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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 .
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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…
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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…
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When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or…
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What is the timeline for posting the responses? Will we receive an email with notification on the answers or shall I monitor the website for the posting?
EPA will respond to the individual email 1 - 2 days after receipt and will post the questions and answers to the RFA website very soon thereafter.
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My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the new carpet, but sometimes there is. How do I know when I need to comply with the Lead Renovation, Repair and Painting (RRP) Rule?
If when installing the carpet, you disrupt six square feet or less of painted surface per room, the job is not covered by the RRP Rule . Question Number: 23002-19749 Find a printable PDF copy of all frequent questions pertaining to lead .
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Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.”
Answer: “Minor repair and maintenance” is defined in 40 CFR 745.83 as activities that disrupt less than 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or…
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Does the minor maintenance exception mean that if I drill one-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule?
The exception is based on the area of paint disrupted, which in this example is based on the combined areas of the holes drilled in the wall. Question Number: 23002-15677 Find a printable PDF copy of all frequent questions pertaining to lead . Other Frequent Questions about the RRP Program…
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In a multi-family building, does the standard for interiors of six square feet or less, or the standard for exteriors of 20 square feet or less of disrupted painted surface apply to the whole building or can it be applied to each separate unit?
For interiors, the exception for work that disrupts six square feet or less of painted surface applies to each individual room and is inclusive of all work done in the room in any 30-day period. For exteriors, to qualify for the exception for minor repair and maintenance activities, the total…
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Is replacing a pane of glass or fixing a broken window balancer a renovation covered by the RRP Rule?
It depends. Replacing a pane of glass or fixing a broken window balancer can disturb paint. If the job disrupts more than six square feet of painted surface per room, the job is not considered minor repair and maintenance and it is covered by the RRP Rule. When removing a…
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How can homeowners protect themselves and their families from exposure to lead dust if they plan on doing their own renovations?
The Lead Renovation, Repair and Painting Rule does not impose requirements on homeowners performing renovations in their own homes. If you do decide to do a renovation yourself, it's very important to take precautions to protect you and your family from exposure to lead dust. EPA recommends that you follow…
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As a floor covering installer I use an undercut saw to remove a small amount of wood at the bottom of baseboards and door casings. How do I calculate the area of the paint that is affected for purposes of the minor repair and maintenance provision?
As a floor covering installer I use an undercut saw to remove a small amount of wood at the bottom of baseboards and door casings. I am only disturbing the paint in the 1/8 inch cut of the blade. How do I calculate the area of the paint that is…
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If an electrician or plumber, working in a different room from the contained renovation project, needs to drill or cut a hole six square feet or less in size to chase a wire or pipe, does the RRP rule apply to that work?
As long as six square feet or less of painted surface in that room is disrupted with 30 days, including the work done by the electrician or plumber, and the job does not use prohibited practices or involve window replacement or demolition of painted surfaces, the minor repair and maintenance…
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If a renovator disrupts six square feet or less of painted surface per room in several rooms inside one property, does the RRP Rule apply?
No, as long as no prohibited work practices are used and the work does not involve window replacement or demolition of painted surfaces. The exception to the Lead Renovation, Repair, and Painting (RRP) Rule for work that disrupts six square feet or less of painted surface applies to each individual…
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My company installs new or replacement seamless gutters. We install the gutters using self-tapping screws and the cumulative size of the total number of holes is only a couple of square inches. If the job does not involve sanding, scraping, repainting, repair, replacement or reconditioning of the fascia surface, is it covered by the RRP Rule?
Minor repair and maintenance activities are not subject to the requirements of the Lead Renovation, Repair, and Painting (RRP) Rule . For exterior renovations, minor repair and maintenance activities are those activities that disrupt 20 square feet or 29 less of painted surface, and do not use prohibited practices or…
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