Frequently Asked Questions
More Frequently Asked Questions can be found on the
EPA's website
If I am a General Contractor, do my sub-contractors need
training?
Yes, the EPA has determined that workers in the containment area
must be employees of a Certified Firm and be Certified Remodelers
or Non-certified workers trained by the Certified Renovator. This
means the General Contractor must be a Certified Firm. His
sub-contractor must be a Certified Firm with his own Certified
Renovators.
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 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.
