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About the Renovation, Repair and Painting Rule
  • Enroll Online Now
  • To whom does the RRP Rule apply?
  • Where does the RRP Rule apply?
  • What does the RRP Rule require?
  • What should Contractors do?
  • What Training is required?
  • What is Firm Certification?
  • Frequently Asked Questions (FAQs)
  • To enroll in an RRP class now, go HERE
    NOTE: The Federal law creating the Renovation, Repair, and Painting Rule (RRP) was passed in 2008. The Rule actually went into effect on April 22, 2010 and was updated on July 15, 2011. (40 CFR 745.80, Subpart E)

    Introduction 
    EPA's RRP Rule requires anyone (remodeling, renovation and painting contractors and most other trades) who works in pre-1978 housing for compensation and who might disturb painted surfaces to become an EPA Certified Renovator by taking a "Lead Safe Work Practices" RRP class from an EPA accredited training provider.

    A summary of the Rule - with California-related Notes - follows:

    Why is the RRP Rule important? 
    When lead paint is sanded or scraped or disturbed, microscopic particles of the metal mingle with the dust that is created. That "lead-containing" dust is what can seriously impact people's health, especially children and pregnant women.  

    Lead causes a long list of problems, including learning and behavioral problems, kidney disease, high blood pressure, miscarriage and birth defects.  Lead can even cause depression and aggressive behavior.  Experts say lead poisoning doubles the number of children in special education classes. Studies show it plays a major role in crime rates. Any amount of lead is bad for you. There is no safe level. 
    There has been a lot of publicity about toys and other consumer products containing lead.  But, problems caused by all of those products put together is a drop in the bucket compared to the number of people harmed when contractors disturb old paint in pre-1978 buildings without taking some simple precautions. 
    That's why EPA and the State of California require contractors to protect people they work for. 
      NOTE: California's lead-based paint related regulations have been in effect since 2003. The EPA's Renovation, Repair and Painting Rule (or RRP) went into effect on April 22, 2010.
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    To Whom does the RRP Rule apply?
    The RRP rule applies to anyone who works for compensation in pre-1978 housing and child-occupied facilities, including:
      * General contractors
      * Demolition workers
      * Remodeling contractors
      * Maintenance workers in multi-family housing
      * Painters, plumbers and most specialty trades.
    The RRP rule covers a lot of jobs: renovation, remodeling, painting, window replacement, plumbing, electrical work, heating & air-conditioning, demolition, plus work performed by trades like carpenters, electricians and handymen.  The rule also applies to persons working for rental property owners, schools, and day care providers.  And, it also applies to non-profits and governmental agencies.

    Where does the RRP Rule apply?
    The RRP rule applies to "Target Housing" and "Child-Occupied Facilities."
      NOTE: California's lead-based paint regulations cover ALL pre-78 structures that have not been tested - not just Target Housing and Child-Occupied Facilities. (Title 17, CCR, Div 1, Ch 8)
    Definition: Target Housing - is a house or apartment (including mobile homes) built before January 1, 1978 except for: 
      1) 0-bedroom units (like dorm rooms or studio apartments)
      2) housing that is officially designated for the elderly or the handicapped
      3) housing that has been tested by a State Certified Lead Inspector and found to be free of lead-based paint.
    Definition: Child-Occupied Facility - is a building, or portion of a building, constructed prior to 1978, visited by the same child, 6 years of age or under, on at least 2 different days within any week, provided that each day's visit lasts at least 3 hours, the combined weekly visit lasts at least 6 hours, and the combined annual visits last at least 60 hours. Such facilities may include, but are not limited to, day-care centers, preschools and kindergarten classrooms.
      NOTE: On August 26, 2009, EPA announced plans to, "expand lead safe work practices and other protective requirements for ... work involving lead paint to most buildings, including public and commercial structures, built before 1978."


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    What does the RRP Rule require?
    1. Pamphlet Distribution - Contractors must give clients a pamphlet called "Renovate Right" and get a signed receipt before beginning a job.

    Contractors can call (800) 424-5323 and ask for free copies of "Renovate Right" and the "Small Entity Compliance Guide to Renovate Right" or both can be downloaded as PDF files from the
    EPA website.

    2. Individual Certification - At least one RRP Certified Renovator is required at each job site. Certification involves taking a 1-day class from an EPA Accredited Training Provider like HomeSafe.  For available classes visit: RRP Training
      Note: State Certified Lead Abatement Supervisors and Workers must also become RRP certified, but they only need to take a 1/2 day "refresher" class.
    3. Firm Certification - In addition to individual certification, each firm, agency or non-profit must also become RRP certified. (Note: This includes city agencies and school districts as well as small "one-man-band" handymen and owners of rental property.) Firms or "entities" must submit an application and pay EPA a fee ($300) which is good for 5 years.

    The EPA Firm Certification Register your firm online at
    EPA web site. You do not need individual certification to submit a Firm Application. Firms should apply as soon as possible.
    According to the EPA, after April 22, 2010, "... no firm working in target housing or child-occupied facilities, where lead-based paint will be affected by the work, may perform, offer or claim to perform renovations without EPA Firm Certification."

    Firm certification is NOT the same as individual certification attained by successful completion of an RRP course. There is no training requirement for Firm Certification.
      Note: Abatement firms must be RRP Certified if they do non-abatement jobs.
    4. On-the-Job-Training - RRP Certified Renovators are rerquired to train all non-certified people at the job site. 
      Note: Contractors who do business with agencies receiving Federal money for housing rehabilitation, etc must have everyone trained in the classroom.
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    5. Paint Testing - The RRP rule requires contractors to either test paint they will disturb BEFORE beginning a job, or assume that the paint is lead-based. This testing is to be done using EPA-approved test kits. However, this does NOT apply in California.
      Note: In California contractors MAY NOT test paint. California law requires contractors to assume all surfaces in all structures built before 1978 contain lead-based paint, unless they have been tested and found to be "lead-based paint free" by a State Certified Lead Inspector/Risk Assessor. No one else can test for lead-based paint in California.
    6. Lead Safe Work Practices Required - The RRP Rule requires that "Lead Safe Work Practices" be used when disturbing more than 6 sq feet per room or 20 sq feet outside. 
      Note: However, since 2003, California law (Title 17) has required that "Lead Safe Work Practices" be used in ALL pre-1978 structures when disturbing any amount of known or "presumed" lead-based paint.
    "Lead Safe Work Practices" aren't difficult or costly.  Buying a good HEPA vacuum is probably the biggest expense.  Shop Vacs adapted with HEPA filters are not allowed. Certified HEPA vacuums are the only type of vacuum permitted under the RRP Rule. (As well in as OSHA's Lead-in-construction standard and HUD's Title 10.)

    7. Cleaning Verification - At the end of each job, contractors are required to perform a "cleaning verification" to make sure they cleaned up properly.  They wipe a cleaned area and then compare the wipe against a picture on a laminated "Cleaning Verification" card.  If the wipe is lighter than the picture on the card, the area is considered to be clean.  
      Note: This is a controversial part of the regulation. Standard procedure after most lead jobs is to hire a 3rd-party State-Certified Lead Inspector to take (clearance) dust samples for laboratory evaluation. However, as of today, the RRP rule does not require 3rd-party testing of any kind. 
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    What do Contractors Need to Do?
    1.  Sign up for an EPA Accredited
    RRP Class or call HomeSafe at (800) 648-5323.
      NOTE: Lead Abatement Workers & Supervisors already state certified should sign up for a 4-hr RRP Refresher.
    2.  Obtain free copies of "Renovate Right" and the "Small Entity Compliance Guide" by calling 800-424-5323 or, download them from the EPA Publications page.
    3.  Purchase a good quality HEPA vacuum (if you don't already own one). They are available from most Remediation or Environmental Equipment suppliers.

    4. For more about the RRP Rule visit the: EPA RRP Page.


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    Frequently Asked Questions ... from the EPA
    RRP FAQ page.
    Q: Are 3rd Party lead-based paint inspections required before RRP jobs?
    A: No, 3rd party inspections are not currently required. However, contractors must "assume" that any un-tested pre-1978 structure contains lead-based paint (LBP) in which case lead safe work practices are required.

    Q: Are public schools subject to the RRP rule?
    A: Yes, RR&P applies to all schools public, private and alternative.

    Q: If I have three apartment buildings - each it's own LLC - and I work on each of them as owner, do I need three firm certs?
    A: Only one firm certification and only one project overseer needs to have the eight hours of training for the apartment maintenance unit regardless of the number apartments handled.

    Q: While the rule specifically mentions "surface coatings" such as paint, varnish or shellac, it does not mention stain. Are stained surfaces subject to the RRP Rule?
    A: Yes, comes under coatings.

    Q: Do workers need to be trained in a task - say wet sanding - at every job, or once trained are they considerd trained for all successive jobs?
    A: On-the-job training is required at every job except when you can document that a worker has been previously trained.

    Q: If I am a handyman working alone do I need a Firm certification?
    A: Yes, to work on pre-78 structures, you will need both the individual and the firm certifications.

    Q: If a general contractor hires a subcontractor to work at a renovation site, does the subcontractor need to be a certified firm if the subcontractor does not disturb any paint?
    A: Firms performing tasks that disturb no painted surfaces whatsoever do not need to be certified. However, since conditions at the job site may be difficult to predict, EPA strongly recommends that all firms involved in the renovation be certified and use properly trained and certified personnel.

    As every renovation job is different, it is up to the general contractor to determine what activities are within the scope of the renovation and to ensure that other firms on the job are properly trained and certified for the tasks they will be performing. All firms, including the general contractor, are responsible for making sure the renovation is performed in accordance with the work practice standards, including keeping containment intact and making sure lead dust and debris do not leave the work site. General contractors should keep in mind that if a they hire a subcontractor that fails to follow the work practice standards or otherwise violates the Renovation, Repair, and Painting rule, they (the General Contrqactor) will also be held responsible for the violation.


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