RRP Rule scope, applicability and exemptions (pre-1978 housing, child-occupied facilities, emergency/disaster provision)
This domain tests whether you can decide, before work begins, whether the RRP Rule applies. Exam questions ask you to classify the building, identify the disturbed painted surface, and apply narrow exemptions without overreading them.
What triggers the rule
- A renovation is a modification of an existing structure that disturbs painted surfaces, including removal or replacement of painted components. It excludes minor repair and maintenance and excludes abatement.
- Target housing is housing constructed before January 1, 1978. Two categorical exclusions apply: housing for elderly or disabled persons, and zero-bedroom dwellings, but only when no child under age 6 resides there.
- A child-occupied facility is a pre-1978 building or portion regularly visited by the same child under 6, generally at least 6 hours per week or 60 hours per year. Classrooms and common areas can qualify.
- The job needs a certified firm and a certified renovator, plus pre-renovation education.
Exemptions and limits
- Minor repair and maintenance: no more than 6 square feet of interior painted surface per room or 20 square feet exterior. It never covers window replacement, demolition of painted surfaces, or work using prohibited practices.
- Emergency renovation: a sudden, unexpected event that requires immediate action. The firm is exempt from pre-renovation education and the 7-day waiting period, but must still use lead-safe work practices and cleaning verification, and must keep records.
- There is no owner-occupant opt-out; the former opt-out was eliminated.
- Work that does not disturb paint is outside the rule; permanent elimination is abatement, not RRP.
Worked example
A landlord renovates a 1962 rental bathroom, replacing a vanity and disturbing 9 square feet of painted wall. The 9 square feet exceeds the 6-square-foot interior limit, so the minor repair exemption is unavailable. The landlord must use a certified firm, provide the Renovate Right pamphlet at least 60 days before and wait 7 days, contain the work area, and complete cleaning verification. If only 4 square feet were disturbed and no prohibited practice or window replacement were involved, the minor repair exemption could apply, but the firm should document the measurement.
Traps that cost marks
- Treating 1978 as included; pre-1978 means before January 1, 1978.
- Measuring per component instead of per room, or swapping the 6-square-foot and 20-square-foot limits.
- Assuming an emergency removes all work-practice duties.
- Thinking “no children live here” lifts the rule; only the two categorical exclusions apply, and each has a child-under-6 caveat.
- Missing common areas and parent notification in child-occupied facilities.