Lead Renovation, Repair and Painting (RRP) Rule
In 2008 EPA issued a rule for home improvement contractors and maintenance professionals who renovate or repair pre-1978 housing, child care facilities or schools. The rule requires that by April 2010 contractors and maintenance professionals be certified, that their employees be trained, and that they follow protective lead-safe work practice standards.
Who is covered by the regulations?
The covered facilities include residential buildings (owner-occupied and rental), and child-occupied facilities such as day care centers and kindergartens. The rule applies to renovation, repair or painting activities. It does not apply to minor maintenance or repair activities affecting less than six square feet of lead-based paint in a room or less than 20 square feet of lead-based paint on the exterior. Window replacement is covered regardless; it is not considered minor maintenance or repair.
What is the purpose of the regulations?
Lead can affect almost every organ and system in your body. Children six years old and younger are most susceptible to the effects of lead. In children, the main target for lead toxicity is the nervous system. Even very low levels of lead in the blood of children can result in:
Permanent damage to the brain and nervous system, leading to behavior and learning problems, lower IQ, and hearing problems.
Lead can accumulate in our bodies over time, where it is stored in bones along with calcium. During pregnancy, lead is released from bones as maternal calcium is used to help form the bones of the fetus. This is particularly true if a woman does not have enough dietary calcium. Lead can also be circulated from the mother’s blood stream through the placenta to the fetus. Lead in a pregnant woman’s body can result in serious effects on the pregnancy and her developing fetus.
Many contractors think the issue of lead paint poisoning went away years ago, or that they are doing all that needs to be done to avoid it. But lead paint poisoning isn’t just about eating paint chips, and even contractors who think they are doing a good job may not be working in a lead-safe manner. Lead paint was used in more than 38 million homes prior to its ban for residential use in 1978. This paint can form toxic dust when it is disturbed during normal home repair work.
The purpose of the RRP rule is to minimize exposure from lead-based paint dust during renovation, repair, or painting activities. The RRP Rule is expected to reduce the prevalence of childhood lead poisoning, particularly lead poisoning caused by housing contaminated by renovation activities. The Rule will also minimize exposure to older children and adults who are also adversely impacted by lead-based paint dust exposure.
The RRP requires that all renovation, repair, and painting firms (including sole proprietorships) working in housing, or facilities where children are routinely present, built before 1978, to be certified. Individuals within these firms must also be certified ("Certified Renovator") and they must be assigned to each job, and must provide lead-safe work practices training to all non-certified renovation workers on a job site. To become a Certified Renovator, a person must complete a renovator training course accredited by EPA or an EPA-authorized program on lead-safe work practices and other regulatory requirements (locate a training program). Renovator training is also available via e-learning (see requirements). This option allows trainers to provide much of the course content online, making it more convenient for many renovators. EPA certification is good for five years.
EPA requires that renovators follow certain work practice and clean up requirements during regulated jobs including: setting up the job site safely, minimizing dust on the job, and cleaning up carefully and completely.
Effective September 15, 2015 EPA will no longer offer the option to submit firm certification applications by mail. After that date all firm applications, payments, updates and certificate replacement requests will be done online. This change is part of an Agency effort to decrease cost and increase efficiency. The option to submit firm applications online has been available for some time; currently 85% of applications are submitted in this manner. Acceptable methods for payments online include credit card, debit card, or electronic check.
Renovator Training Re-Certification and Expiration Extension
Firms and individuals must be re-certified every five years. However, for individuals, EPA has extended the training expiration date for many certified renovators. This was done so if the proposed changes of January 2015 are finalized, many more renovators will be able to take advantage of those changes. Affected expiration dates are based on when the previous course was taken (see table below). Please be aware that the extensions only apply to individual renovators who must get re-certification training within the time-frames explained in the rule. The extensions do not apply to firm certifications. To continue lead renovation work, firms must be re-certified when their current certification ends. Also, the extensions do not apply to renovators in the 14 states that administer their own program (see state programs).
Renovator Training Expiration Information
|Date course completed
|On or before March 31, 2010
||March 31, 2016
|From April 1, 2010 - March 31, 2011
||6 years from the date of course completion
|On or after April 1, 2011
||No extension provided - Expiration is 5 years from the date of course completion
Current Regulatory Activity
After the 2008 RRP Rule was published, EPA was sued for failing to address potential hazards created by the renovation of public and commercial buildings. In the settlement agreement and subsequent amendments, EPA agreed to either determine that renovations of public and commercial buildings do not create hazards or to propose work practice and other requirements by July 1, 2015. For more information, see: LRRP Public & Commercial Buildings.
EPA's main RRP page. Provides links to proposed and final rule, compliance assistance documents and other resources.
Locate Accredited Renovation Training Programs. This locator identifies lead renovation, repair and painting (RRP) trainers accredited by EPA. EPA runs the lead RRP program in most states. Please note that fourteen states are authorized by EPA to administer their own RRP programs:
Small Entity Compliance Guide to Renovate Right: EPA's Lead-based Paint Renovation, Repair and Painting Program. This document provides information on how to become certified, responsibilities of certified contractors, recordkeeping requirements, and other important aspects of the rule.
EPA Answers to RRP FAQ. EPA lists FAQs on this page. If you have other questions about the Lead Renovation, Repair, and Painting (RRP) Rule and can not find your answers here, call the National Lead Information Center at 1-800-424-LEAD (5323).
Lead Paint Abatement State Resource Locator. The purpose of this on-line tool is to provide quick access to:
state rules relating to lead/construction issues,
state or federal programs that provide training and certification,
resources that can help achieve compliance.