Renovations Covered by the RRP Rule

• General Renovation

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

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

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

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

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

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

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

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

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

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

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

• Definition of "Renovation"

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

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

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

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

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

  6. 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?

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

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

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

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

  11. 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?

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

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

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

  15. 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?

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

  17. What is a renovation?

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

• Minor Repair and Maintenance

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

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

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

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

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

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

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

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

  9. 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?

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

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

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

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

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

  15. What does the minor maintenance exception mean?

• Renovations for Compensation

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

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

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

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

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

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

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

• Target Housing

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

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

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

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

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

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

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

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

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

  10. Does zoning affect the target housing determination?

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

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

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

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

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

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

  17. What is a studio apartment?

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

• Child-Occupied Facilities

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

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

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

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

  5. What is a child-occupied facility?

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

• Testing Painted Components

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

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

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

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

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

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

• Emergency Renovations

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

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

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

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

• Opt-Out Provision

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