Laws & Regulations
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Does the RRP Rule apply to renovations that disturb ceramic tile where the glaze on the tile contains lead at regulated levels?
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. Question Number: 23002-15691 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does the RRP Rule apply to removing a roof that is not painted?
The RRP Rule applies to work that disturbs painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15689 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does the RRP Rule apply to demolishing and disposing of the following types of structures?
Question: 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…
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Does the Renovation, Repair, and Painting (RRP) Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?
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 Number: 23002-15696 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?
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 Number: 23002-15404 Find a printable PDF copy of all frequent questions pertaining to lead .
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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…
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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. How do I calculate the area of the paint that is affected for purposes of the minor repair and maintenance provision?
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…
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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…
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Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been painted?
Answer: The Lead Renovation, Repair, and Painting (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 Number: 23002-14025 Find a printable PDF copy of all frequent questions pertaining to lead .
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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 share…
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Under the Lead Renovation, Repair and Painting (RRP) Rule, when testing a property for the presence of lead prior to beginning a renovation using an EPA-recognized lead test kit, must I test every component affected by the renovation?
Yes. Certified renovators using EPA-recognized lead test kits 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 because certified renovator training does not cover sampling protocols…
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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. 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 Number: 23002-19775 Find a printable PDF copy of all frequent…
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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 Number: 23002-31784 Find a printable PDF copy of all frequent questions pertaining to lead .
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My firm acts as a general contractor - we subcontract the entire renovation job to other companies rather than using our own employees. Under the Renovation, Repair, and Painting (RRP) Rule, 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…
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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 Number: 23002-18225 Find a printable PDF copy of all frequent questions pertaining to lead .
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Are there any American Society of Testing Materials (ASTM) standards that EPA considers “documented methodologies”?
Answer: Yes. ASTM Standards are voluntary consensus standards developed after careful review by technical committees which generally include EPA and HUD staff. ASTM Standards relating to lead often reference EPA and HUD documents, just as EPA and HUD documents often reference appropriate ASTM Standards. Although EPA did not specifically list…
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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?
Yes. The attesting individual need not be a certified renovator. Question Number: 23002-18047 Find a printable PDF copy of all frequent questions pertaining to lead .
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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?
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…
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What do I do if I need to mail a paper Electronic Signature Agreement (ESA) due to Identity Proofing failure or opting out of the online process?
A paper ESA will be sent to the email address provided on your application. A copy of this form can also be found in your CDX Inbox. Print this form, sign it, and mail it to: EPA Lead Data Processing Center c/o CGI Federal 12601 Fair Lakes Circle Fairfax, VA…
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What is a “whole house gut rehabilitation project” for Lead Renovation, Repair and Painting (RRP) Rule purposes? If target housing has, at some point after 1978, been gut-rehabbed, would the RRP Rule apply to subsequent renovations on the property?
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…