Laws & Regulations

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…

Last published: November 12, 2025

My firm was hired to scrape and repaint siding on a pre-1978 home. The siding is relatively new and was installed after 1978, but was nailed over top of the old lead-based exterior paint. Does the Lead Renovation, Repair and Painting (RRP) Rule apply?

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 milligram per square centimeter (mg/cm2) or 0.5% by weight…

Last published: November 12, 2025

For an exterior renovation where 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?

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…

Last published: November 12, 2025

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…

Last published: November 12, 2025

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 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 six feet the perimeter of the work…

Last published: November 12, 2025

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 Lead Renovation, Repair, and Painting (RRP) Rule does not apply. For more information on what types of activities disturb paint, go to the following question: 23002-14867 . Question Number: 23002-19760…

Last published: November 12, 2025

My firm plans on doing renovation work on a storage building of an apartment complex. The apartment complex is target housing, but the storage building was constructed after 1978. Will our work on the storage building be covered under the RRP Rule?

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…

Last published: November 12, 2025