EPA RRP cheat sheet

The RRP Rule (40 CFR Part 745, Subpart E) applies to renovation, repair, or painting of pre-1978 target housing and child-occupied facilities where regulated lead-based paint is disturbed.

Pre-1978 target housing includes any housing constructed before January 1, 1978, except housing for the elderly or persons with disabilities (unless a child under age 6 resides or is expected to reside there) and zero-bedroom dwellings where a child under 6 does not reside.

A child-occupied facility is a pre-1978 building (or portion) visited regularly by the same child under age 6, at least two days per week, at least three hours per visit, at least 60 hours per year, including daycares, preschools, and kindergarten classrooms.

Regulated lead-based paint is paint or surface coating containing lead at 1.0 mg/cm2 or 0.5% by weight; disturbing more than the de minimis amount triggers the rule.

De minimis amount: less than 2 square feet of interior surface, less than 20 square feet of exterior surface, or 10% or less of the total surface area of a small component type per room (interior) or per exterior component.

Exemptions include housing certified as lead-based paint free by a certified inspector or risk assessor, emergency renovations (limited to the extent needed), and activities where no regulated paint is disturbed.

Emergency renovation means work resulting from a sudden, unexpected event (e.g., burst pipe, windstorm, or vandalism) that, if not immediately attended to, presents a safety or public health hazard or threatens equipment.

The emergency provision still requires the firm to be certified, use lead-safe work practices, clean up, and provide the required records and pamphlet; the pre-renovation education and waiting-period requirements are modified.

Minor repair and maintenance activities that disturb less than the de minimis amounts are not covered, but repeated small jobs cannot be combined to evade the threshold.

Firms performing regulated renovations must be EPA-certified (or certified by an authorized state/Tribal program) and must use certified renovators who are trained by EPA-accredited training providers.

A certified renovator must complete an EPA-accredited initial renovator course (typically 8 hours) and refresher training every 5 years to maintain certification.

Firm certification is not the same as individual certification; the firm holds the certification number and is responsible for compliance, records, and work practices.

Non-certified workers may perform renovation tasks only when directed and supervised by a certified renovator who is responsible for on-site compliance.

The certified renovator must be physically present at the work site during certain key activities: post-work cleaning verification and, for initial cleaning, must personally conduct or direct it.

Records the firm must retain for 3 years include: renovator certification, non-certified worker training documentation, occupant pamphlet delivery, and lead test kit results or clearance documentation.

On-the-job training for non-certified workers must cover lead-safe work practices and be documented; the certified renovator provides this training before the worker performs regulated work.

Certified renovators must provide the EPA pamphlet 'The Lead-Safe Certified Guide to Renovate Right' to owners and occupants before work begins and obtain acknowledgment (or document refusal).

Containment: isolate the work area with plastic sheeting (minimum 6 mil) and seal all openings, doors, and HVAC registers; post warning signs and restrict occupant access.

Prohibited practices: open-flame burning, heat guns above 1,100°F, high-temperature power sanding, dry scraping (except limited), and use of certain power tools without HEPA exhaust.

Interior work-area containment: two layers of plastic on floors, one layer on walls and objects; maintain containment until cleaning verification or clearance is complete.

Wet methods and HEPA-equipped tools are required for sanding, scraping, and demolition to control dust; mist surfaces before disturbing paint.

Daily and final cleaning: use HEPA vacuuming, wet wiping, and wet mopping; then perform cleaning verification (or clearance by a certified inspector/risk assessor if required by state program).

Waste from renovation must be contained (e.g., sealed heavy-duty bags or wrapped) and transported and disposed of in accordance with applicable waste regulations.

Occupants must be kept out of the work area until cleaning verification (or clearance) is complete; the certified renovator documents the completion.

Personal protective equipment (respirators, coveralls, gloves, eye protection) is required for workers when dust or paint disturbance is expected.

An EPA-recognized lead test kit may be used by a certified renovator to determine whether a surface is coated with regulated lead-based paint; kits must be used per manufacturer instructions.

A positive test result means the component must be treated as regulated lead-based paint; negative results on all components allow the renovation to proceed as non-regulated.

Test kits are not reliable on certain substrates (e.g., some plastics, metals, or surfaces with multiple layers); in those cases, assume regulated paint is present or use an inspector/risk assessor.

The certified renovator must test each component type to be disturbed; if any component tests positive, the work is regulated.

Documentation of test kit results (component, location, result, date) must be retained by the firm for 3 years.

A certified inspector or risk assessor can determine absence of lead-based paint through paint inspection (XRF or lab analysis); a report of 'lead-free' may exempt the property.

A negative test kit result does not equal a clearance or a lead-free certification; only an inspection report by a certified professional can establish absence of lead-based paint for exemption purposes.

If a test kit is unavailable or the surface cannot be reliably tested, the renovator must presume regulated lead-based paint is present and follow lead-safe work practices.

Landlords and property managers must ensure that renovation firms they hire are EPA-certified and that required records are maintained; they must disclose known lead-based paint hazards to tenants.

Property managers must provide the EPA pamphlet and obtain acknowledgment before renovation; they coordinate occupant notification and access.

Childcare facility operators must ensure the facility (if pre-1978 and child-occupied) is renovated by certified firms and that the required pamphlet is provided to parents/guardians.

Real estate agents must disclose known lead-based paint and hazards, provide the EPA pamphlet, and include the lead warning statement in sales/lease contracts for pre-1978 housing.

Real estate agents are not responsible for performing renovation work but must not misrepresent lead-safe status or advise clients to avoid compliance.

Owners of rental property must provide tenants with the EPA pamphlet 'Protect Your Family from Lead in Your Home' and disclose known hazards under the disclosure rule.

Childcare operators must maintain records of renovation activities and any lead test results for the facility, and provide them to parents upon request.

Property managers must ensure that emergency renovations are still performed by certified firms and that required documentation is completed after the event.

Renovation, repair, and painting (RRP) activities are those that disturb paint surfaces in a way that creates dust but do not permanently eliminate lead-based paint hazards.

Abatement means any measure designed to permanently eliminate lead-based paint or lead-based paint hazards, including removal, enclosure, encapsulation, replacement, or soil removal; abatement requires certified abatement workers and firms.

A lead-based paint inspection determines the presence and location of lead-based paint on components (typically XRF or lab analysis); it does not assess hazards.

A risk assessment identifies lead-based paint hazards (deteriorated paint, dust, soil) and provides options for controlling them; it is performed by a certified risk assessor.

A clearance examination is performed after abatement or renovation to confirm that lead dust levels are below applicable standards; it is not part of RRP unless required by state program.

RRP does not require clearance by a certified inspector/risk assessor under the federal rule (cleaning verification by the certified renovator is used), but some authorized state programs require clearance.

Abatement is not the same as RRP: abatement permanently eliminates hazards and triggers different certification, worker protection, and clearance requirements.

Inspections and risk assessments are performed by certified inspectors/risk assessors, not by certified renovators; a renovator's test kit results do not substitute for these.

EPA may authorize a state or Tribal program to administer and enforce the RRP Rule in its jurisdiction; authorized programs must be at least as protective as the federal rule.

In authorized states/Tribes, firms and renovators must obtain certification from that program, and compliance with the state/Tribal requirements satisfies federal requirements in that jurisdiction.

Authorized programs may impose additional requirements, such as mandatory clearance examinations, different record retention periods, or additional training.

EPA maintains a list of authorized states and Tribes; if a state is not authorized, the federal EPA program applies directly.

Tribal programs may be authorized for specific Tribes; work on Tribal lands may be subject to the Tribal program rather than the state program.

Firms working in multiple jurisdictions must verify whether each state/Tribe is authorized and comply with the applicable program's certification and work practice rules.

Violations of authorized state/Tribal programs may be enforced by the state/Tribal agency and may also be subject to EPA enforcement.

The federal RRP Rule remains the minimum standard; authorized programs cannot be less stringent than the federal requirements.

Target housing does not include housing constructed on or after January 1, 1978, unless it is a child-occupied facility that meets the pre-1978 criterion; post-1978 child-occupied facilities are not covered.

The RRP Rule applies to renovation activities in common areas of pre-1978 multi-unit housing if those areas are child-occupied or if the work disturbs regulated paint.

Work on exterior surfaces is regulated when it disturbs more than 20 square feet of regulated paint or 10% of a small component type.

The de minimis exemption does not apply if the work is part of a larger project that exceeds the de minimis amount; the entire project is then regulated.

Emergency renovations still require the firm to be certified and to use lead-safe work practices, but the pre-renovation education and 7-day waiting period may be modified.

A property certified as lead-based paint free by a certified inspector or risk assessor is exempt from the RRP Rule for that property.

The RRP Rule does not apply to abatement activities, which are covered by separate abatement regulations (40 CFR Part 745, Subpart L).

Renovation of a pre-1978 property that has been tested and found to have no regulated lead-based paint on the components to be disturbed is not regulated.

The certified renovator must ensure that non-certified workers receive on-the-job training in lead-safe work practices before performing regulated work, and must document that training.

The firm must retain records for 3 years, including the renovator's certification, worker training records, occupant pamphlet acknowledgment, and test kit results.

The certified renovator must be on-site during the post-work cleaning verification and must personally conduct or direct the initial cleaning.

Refresher training is required every 5 years; failure to complete refresher training results in loss of certification.

Firm certification requires the firm to designate a certified renovator and to ensure that all regulated work is performed under the supervision of a certified renovator.

The certified renovator must provide the EPA pamphlet to the owner and occupant before work begins and obtain written acknowledgment or document refusal.

Non-certified workers may not perform regulated work unless supervised by a certified renovator who is responsible for compliance.

Training providers must be EPA-accredited; courses from non-accredited providers do not satisfy the certification requirement.

Containment must be established before any paint disturbance begins and must remain in place until cleaning verification or clearance is complete.

Prohibited practices include open-flame burning, heat guns above 1,100°F, high-temperature power sanding, and dry scraping except in limited circumstances.

Wet methods and HEPA-equipped tools are required for sanding, scraping, and demolition to control dust; mist surfaces before disturbing paint.

Daily and final cleaning must include HEPA vacuuming, wet wiping, and wet mopping, followed by cleaning verification or clearance.

Waste must be contained in sealed heavy-duty bags or wrapped and disposed of in accordance with applicable waste regulations.

Occupants must be kept out of the work area until cleaning verification or clearance is complete.

Personal protective equipment, including respirators, coveralls, gloves, and eye protection, is required for workers when dust or paint disturbance is expected.

Warning signs must be posted and occupant access restricted for the duration of the regulated work.

EPA-recognized lead test kits must be used according to manufacturer instructions by a certified renovator to determine whether a surface is coated with regulated lead-based paint.

A positive test result means the component must be treated as regulated lead-based paint; negative results on all components allow the work to proceed as non-regulated.

Test kits are not reliable on certain substrates, such as some plastics, metals, or surfaces with multiple layers; in those cases, assume regulated paint is present.

The certified renovator must test each component type to be disturbed; if any component tests positive, the work is regulated.

Documentation of test kit results, including component, location, result, and date, must be retained for 3 years.

A certified inspector or risk assessor can determine absence of lead-based paint through paint inspection using XRF or lab analysis.

A negative test kit result does not equal a clearance or a lead-free certification; only an inspection report by a certified professional can establish absence of lead-based paint for exemption purposes.

If a test kit is unavailable or the surface cannot be reliably tested, the renovator must presume regulated lead-based paint is present and follow lead-safe work practices.

Landlords and property managers must ensure that renovation firms they hire are EPA-certified and that required records are maintained.

Landlords must disclose known lead-based paint hazards to tenants and provide the EPA pamphlet before renovation.

Childcare facility operators must ensure that pre-1978 child-occupied facilities are renovated by certified firms and that the required pamphlet is provided to parents or guardians.

Real estate agents must disclose known lead-based paint and hazards, provide the EPA pamphlet, and include the lead warning statement in sales and lease contracts for pre-1978 housing.

Real estate agents must not misrepresent lead-safe status or advise clients to avoid compliance.

Owners of rental property must provide tenants with the EPA pamphlet 'Protect Your Family from Lead in Your Home' and disclose known hazards.

Childcare operators must maintain records of renovation activities and any lead test results and provide them to parents upon request.

Property managers must ensure that emergency renovations are performed by certified firms and that required documentation is completed after the event.

RRP activities disturb paint surfaces in a way that creates dust but do not permanently eliminate lead-based paint hazards.

Abatement permanently eliminates lead-based paint or hazards through removal, enclosure, encapsulation, replacement, or soil removal and requires certified abatement workers and firms.

A lead-based paint inspection determines the presence and location of lead-based paint on components using XRF or lab analysis; it does not assess hazards.

A risk assessment identifies lead-based paint hazards and provides options for controlling them; it is performed by a certified risk assessor.

A clearance examination is performed after abatement or renovation to confirm that lead dust levels are below applicable standards.

RRP does not require clearance by a certified inspector or risk assessor under the federal rule; cleaning verification by the certified renovator is used, though some authorized state programs require clearance.

Abatement triggers different certification, worker protection, and clearance requirements than RRP.

Inspections and risk assessments are performed by certified inspectors or risk assessors, not by certified renovators; test kit results do not substitute for these.

EPA may authorize a state or Tribal program to administer and enforce the RRP Rule; authorized programs must be at least as protective as the federal rule.

In authorized states or Tribes, firms and renovators must obtain certification from that program, and compliance with the program satisfies federal requirements in that jurisdiction.

Authorized programs may impose additional requirements, such as mandatory clearance examinations, different record retention periods, or additional training.

EPA maintains a list of authorized states and Tribes; if a state is not authorized, the federal EPA program applies directly.

Tribal programs may be authorized for specific Tribes; work on Tribal lands may be subject to the Tribal program rather than the state program.

Firms working in multiple jurisdictions must verify whether each state or Tribe is authorized and comply with the applicable program's certification and work practice rules.

Violations of authorized state or Tribal programs may be enforced by the state or Tribal agency and may also be subject to EPA enforcement.

The federal RRP Rule remains the minimum standard; authorized programs cannot be less stringent than the federal requirements.