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Summary of the Lead RRP Rule

EPA Renovation, Repair, and Painting Rule

EPA Lead: Renovation, Repair & Painting Program

The Environmental Protection Agency (EPA) issued a final rule on April 22, 2008 under the authority of § 402(c)(3) of the Toxic Substances Control Act (TSCA) to address lead-based paint hazards created by renovation, repair, and painting (RRP) activities that disturb lead-based paint in “target housing” and “child-occupied facilities.” According to this rule, contractors conducting RRP activities on any pre-1978 residential property, apartment or child occupied facility with children less than six years of age will need to be trained as renovators and certified as firms through EPA. The final rule went into effect on April 22, 2010.

At least 66% of the homes built between 1940 and 1960 contain lead-based paint. For those built before 1940, around 90% contain lead-based paint. Lead exposure can cause damage to nearly every organ in the body, and is especially dangerous for children, whose bodies are still developing. Children who are exposed to even low levels of lead are more likely to experience learning delays, developmental problems, and behavioral problems. Adults who are exposed to lead through their work can also experience health problems, and they can accidentally bring lead residue home to their families.

What is covered by the rule?

The rule applies to paid contractors working in pre-1978 housing, child care facilities and schools with lead-based paint. Contractors include home improvement contractors, maintenance workers in multi-family housing, painters and other specialty trades. The covered facilities include residential, public or commercial buildings where children under age six are present on a regular basis as well as all rental housing. The rule applies to renovation, repair or painting activities. It does not apply to minor maintenance or repair activities affecting less than six square feet of lead-based paint in a room or less than 20 square feet of lead-based paint on the exterior. Window replacement is not minor maintenance or repair.

What does the rule require?

The rule, issued under the authority of section 402(c)(3) of the Toxic Substances Control Act (TSCA), 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.

What is renovation?

Renovation is defined as modification of any existing structure that results in the disturbance of painted surfaces. The RRP rule covers all activities done for compensation that disturb painted surfaces including most repair, remodeling and maintenance activities, such as window replacement, weatherization and demolition.

What are the responsibilities of the firm?

Firms performing renovations must ensure that:

  • All persons performing renovation activities are certified renovators or have received on-the-job training by a certified renovator;
  • A certified renovator is assigned to each renovation performed by the firm; and
  • All renovations are performed in accordance with applicable work practice standards.

What work practices are required?

Certain dangerous work practices are prohibited for every renovation, including minor maintenance or repair jobs. These prohibited practices are: open flame burning or torching; sanding, grinding, needle gunning, or blasting with power tools and equipment not equipped with a shroud and High Efficiency Particulate Air (HEPA) vacuum attachment; and using a heat gun at temperatures greater than 1100° F.
These are examples of work practices described in the rule:

  • Renovations must be performed by certified firms.
  • Certified firms must use certified renovators to perform certain activities and will provide on-the-job-training for uncertified workers.
  • 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.
  • 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.
  • Waste from renovation activities must be contained to prevent releases of dust and debris.
  • After the renovation is complete, the firm must clean the work area. The certified renovator must verify the cleanliness of the work area using a procedure involving disposable cleaning cloths and the new EPA Cleaning Verification Card.

What are the notification requirements?

The rule requires that occupants and other specified individuals receive certain information before a lead renovation project.  For homeowners and tenants, renovators must give both parties the pamphlet titled "Renovate Right: Important Lead Hazard Information for Families, Child Care Provider and Schools"before starting work in their living area(s).  The firm must get a signature proving receipt of delivery or document the attempted method of delivery when a signature was not obtained.  Other requirements apply when working in common areas of residential properties or in child occupied facilities.
The certified firm must maintain documentation describing how and when notification procedures were accomplished.

How does a firm become certified?

Firms that perform renovations for compensation will apply to EPA or a state that has an approved program for certification to perform renovations. For EPA certification, firms will have to apply for re-certification every five years.  A $300.00 fee is required to become EPA certified.

How do renovators and dust sampling technicians become certified?

A person can become:

  1. A certified renovator by either
    1. successfully completing an accredited renovator training course, or
    2. successfully completing an accredited refresher renovator training course, if the individual previously completed an accredited abatement worker or supervisor course, or has completed an EPA, HUD, or EPA/HUD model renovation training course.

  2. A certified dust sampling technician by either
    1. successfully completing an accredited sampling technician course, or
    2. successfully completing an accredited refresher dust sampling technician course, if the individual previously completed an accredited lead-based paint inspector or risk assessor course.

To maintain certification, a person must complete an accredited refresher course every five years.

What is the role of the certified renovator?

A certified renovator:

  • Performs or directs uncertified workers performing regulated renovation activities;
  • Provides training to uncertified workers on lead safe work practices;
  • Is required to be at the work site during key stages of a renovation, and at other times be available on-site or by telephone; and
  • May use an acceptable test kit to determine whether lead-based paint is present in affected areas.
  • Must perform the cleaning verification procedure to verify the successful completion of cleaning activities within each work area.

What role do the States have in this regulation?
States and tribes may become authorized to implement this rule. The rule contains procedures for the authorization of states, territories, and tribes to administer and enforce these standards and regulations in lieu of a federal program.

What is not covered by the rule?

The rule does not apply to:

  • Owner-occupied housing where children under six and/or a pregnant woman do not reside;
  • Minor repair and maintenance activities that disrupt six square feet or less of painted surface per room for interior projects, and twenty square feet or less of painted surface for exterior projects; and
  • Renovations where it is determined the renovation will not involve lead-based paint. The determination that the components affected by the renovation are free of lead-based paint can be made by a certified inspector or risk assessor, or by a certified renovator, using an EPA recognized test kit.

Where can I get more information?
For general information contact the National Lead Information Center at 1-800-424-LEAD. Information is also available at www.epa.gov/lead or at www.minnesotalead.com.



The application can be downloaded from our Forms page CLICK HERE.