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 involve window replacement or demolition of painted surfaces. If the job described, when combined with other renovation work on the exterior of the building, does not disrupt more than 20 square feet of painted surface, and does not use prohibited practices or involve window replacement or demolition of painted surfaces, it is a minor repair and maintenance activity that is not subject to the requirements of the RRP rule.

Question Number: 23002-19724

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