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.

Question Number: 23002-19962

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