Skip to main content
U.S. flag

An official website of the United States government

Here’s how you know

Dot gov

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

HTTPS

Secure .gov websites use HTTPS
A lock (LockA locked padlock) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

    • Environmental Topics
    • Air
    • Bed Bugs
    • Cancer
    • Chemicals, Toxics, and Pesticide
    • Emergency Response
    • Environmental Information by Location
    • Health
    • Land, Waste, and Cleanup
    • Lead
    • Mold
    • Radon
    • Research
    • Science Topics
    • Water Topics
    • A-Z Topic Index
    • Laws & Regulations
    • By Business Sector
    • By Topic
    • Compliance
    • Enforcement
    • Laws and Executive Orders
    • Regulations
    • Report a Violation
    • Environmental Violations
    • Fraud, Waste or Abuse
    • About EPA
    • Our Mission and What We Do
    • Headquarters Offices
    • Regional Offices
    • Labs and Research Centers
    • Planning, Budget, and Results
    • Organization Chart
    • EPA History

Breadcrumb

  1. Home
  2. Lead

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 and verification, and recordkeeping. The type of activity described in the question should not be confused with a “whole house gut-rehabilitation project” that effectively results in new construction as discussed in FQ 23002-18426.

EPA has recognized the fact that there may be circumstances where it is impossible for firms to meet all of the requirements under the RRP Rule. To the extent that performance of an RRP requirement would be impossible, the firm is excused from compliance. However, impossibility of one work practice does not excuse a firm from complying with other requirements. EPA further recommends that the firm document and keep records of the specific circumstances surrounding the impossibility.

With respect to the comprehensive renovation activities described in the question, impossibilities may be more prevalent. For example, during removal of a floor, covering the floor surface with taped-down plastic sheeting as required by 40 CFR 745.85(a)(2)(i)(D) would be impossible. As described above, the firm would be excused from this requirement. Nevertheless, the firm must still ensure that the work area is properly contained. Windows, doors and ducts in the work area must be closed and covered. Precautions must be taken to ensure that all personnel, tools, and other items are free of dust and debris before leaving the work area. At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris, and disposed of properly.

Following the renovation, the work area must also be cleaned until no dust, debris or residue remains. If no more painted surfaces will be disturbed, then cleaning may take place after either removal of all components, or after all new surfaces have been installed. Further, should cleaning or verification be impossible to achieve (for example, due to the nature of the surfaces), a firm must still make their best effort to collect and remove all paint chips, dust, debris and residue. See FQ 23002-15872.

Question Number: 23002-23415

Find a printable PDF copy of all frequent questions pertaining to lead.

Other Frequent Questions about Lead

General Information about Lead
Testing for Lead
Renovation, Repair and Painting
Abatement, Risk Assessment and Inspection

Applying for Certification or Accreditation
Lead-Based Paint Program Fees
EPA/HUD Real Estate Notification & Disclosure Rule

Lead in Products
Lead in Drinking Water
Lead at Superfund Sites

Lead

  • Learn About Lead
  • Protect Your Family
  • Renovation, Repair and Painting Program
  • Evaluating & Addressing Lead-Based Paint Hazards
  • Real Estate Disclosure
  • Lead Laws and Regulations
  • En español: Plomo
Contact Us about Lead
Contact Us to ask a question, provide feedback, or report a problem.
Last updated on November 5, 2024
  • Assistance
  • Spanish
  • Arabic
  • Chinese (simplified)
  • Chinese (traditional)
  • French
  • Haitian Creole
  • Korean
  • Portuguese
  • Russian
  • Tagalog
  • Vietnamese
United States Environmental Protection Agency

Discover.

  • Accessibility Statement
  • Budget & Performance
  • Contracting
  • EPA www Web Snapshot
  • Grants
  • No FEAR Act Data
  • Plain Writing
  • Privacy
  • Privacy and Security Notice

Connect.

  • Data
  • Inspector General
  • Jobs
  • Newsroom
  • Regulations.gov
  • Subscribe
  • USA.gov
  • White House

Ask.

  • Contact EPA
  • EPA Disclaimers
  • Hotlines
  • FOIA Requests
  • Frequent Questions
  • Site Feedback

Follow.