890)
What happens if my firm is in the middle of a renovation job on April 22, 2010? My firm is not certified
and none of my employees have taken the lead-safe certified renovator training. What should I do?
Answer
You should submit your application for renovation firm certification immediately. You should also arrange
for lead-safe certified renovator training for at least one of your employees as soon as possible, and you
should require at least one of your employees to review EPA’s online training materials at
http://www.epa.gov/lead/pubs/training.htm. In addition, you must follow the lead-safe work practices
required by the rule. Information on these work practices can be found at www.epa.gov/lead or obtained
from the National Lead Information Center at 1-800-424-LEAD (5323). For the first 60 days after April 22,
2010, EPA’s general approach for work initiated before that date will be, upon learning that a firm or
individual conducting a renovation is not certified or trained, to issue a notice without monetary penalties
to that firm or individual. This notice will state that the firm or individual needs to come into compliance as
quickly as possible. To correct the noncompliance, the individual or firm will need to provide a copy of an
accredited course completion certificate or firm certification to EPA within a reasonable time.
Question (23002-18348)
If a property management company hires a certified firm to perform a renovation and the firm violates the
RRP Rule, for example, by failing to distribute the necessary materials or keep proper records, which
entity is subject to enforcement action, the property manager or the certified firm?
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Answer
It is the certified firm’s responsibility to comply with the requirements of the RRP Rule, and any
enforcement action taken would be against the firm.
Question (23002-15532)
Does EPA’s announcement of June 18, 2010, modify the Lead Renovation Repair and Painting Rule’s
requirements that contractors use lead-safe work practices when working in pre-1978 housing or childoccupied
facilities?
Answer
This announcement does not change the requirement that all contractors take steps to protect children
and families from the dangers of lead poisoning by becoming certified and following the work practice
standards and the associated recordkeeping requirements. As of April 22, all contractors have been
required to be certified and follow the work practice standards described on EPA’s website. The effect of
the June 18 memorandum only provides firms more time to apply for and obtain certification as a leadbased
paint renovation firm before active enforcement of the firm certification requirements begins. EPA
is also providing individual workers additional time to enroll in and take the required training course to
become certified lead-based paint renovators before active enforcement of the individual renovator
training requirements begins. EPA will use its enforcement authority to ensure compliance by enforcing
work practice standards and their associated recordkeeping requirements against all renovators and
firms. Therefore, renovators who have not been able to complete the training requirements are advised to
review EPA’s model training materials available at www.epa.gov/lead/pubs/training.htm. Additional
information on lead-safe work practices can be found at www.epa.gov/lead or obtained from the National
Lead Information Center at 1-800-424-LEAD (5323).
All renovation firms, even those not yet certified under the RRP rule, are also reminded of their continuing
obligations to comply with Lead Renovation, Repair and Painting Rule’s pre-renovation information
distribution requirements, which require that before firms begin each renovation on pre-1978 housing or
child-occupied facilities and to comply with the associated recordkeeping requirements. These
requirements are explained in EPA’s Small Entity Compliance Guide to Renovate Right.
Question (23002-15654)
Does the June 18, 2010, announcement mean that EPA will not enforce certification and training
requirements until after October 1, 2010, for firms and December 31, 2010, for renovators?
Answer
EPA is not stopping its enforcement against any renovation firms and individual renovators who do not
comply with requirements of work practice standards and associated recordkeeping requirements.
However, EPA is providing additional time for renovation firms and workers to obtain the necessary
training and certifications before enforcement of the firm certification and individual renovator
requirements begins.
 Renovation Firms. Until October 1, 2010, EPA will not take enforcement action for violations of
the RRP rule’s firm certification requirement.
 Individual Renovators. EPA will not enforce against individual renovation workers for failure to
be trained if the person has applied to enroll in, or has enrolled in, by not later than September
30, 2010, a certified renovator class to train contractors in practices necessary for compliance
with the final rules. Individual renovators must complete the training by December 31, 2010.
Renovators who have not been able to complete the training requirements are advised to review
EPA’s model training materials available at www.epa.gov/lead/pubs/training.htm. Additional
information on lead-safe work practices can be found at www.epa.gov/lead or obtained from the
National Lead Information Center at 1-800-424-LEAD (5323).
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Question (23002-20668)
Thousands of renovators are already trained and their firms are EPA certified. Will EPA enforce against
renovators who did not receive their training certification before December 31, 2010?
Answer
It is most important that all contractors follow the RRP work practice standards. However, EPA is
providing additional time for renovation firms and workers to obtain the necessary training and
certifications before the enforcement of the firm certification and individual renovator requirements begins.
Therefore, renovators who have not been able to complete the training requirements are advised to
review EPA’s model training materials available at www.epa.gov/lead/pubs/training.htm. Additional
information on lead-safe work practices can be found at www.epa.gov/lead or obtained from the National
Lead Information Center at 1-800-424-LEAD (5323).
Question (23002-17305)
How does the June 18 announcement impact renovators in states that have adopted their own RRP
programs?
Answer
As of July, 2011, twelve states — Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North
Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin – administer and enforce their own
RRP programs. Renovators working in these states must comply with all applicable state laws,
notwithstanding this guidance.
Question (23002-21884)
What happens if an individual applied or was accepted for training before October 1, 2010, but the course
is cancelled or delayed by the training provider during that 90-day period (October 1 – December 31,
2010)? What recourse does the individual renovation worker have after 12/31/10?
Answer
The renovator must complete training by December 31, 2010. EPA encourages renovators and firms to
take advantage of this opportunity and not delay in becoming trained and certified.
Question (23002-17858)
How soon should renovation firms send their applications to EPA?
Answer
Firms should send their applications to EPA as soon as possible. All firms that are not certified by October
1, 2010, will be subject to penalties for failing to comply with the renovation firm requirements of the RRP
rule. EPA has been working to expedite processing of applications but, under the regulations, may take
up to 90 days.
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Question (23002-15746)
Doesn’t the June 18 memorandum extend an unfair advantage to members of the regulated community
who have delayed compliance with the certification and training requirements and punish those who have
complied with the rule?
Answer
EPA does not believe that allowing more time for firms to become certified and renovators to become
trained extends an unfair advantage. To the contrary, firms that are already certified can benefit by
continuing to advertise that they are certified and may continue to use EPA’s program logo during this
interim period. The Agency also recognizes the challenges some are facing in obtaining training in a
timely fashion and is providing additional time to individual renovators to enroll in and take the required
training courses before the Agency actively enforces the individual renovator requirements. EPA is
committed to encouraging additional training opportunities in every state to meet this demand for classes.
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Information for Do-It-Yourselfers
Question (23002-16166)
How can homeowners protect themselves and their families from exposure to lead dust if they plan on
doing their own renovations?
Answer
The RRP Rule does not impose requirements on homeowners performing renovations in their own
homes. If you do decide to do a renovation yourself, it’s very important to take precautions to protect you
and your family from exposure to lead dust. EPA recommends that you follow these simple procedures:
- Contain the work area so that dust does not escape from the area. Cover floors and furniture that
cannot be moved with heavy duty plastic and tape, and seal off doors and heating and cooling system
vents;
- Keep children, pregnant women, and pets out of the work area at all times;
- Minimize dust during the project by using techniques that generate less dust, such as wet sanding or
scraping, or using sanders or grinders that have HEPA vacuum attachments which capture the dust that
is generated; and
- Clean up thoroughly by using a HEPA vacuum and wet wiping to clean up dust and debris on
surfaces and wet mopping the floors with plenty of rinse water before taking down plastic over doors,
windows, and vents.
For more specific information on how to perform renovation, repair, and painting projects safely in your
own home, go to www.epa.gov/lead or call the National Lead Information Center at 1-800-424-LEAD.