My firm installs replacement doors. We simply remove the hinge bolts, unscrew and remove the hinges, and install the new door and hinges. We may disturb paint on the hinges and bolts but no other painted surface. Is this work subject to the RRP Rule?

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 six square feet 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 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 Number: 23002-19751

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