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• Does EPA’s announcement of June 18, 2010 modify the Lead Renovation Repair and Painting Rule’s requirements that contractors use lead-safe work practices when working in pre-1978 housing or child-occupied facilities?

  Answer: This announcement does not change the requirement that all contractors take steps to protect children and families from the dangers of lead poisoning by becoming certified and following the work practice standards and the associated recordkeeping requirements. As of April 22, 2010 all contractors have been required to be…

  • Last published: November 14, 2024

• Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?

  Yes, as long as the installation does not disturb more than six square feet of painted surface per room within a 30-day period. Question Number: 23002-15404 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 14, 2024

• Are renovations performed on detached garages, sheds and other detached outbuildings on the property subject to the RRP Rule?

  Yes. EPA interprets target housing to include pre-1978 buildings or structures that are (1) located on the residential portion of the property, and (2) associated with the residential use of the property. As a practical matter, the entire property of most urban and suburban residential lots is normally considered to…

  • Last published: July 3, 2024

• How does the June 18, 2010 announcement impact renovators in states that have adopted their own RRP programs?

  Answer: If you work in a state authorized by EPA to run their own renovation program, you should contact them for information on their certification requirements. If you work in a state where EPA administers the renovation program your firm needs to be certified by EPA. Please refer to the…

  • Last published: November 5, 2024

• If a certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?

  Answer: The renovation firm is the entity responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The certified renovator is responsible for preparing the records demonstrating that the renovation was…

  • Last published: November 19, 2024

• I have a for-profit business where I purchase residential properties and renovate them. Is this type of renovation work on pre-1978 properties covered by the Lead Renovation, Repair, and Painting (RRP) Rule?

  Yes. Individuals who buy, renovate and sell pre-1978 residential properties for a profit (i.e., house flippers) or lease pre-1978 residential properties (i.e., landlords), and do the renovation work themselves, are performing renovations for compensation and are therefore subject to all requirements under the RRP Rule . You must be a…

  • Last published: November 19, 2024

• How do the RRP requirements apply to renovations on a pre-1978 building that contains both multi-room apartments (i.e., target housing) and zero-bedroom dwellings?

  In pre-1978 buildings that contain a mix of target housing and zero-bedroom dwellings, the Lead Renovation, Repair, and Painting (RRP) Rule applies only to renovations performed in target housing and common areas. Common areas are those portions of a property generally accessible to residents/users of target housing, and can exist…

  • Last published: November 14, 2024

• How long will it take EPA to process my application to be a lead-safe certified firm?

  EPA is required to process your application to be a lead-safe certified firm within 90 days of receipt. In most instances, properly-completed firm applications are processed in about one month. Question Number: 23002-17543 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 14, 2024

• Does zoning affect the target housing determination? For example, would a pre-1978 house that is zoned for commercial or office use, but used for residential purposes be considered target housing?

  In determining whether a pre-1978 property is target housing, it is the actual or intended use of the property that matters, not its zoning classification. Therefore, a pre-1978 house that is used or intended to be used as a residence, even if only temporary, is target housing regardless of its…

  • Last published: November 14, 2024

• If a remodeling company that is a certified firm uses all contractual workers rather than employees, must each contractual worker be a certified renovator, or can the workers be trained on the job by a certified renovator employed by the firm?

  Firms hiring contractual workers may provide the certified renovator that oversees the renovation project and provides on-the-job training to contractual workers and other non-certified workers. Question Number: 23002-18377 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 19, 2024

• If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?

  Yes. To qualify for the exception for minor repair and maintenance activities, the total amount of exterior paint disrupted must be 20 square feet or less. In addition, the job must not use prohibited practices or involve window replacement or demolition of painted surfaces. Question Number: 23002-18379 Find a printable…

  • Last published: November 19, 2024

• If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?

  Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to make the hole is demolition of the surface, so the minor repair and maintenance exception does not apply. Making the hole using a cut-out technique that does not destroy the section of…

  • Last published: November 19, 2024

• If a door is outside the work area but used by workers to enter and exit the room, does the door need to be covered with plastic?

  If the work area is smaller than the entire room, and the door is not within the work area, you do not need to cover the door with plastic. However, all personnel, tools, and other items, including the exterior of containers of waste, must be free of dust and debris…

  • Last published: November 19, 2024

• For an exterior renovation where vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?

  My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely…

  • Last published: November 19, 2024

• In the EPA Certified Renovator Initial course, plastic sheeting is taped to the floor at several corners, but not around the entire perimeter. Must the plastic be "sealed" to the floor on all four edges by tape or just taped at several locations?

  It depends on the specifics of the renovation job. The RRP Rule requires the renovation firm to cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to…

  • Last published: November 19, 2024