Q: My firm installs replacement doors, Is this work subject to the RRP Rule?

Because doors are not cut-outs, the entire surface area is not counted for purposes of calculating the six square feet threshold of minor maintenance and repair—unless removing the door also...

Because doors are not cut-outs, the entire surface area is not counted for purposes of calculating the six square feet threshold of minor maintenance and repair—unless removing the door also disturbs any paint on the door (e.g., because of the deteriorated condition of the paint or any dust-generating activities).  Therefore, if unbolting and unscrewing a door disturbs paint only on the bolts, screws and/or hinges, but does not otherwise disturb a painted surface on the door, frame, 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.