FAQ (Reprinted from EPA website)
If a renovation is talking place in a home built in 1950,
but in an addition that was built in 1980, does the RRP Rule apply
to the renovation?
Yes, unless you have determined that the components affected by
the renovation are free of paint or other surface coatings that
contain lead equal to or in excess of 1.0 milligrams per square
centimeter (mg/cm2) or 0.5% by weight. This determination must be
made either by a certified inspector or risk assessor, or by a certified
renovator using an EPA recognized test kit. You must keep records
of any lead-based paint free determination and make the records
available to EPA if requested.
Does a business need to be a certified firm under the RRP
Rule even offering services in pre-1978 property?
Yes. Beginning April 22, 2010, no firm may perform, offer, or claim
to perform renovations covered by the RRP rule without certification
from EPA.
Does the RRP Rule apply to installing replacement windows,
in other words, removing the old sash and installing a new vinyl
window in the opening, without sawing or sanding?
Yes. Window replacement does not qualify for the minor repair or
maintenance exception.
If I rent out apartments built before 1978, in order to
comply with the Renovation, Repair, and Painting (RRP) Rule, do
I need to get firm and renovator certification if I do my own work
on it? What if I hire a renovation firm to do the work?
With respect to landlords, EPA believes that there are two circumstances
where work being done in pre-1978 apartment is for compensation
such that the landlord must be a certified firm and use (or be)
a certified renovator. First, if the landlord does the renovation
him or herself, then the landlord must have firm and renovator certification.
Second if an employee of the landlord does the renovation work,
then the landlord must have firm certification and the employee
must be a certified renovator.
If my firm already has abatement certification, is separate
RRP certification necessary?
RRP firm certification is not required to perform lead abatements.
However, if your firm performs, offers, or claims to perform renovations
as well as abatements, after April 22, 2010 it must be a certified
renovation firm.
A property management company performs most of the clerical
functions of the business, and hires plumbers, electricians, carpenters,
etc., for its renovation needs. Does the property management company
need firm certification to comply with the Renovation, Repair, and
Painting (RRP) Rule?
A property management company acts as an agent for the landlord
and has the same responsibilities as the landlord under the RRP
Rule. Therefore, if the property management company uses its own
employees to do the work, the property management company must be
a certified firm and one of the employees must be a certified renovator.
If the property management company hires a renovation firm to perform
the renovation, the property management company does not need firm
or renovator certification, but the firm the property management
company hires must be certified and must perform the renovation
using a certified renovator that directs and provides on-the-job
training to any workers that are not certified renovators.
What is a renovation?
The RRP Rule covers activities that modify an existing structure
and that result in the disturbance of painted surfaces. All types
of repair, remodeling, maintenance, modernization, and weatherization
projects are covered, including projects performed as part of another
Federal, State, or local program, if the projects meet the definition
of ''renovation''. The term "renovation" includes (but
is not limited to):
- Removing, modifying or repairing painted surfaces or painted
components. Examples include modifying painted doors, surface restoration,
window repair, and surface preparation activity like sanding and
scraping that may generate paint dust.
- Removing building components such as walls, ceilings, plumbing,
or windows.
- Weatherization projects such as cutting holes in painted surfaces
to install blown-in insulation or to gain access to attics, or planing
thresholds to install weather-stripping.
- Interim controls that disturb painted surfaces.
The RRP Program rule only applies to persons who perform renovations
for compensation.
Are state and local government employees who often do renovation
work required to be certified?
If the state or local government uses its own employees to do the
work, the state or local government must be a certified firm and
at least one of the employees assigned to each job must be a certified
renovator. If the state or local government hires a renovation firm
to perform the renovation, the state or local government does not
need firm or renovator certification, but the firm the state or
local government hires must be certified and must perform the renovation
using a certified renovator that directs and provides on-the-job
training to any workers that are not certified renovators.
Must maintenance workers at kindergartens and elementary
schools become certified renovators if they perform renovations
covered by the Renovation, Repair, and Painting Rule in the portions
of the school that are child-occupied facilities? Are the schools
or school systems then required to become certified renovation firms?
On or after April 22, 2010, all renovations covered by the RRP Rule
must be directed by certified renovators and must be performed by
certified renovators or individuals trained by a certified renovator.
The RRP rule requires any firm, including a local government agency,
that performs, offers, or claims to perform renovations to be certified
by EPA.
Are DOE weatherization projects covered under the Renovation, Repair,
and Painting (RRP) Rule?
The RRP Rule defines "renovation" to include weatherization
projects such as cutting holes in painted surfaces to install blown-in
insulation or to gain access to attics, and planing thresholds to
install weather stripping. Other types of weatherization projects,
such as window replacement, are also be covered if they fall within
the definition of "renovation."
Must a certified lead abatement professional also become
trained and certified to do renovation or repair work?
Yes. Because some skills are different (such as cleaning verification),
Renovation, Repair, and Painting training and certification is required
even if someone already has abatement certification. Please note
that if you previously completed an eligible renovation training
course you may take the 4-hour refresher course instead of the 8-hour
initial course from an accredited training provider to become a
certified renovator. For a list of eligible courses, visit http://www.epa.gov/
Is a lead-based paint inspection, performed by a certified
inspector or risk assessor, that includes a written determination
that various building components are free of paint or other surface
coatings containing lead equal to or in excess of 1.0 milligrams
per square centimeter (mg/cm2) or 0.5% by weight sufficient to determine
compliance with requirements of the RRP rule?
The RRP Rule does not apply to target housing where a certified
inspector or risk assessor has determined that the components affected
by the renovation are free of regulated lead-based paint or that
a property is free of lead-based paint for the purposes of the Lead
Disclosure Rule.
Is a health care facility or hospital covered under the
RRP Rule if it meets the definition of a child-occupied facility?
Yes. The RRP Rule defines a child-occupied facility as a building,
or portion of a building, constructed prior to 1978, visited regularly
by the same child, under 6 years of age, on at least two different
days within any week (Sunday through Saturday period), provided
that each day's visit lasts at least three hours and the combined
weekly visits last at least six hours, and the combined annual visits
last at least 60 hours.
If the state or local government uses its own employees to do the
work, the state or local government must be a certified firm and
at least one of the employees assigned to each job must be a certified
renovator. If the state or local government hires a renovation firm
to perform the renovation, the state or local government does not
need firm or renovator certification, but the firm the state or
local government hires must be certified and must perform the renovation
using a certified renovator that directs and provides on-the-job
training to any workers that are not certified renovators.
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