RRP Program

• RRP Rules

  1. What is the purpose of the RRP Rule?

  2. What does the RRP Rule require?

  3. Who is covered by the RRP Rule?

  4. Is it a violation of the RRP Rule for a homeowner to hire a firm that is not certified?

  5. How much will it cost contractors to comply with the RRP Rule?

  6. What records will my firm be required to keep?

  7. Will insurance premiums go up for contractors that work in homes and child-occupied facilities?

  8. Is there any one document that includes the latest version of the RRP rule with all amendments?

  9. If there are differences among EPA’s, HUD’s, and my State’s requirements, which ones do I have to comply with?

  10. Do the asbestos abatement workers also need to comply with the RRP rule?

  11. Does the RRP Rule apply to states and local governments?

  12. I am planning to renovate my home. How can I find a lead-safe certified firm?

  13. How to identify whether the firm is lead-safe certified or not?

  14. How long will it take EPA to process my application to be a lead-safe certified firm?

  15. I am a renovation firm. What should I do if all certified renovator classes near me are full?

  16. I am a firm and there are no training providers offering classes near me. What do I do?

  17. My state will adopt its own lead RRP program. Do I have to also be certified by EPA?

  18. How can I find a certified renovation firm in my area?

  19. Can a firm that has not received certification from EPA work on pre-1978 properties?

• Renovations Covered by the RRP Rule

  • General Renovation

    1. How is window repair or maintenance, as distinct from removal, treated under the RRP Rule?

    2. Does the RRP rule apply to renovations done in an apartment between tenants?

    3. Does the RRP Rule prohibit the deconstruction and reuse of old building materials containing lead?

    4. Does the RRP Rule apply to renovation performed in unoccupied home that will be put up for sale?

    5. Does the RRP Rule apply to office buildings, stores, and other commercial buildings?

    6. Does the RRP Rule apply to federal employees performing work on federal facilities?

    7. Does the RRP Rule apply to renovations that disturb ceramic tile?

    8. Does the work of window repair by replacing old sash with new sash is subject to RRP rule?

    9. Must I comply with the RRP rule when removing the aluminum siding?

    10. Does the RRP rule apply to simple painting activities that occur when rental properties turn over?

    11. Does the RRP Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?

  • Definition of "Renovation"

    1. What is a renovation?

    2. What is a “whole house gut rehabilitation project” for RRP purposes ?

    3. What RRP requirements apply to a comprehensive renovation project?

    4. Are Department of Energy weatherization projects covered under the RRP Rule?

    5. Is the painting activity always considered a “renovation”?

    6. Does the RRP Rule apply where no paint at all is present, such as in a 100-year-old unfinished basement?

    7. Must I comply with the new regulations if I am painting a wall with multiple coats of latex paint?

    8. Does the RRP Rule apply to demolishing and disposing of: • An entire pre-1978 home or building? • An entire, non-attached free-standing structure on the same property such as a garage, shed, or gazebo? • An attached but segregated section of pre-1978 home or building such as a sunroom, addition, two-story porch, or garage attached by a breezeway?

    9. Can you list specific activities deemed a disturbance of painted surfaces?

    10. Does the RRP Rule apply when removing a siding installed after 1978 on old lead based paint?

    11. Does the RRP Rule apply to the removal of old furnace whose surface area exceeds six square feet?

    12. If a homeowner removes all the painted surfaces in a room and then hires a certified firm to remodel the room, does the renovator need to follow the RRP Rule?

    13. My firm replaces garage doors. We unbolt the door from its hardware and remove it without penetrating, scraping, or removing paint. Is this work subject to the RRP Rule?

    14. Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been painted?

    15. Does the RRP Rule apply if we do hammer the unpainted side of the lumber under roof?

    16. Does the RRP Rule apply to removing a roof that is not painted?

    17. My firm installs replacement doors, Is this work subject to the RRP Rule?

    18. Is the work of replacing milfinish windows by removing sash subject to RRP rule?

  • Minor Repair and Maintenance

    1. Does the RRP rule apply to less than 6 Sq. Ft. repair in several rooms?

    2. If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?

    3. My firm installs carpets, How do I know when I need to comply with the RRP rule?

    4. Does the standard for surfaces apply to the whole building when insulating a multi-family building?

    5. What does the minor maintenance exception mean?

    6. Does the RRP rule apply if a person working in different room from project needs to drill a hole?

    7. If a renovator removes less than six square feet of crown molding, is that considered demolition?

    8. If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?

    9. My company installs new or replacement seamless gutters, is this work covered by RRP rule?

    10. Is replacing a pane of glass or fixing a broken window balancer a renovation covered by the RRP Rule?

    11. Does drilling holes in window frames qualify as minor repair and maintenance?

    12. How do I calculate the affected area for purposes of the minor repair and maintenance provision?

    13. How do I determine whether the job qualifies as a minor repair when removing old wood door?

    14. Does the RRP Rule apply to removal of garage doors made up of multiple panels?

    15. How the Agency will interpret the term “minor repair and maintenance activities?

  • Renovations for Compensation

    1. Is work done by friends, a brother-in-law, or volunteers covered by the RRP Rule if no one is compensated?

    2. Is the organizations doing roof repair and interior work covered by RRP Rule?

    3. Does the RRP rule also applies to the non-profit groups?

    4. If a renovator is only reimbursed for materials, would that be considered compensation?

    5. Does the rule apply if landlord supplies the materials, and the tenant does the labour for free?

    6. Are the rebuilding and recovery efforts organized by a committee subject to the RRP Rule?

    7. If I purchase and renovate pre-1978 properties, Is this type of work covered by RRP rule?

  • Target Housing

    1. How does a firm or renovator document or confirm the age of the structure?

    2. What does the term "target housing" mean?

    3. How RRP rule apply to housing for the elderly?

    4. Does the rule apply to a unit of student housing made up of two bedrooms ,a living room and kitchen?

    5. Can I work on homes built after 1978 without RRP certification?

    6. Does the RRP rule apply when one-room units are converted to two room suits in pre-1978 hotels?

    7. What is "housing for persons with disabilities"?

    8. What is a studio apartment?

    9. If a home was built in 1950, but in an addition it was built in 1980, does the RRP rule apply?

    10. Are renovations in short-term lodgings covered by the RRP Rule?

    11. Does the RRP Rule apply to renovations in mobile homes?

    12. Are renovations performed on detached outbuildings on the property subject to the RRP Rule?

    13. Does RRP rule apply to a post-1978 building detached from, but a part of, an pre-1978 apartment?

    14. Are prison facilities and juvenile detention centers built before 1978 considered target housing?

    15. Does zoning affect the target housing determination?

    16. Would RRP apply to renovations in a pre-1978 house that is partially used for commercial purposes?

    17. Are sleeping areas in building built before 1978 considered target housing?

    18. How do the RRP apply to a building containing both target housing and zero-bedroom dwellings?

  • Child-Occupied Facilities

    1. Is a health care facility or hospital covered under the RRP Rule if it meets the definition of a childoccupied facility?

    2. If a building contains a child-occupied facility, must all renovations in the building follow the RRP Rule?

    3. Does the RRP Rule apply to office buildings, stores, and other commercial buildings?

    4. What is the definition of a child under six years of age?

    5. How long does such a building remain a child-occupied facility if child visits were an rare event?

    6. What is a child-occupied facility?

  • Testing Painted Components

    1. Is a inspection including written determination sufficient to determine compliance with RRP rule?

    2. Do we need to comply with the RRP Rule when lead dust results are positive?

    3. Must I test every component affected by the renovation for the presence of lead?

    4. Can the renovation firm rely on determination of a certified inspector or risk assessor?

    5. Does any testing need to be done again if work is done on the property several years later?

    6. What components must test negative in order to qualify for the exclusion in 40 CFR 745.82(a)(2)?

  • Emergency Renovations

    1. How do the record keeping requirements apply to an emergency renovation?

    2. What is an “emergency renovation” for purposes of the RRP Rule?

    3. How do I know if a child has an EBL prior to my work if they haven’t had their blood lead tested recently?

    4. Does the RRP rule apply to contractors working on homes damaged by any natural disaster?

    5. Do the companies doing emergency renovation work need to be certified and comply with RRP rule?

  • Opt-Out Provision

    1. What was the “opt-out” provision and when was it revoked?

• Pre-Renovation Education

  1. Is an electronic version of the information pamphlet sent to the customer via e-mail acceptable?

  2. What are the pre-renovation education requirements for a vacant apartment?

  3. Should a firm provide pre-renovation education to all tenants before performing renovation?

  4. Who will provide the pre-renovation education when multiple contractors are involved in renovation?

  5. When renovating a common area in an apartment building, must my firm provide pre-renovation education to all tenants?

  6. How can a firm comply with the pre-renovation education requirements if the owner desires that the renovation begin immediately?

  7. How to comply with the pre-renovation requirements when working in area occupied by blind people?

  8. Do we need to comply with the pre-renovation education requirements for doing renovation in school?

  9. Should I comply with pre-renovation education requirements for minor repair and maintainance?

  10. Must I provide separate notice to the tenants when doing renovations to common areas?

  11. Must notifications for common area renovations always be provided to every unit in a multifamily housing complex?

  12. Is delivery of pamphlet to the property manager sufficient for purposes of delivery to the owner?

  13. May I use the pamphlet “Protect Your Family from Lead in Your Home” to meet my obligations?

  14. If a renovation is to be performed on a private balcony of a single unit in a multi-unit target housing building, does that activity trigger the common area notification requirements?

  15. Can notices for multi-family housing common area be delivered to the mailboxes of dwelling units?

  16. If a firm completely blocks access to a common area for the duration of a renovation, does the renovator still have to provide notifications to all tenants?

  17. Does a renovator need to attempt personal delivery before utilizing the “self-certification option?

  18. Who are the “owners” in a typical co-operative apartment building ?

  19. If I am sending pamphlet via mail, does the tenant’s name need to be addressed on the mailing?

  20. What is the difference between a certificate of mailing and certified mail?

  21. What pre-renovation education requirements would apply for a mix of studio apartments?

  22. Is the work of replacing windows in a condominium considered work in a common area?

  23. What does EPA consider an “adult” for these pre-renovation education purposes?

• Work Practice Standards

  • Occupant Protection

    1. Does the rule to close and seal doors and windows within 20 feet apply in a high-rise building?

    2. Is the work of replacing windows in a condominium considered work in a common area?

  • Containing the Work Area

    1. What is the “work area?”

    2. Is the plant, however large, need to be covered during exterior containment?

    3. What to do if it begins to rain during work and what do we do with the water on plastic?

    4. What mil plastic is considered impermeable?

    5. Do I need to cover a closet door with plastic?

    6. What are the requirements for covering doorways used to access the work area?

    7. Does the door need to be covered if it is outside the work area but used by workers?

    8. Is both interior and exterior containment required for an exterior window removal?

    9. When must scaffolding and vertical shrouding be used on an exterior renovation?

    10. If I paint without disturbing the surface of the existing paint, can I use a tarp instead of six mil plastic?

    11. Can’t I just clean the floor at the end of the job?

    12. How can I use plastic sheeting in exterior renovations without creating a safety hazard?

    13. Can landscaping fabric or a similar material be used during exterior power washing?

    14. Must the plastic be "sealed" to the floor on all edges or just "secured or held" to the floor?

    15. Does the RRP rule require people working on a renovation to wear personal protective equipments?

    16. When replacing window in a 90-year old home, should I install plastic on the roof under the windows?

    17. Does only damaged area need to be contained when fixing the lumber under roof?

    18. Can my firm fold up the plastic sheeting used for containment at night and re-use it the next day?

    19. When I replace windows, I set up interior vertical containment barriers that extend from floor to ceiling and completely enclose the interior area in which I physically work. If these barriers are set up at a distance less than six feet from the perimeter of the work surface, must I still extend the containment on the floor beyond the vertical barrier to meet the six-foot requirement?

    20. What if any additional liabilities exist if a owner independently removes the protective barriers?

    21. My firm removes and replaces windows from the exterior of a building or residence. To contain dust in the work area, we cover the entire interior surface of the window with impermeable plastic sheeting and affix the sheeting to the surrounding interior wall. This creates a pocket, accessible only from the exterior, from which the window is removed and replaced. All removal and replacement work is performed from the exterior, and we still apply the exterior containment measures as provided in the Rule. Does the interior containment method described meet the requirements under the Rule?

    22. Can I reuse the plastic sheeting on the same day after I mist and HEPA vacuum the plastic sheeting?

    23. My firm replaces windows. Various obstacles make it difficult to set up the ten-foot exterior ground containment in a way that would enable our renovators to perform the work and still effectively contain dust. In these cases, we lay the ground containment, but also use vertical containment measures to completely enclose the area in which we work. Is this a permissible method of exterior containment? If the vertical containment is set up at a distance of less than ten feet from the work surface, must we still extend the ground containment beyond the vertical barrier to meet the ten-foot requirement?

    24. Is the plant, however large, need to be covered during exterior containment?

    25. At what point is the wind too strong to allow work to continue?

  • Restricted Practices

    1. How do RRP requirements apply to pressure washing? What preparations are required?

    2. Is drilling holes in sheet rock to dry it out a prohibited practice?

  • Renovation Waste

    1. Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed?

    2. What type of container is adequate for on-site storage of debris? Where it should be placed?

    3. Can non-certified workers transport debris off site under the RRP Rule?

    4. How should lead-containing wastes from RRP renovations be handled and disposed?

    5. Under the RRP Rule, how should I dispose of contaminated water used in two-bucket mopping?

    6. Why are gloves, which are exposed to large amounts of lead dust, not required to be disposed?

  • Work Area Cleaning

    1. What should I look for when purchasing a HEPA vacuum?

    2. Under the RRP Rule,do paint chips and debris need to be removed from protective sheeting?

    3. Can uncertified workers do the balance of the project after successful cleaning verification?

    4. How should the waste removed from the work area be stored?

    5. Are components removed from the home to be cleaned up subject to the waste handling requirements?

    6. Who is responsible for controlling dust once the truck used to transport the waste leaves the site?

    7. For cleaning the work area, is the interior floor of a garage considered interior or exterior?

    8. How should I proceed to replace the window in pre-1978 home containing lead based paint?

  • Cleaning Verification

    1. Under the RRP Rule, is composite sampling acceptable for clearance in lieu of cleaning verification?

• Record & Reports

  1. Can the certified firm maintain all required records?

  2. What records must a subcontractor keep?

  3. What are new record keeping requirements and when must my firm comply with them?

  4. Who maintains records if one or more contractors are involved in a single project?

  5. Can the required records and documentation be stored electronically rather than as paper copies?

  6. Can the certified renovator comply with the rules by keeping records electronically at job site?

• Firm Certification

  1. Does my firm need to be a certified if we subcontract the entire renovation job to other companies?

  2. Does my firm need a certified renovator at site if we subcontract the entire job to other companies?

  3. Do I need to get firm and renovator certification to work on pre-1978 apartments?

  4. Does the property management company needs firm certification?

  5. How will the RRP rule affect the work of non-profit groups?

  6. DOE provides weatherization grants to states, which in turn provide grants to non-profit sub-grantees. These sub-grantees fall into one of three categories: 1. The sub-grantee uses its own employees to perform all the weatherization services in the home, 2. The sub-grantee uses a combination of its own employees and contractors to perform weatherization services, or 3. The sub-grantee has no employees that perform weatherization services; instead, every service is performed by a hired contractor. Must these sub-grantees be RRP-certified firms?

  7. What do you need to do to become a certified firm?

  8. If my firm already has abatement certification, is separate RRP certification necessary?

  9. Is it sufficient to get certified as a renovator if I have no employees in my firm?

  10. Can a certified renovator supervise workers of different company?

  11. Are state and local government employees who often do renovation work required to be certified?

  12. Does the subcontractor needs to be a certified firm if he does not disturb any paint?

  13. What changes in a renovation firm's status require an amendment of certification and how much will it cost?

  14. If a property owner and a property management company have entered in to a consent agreement related to Section 1018 (lead hazard disclosure) that does not admit an actual violation, is the property management company required to acknowledge a lead-based paint violation when completing the application for firm certification?

  15. At what point, can non-certified firms perform electrical, plumbing, HVAC, or drywall work?

  16. Does the RRP Rule require a certified state lead inspector or risk assessor, who does not do renovation work, to become a certified renovation firm in order to take dust wipe samples?

  17. Is the fee for firm certification waived for self- employed individuals or landlords?

  18. Can contractors submit their application to EPA before they complete the required training, or must the application be submitted after the training is complete? Is there a proof of training required by the EPA in order for the contractor's application to be approved?

  19. Must maintenance workers at kindergartens and elementary schools become certified renovators if they perform renovations covered by the RRP 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?

  20. If a firm does business in several states, must they become certified in all states in which they manage a target property or is this requirement satisfied by certifying the firm in the state in which they are headquartered?

  21. My non-profit organization receives grants to arrange for renovations in older housing, such as weatherization projects or general modernization. Typically, these grants come with eligibility conditions for properties and/or property owners and tenants, but specific properties or projects are not identified. My organization is responsible for locating eligible properties and recipients and hiring firms to perform the eligible renovations. Must my non-profit organization become an RRP-certified firm?

  22. My non-profit organization applies for and receives grants to renovate older homes. We do not perform the renovations ourselves, we hire renovation contractors to perform them on our behalf. We identify the properties to be renovated and the specific projects in the grant application. If we are successful in obtaining the grant, the funding would obligate us to arrange for the renovation of the specific properties named in the grant application. Must my non-profit organization become an RRP-certified firm?

  23. Do we need to be a certified firm to work in a church with daycare and preschool programs?

  24. How long will it take EPA to process my application to be a lead-safe certified firm?

  25. If a company has several legal entities, does each entity have to become a certified firm?

  26. My company has two stores in different states. Must each store be a separate certified firm?

  27. I am the owner of my renovation firm, but I am not a certified renovator. May I be the "attesting individual" named on the RRP firm certification application?

  28. My firm performs renovations covered by the RRP rule, but solely in the capacity of a subcontractor. If the general contractor is a certified firm, does my firm also have to be certified, or can we just provide the certified renovator?

  29. What is the difference between Abatement Certification and Renovation (RRP) Certification?

• Certified Firm Logo

  1. How do I get my Lead-Safe Certified Firm Logo?

  2. How and where can I use the Lead-Safe Certified Firm Logo?

  3. Can I get the Lead-Safe Certified Firm Logo file in different resolution or in black and white?

  4. I can't open the Lead-Safe Certified Firm Logo file I have been sent. What format is it in?

  5. Can I receive an .eps, .ai, .ait or modifiable format of the Lead-Safe Certified Firm Logo?

  6. Can I change the colors of the Lead-Safe Certified Firm Logo to match my company's current materials?

  7. Are trainers authorized to use the EPA Lead-Safe Certified Logo?

  8. Can principal instructors independently advertise, provide training and use EPA Certified logo?

• Renovator Certification

  1. Are state and local government employees who often do renovation work required to be certified?

  2. What training requirements apply to non-certified workers who have previous training experience?

  3. Must a certified lead abatement professional also become trained and certified to do renovation?

  4. How can I find an accredited renovation trainer?

  5. Does there need to be documentation of training provided on-the-job at the work site?

  6. Is the renovator hired by general contractor responsible for the work practices of other contractor?

  7. What if homeowner act as general contractor and hire different companies to perform different work?

  8. Can renovator training courses, both initial and refresher courses, be taught online or via distance learning?

  9. Is it necessary for schools to be certified renovation firms and workers be certified renovators?

  10. Must each contractual worker be a certified renovator, or can the workers be trained on the job?

  11. What do I need to do to comply with EPA's lead RRP rule?

  12. I am a firm and there are no training providers offering classes near me. What do I do?

  13. May I as a training provider issue a certificate without a picture to a trainee?

  14. How long will my new certification last after taking refresher training course?

• RRP Tribal Programs

  1. What do I need to do to work for an EPA certified firm after completing renovator training?

  2. Does the certification from authorized state allow firms to work in EPA administered jurisdictions?

  3. Is my EPA renovator certification accepted in all states and tribal areas?

  4. My state will adopt its own RRP program. Do I have to also be certified by EPA?

• Training Provider Accreditation

  1. Do all renovation course instructors need to be approved as principal instructors?

  2. Can the exam be read to students in their native language if they don't understand English?

  3. May renovator training providers provide reasonable accommodations to people with disabilities?

  4. May the renovator training provider give the exam orally?

  5. Is it permissible for a training provider to employ more than one training manager?

  6. Can the final course assessment be administered in an “open book” format?

  7. What is the validity of new certification if renovator takes the refresher course early?

• Enforcement and Inspections

  1. Who would be liable for the fine if government hired an uncertified contractor?

  2. Which entity is subjected to enforcement action if a certified firm violates the RRP rule?

  3. Does EPA’s announcement of June 18, 2010 modify the RRP Rule’s requirements?

  4. What does the June 18, 2010, announcement mean?

  5. Will EPA enforce against renovators who did not receive their certification before December 31,2010?

  6. How does the June 18, 2010 announcement impact renovators in states that have adopted their own RRP programs?

• DIY Information

  1. How can homeowners protect themselves and their families from exposure to lead dust if they plan on doing their own renovations?