My firm repairs windows in which the glass has been cracked or broken by removing and replacing the sash. For casement windows, we unscrew and remove the hinges on the old window, pull out the old sash, and install the new sash. For double-hung windows, we release the jambliner, pull out the sash with the damaged glass, and install the new sash. We may disturb paint on the hinges and screws, but do not otherwise disturb a painted surface. Is this work subject to the RRP Rule?

Answer: Replacement of a window sash by simply unscrewing hinges or releasing it from a jambliner does not constitute “window replacement” for purposes of the RRP Rule. Therefore, such tasks may fit within the definition of minor repair and maintenance i.e., activities that disturb six square feet or less of interior painted surface, or twenty square feet or less of exterior painted surface.

If unscrewing a hinge or releasing a jambliner disturbs paint on the screws and/or hinges, but does not otherwise disturb a painted surface on the window sash, frame, casing, sill, trim or surrounding walls, then the activity likely disturbs less than six square feet of painted surface and would not be subject to the RRP Rule.

Question Number: 23002-19759

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