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My firm removes and replaces garage doors made up of multiple panels, each of which has an exterior painted surface area of <20 square feet. If we disturb the paint on just one of the door panels, is that activity subject to the Lead Renovation, Repair and Painting (RRP) Rule?
An activity that disturbs less than 20 square feet of exterior painted surface and otherwise meets the definition of minor repair and maintenance is not subject to the RRP Rule . However, the RRP Rule provides that when removing painted components, or portions of painted components, the entire surface area…
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