What is the EPA’s RRP Rule?

Do you have plans to renovate your historic home? If your house was built before 1978 then your house falls under the EPA’s RRP rule. What on earth is the RRP rule and how does it affect you? That’s what we’ll talk about here.

As the owner of a historic window restoration company I’ve dealt with this rule every day since it was created in April of 2008. Its history goes back to the Residential Lead Based Paint Hazard Reduction Act of 1992 when Congress set out to study the health effects of lead paint exposure from renovations.

16 years later they had accumulated enough information to create a new rule called the Renovate, Repair, Painting (RRP) rule that would prescribe how contractors would be required to work in homes built before 1978.

The Scope of the RRP Rule

The EPA’s RRP rule is applicable to residential properties, child care facilities, and schools built before 1978. Why 1978? Though it was already declining in use, lead paint was banned from use in residential buildings in 1978, so buildings built after that date can safely be assumed to be free of lead paint.

The older your home the more likely it is to contain lead-based paint. For example, if your home was built before 1940 you have a 87% chance of finding lead paint. The rule mandates that any renovation, repair, or painting project that disturbs lead-based paint in these structures must follow lead-safe work practices (and extensive documentation) to prevent lead contamination.

Key Requirements for Homeowners and Contractors

Under the EPA’s RRP rule there is no requirement for homeowners who plan to work on their own homes. The requirement only kicks in when you, as the homeowner, are planning to contract out the renovation of your home to a contractor. Basically, if you plan to pay someone to do work on your house they must be RRP certified.

1. Certification and Training:
Contractors working on properties covered by the RRP rule must be certified by the EPA. This involves completing an EPA-approved training course, usually a one day 8-10 hr course, that educates workers on lead-safe work practices.

Homeowners hiring contractors should ensure they are dealing with certified professionals by asking for their certification credentials. You can also check if your contractor is a Certified Renovator using the EPA’s RRP searchable database here.

2. Lead Safe Work Practices:
I’ve written extensively on different lead safe work practices on this blog that you can read more about here. Some basics of the lead-safe practices include:

• Containing the work area to prevent dust and debris from spreading.
• Minimizing dust generation by using methods such as wet sanding and using tools attached to HEPA vacuums.
• Thoroughly cleaning the work area after completion to remove any residual lead particles.

3. Pre-Renovation Education:
Before beginning work, contractors are required to provide homeowners with the EPA’s “Renovate Right” pamphlet. This document educates homeowners about the risks of lead exposure and the steps being taken to mitigate those risks.

4. Documentation:
Contractors must keep detailed records of their compliance with the RRP rule for three years. This includes documentation of training, work practices, and the distribution of the “Renovate Right” pamphlet. This adds to the cost of renovations, but is required for all contractors.

When the RRP Rule Applies

The RRP rule applies under the following conditions:

• When more than 6 square feet of lead paint is disturbed in an interior space or 20 square feet on an exterior.
• During any window replacement or demolition work, which are high-risk activities for lead exposure.

Exemptions from the RRP Rule

Not all projects are subject to the RRP rule. Key exemptions include:

• Homes where lead-based paint has been tested and certified as absent (keep the documentation).
• Renovations in areas that do not disturb lead-based paint.
• Minor repairs and maintenance that disturb less than 6 square feet of interior paint or 20 square feet of exterior paint, provided no window replacement or demolition occurs.

How do you know if you have lead paint? At the time of this writing there is only 1 type of approved home lead test kit by the EPA. If you test using this kit and retain documentation of a negative test then you can be exempt from the requirements required by the RRP rule.

The Importance of Compliance

Lead poisoning is a severe health risk, particularly for young children and pregnant women. Exposure to lead dust can cause developmental issues, learning disabilities, and other serious health problems. By following the EPA’s RRP rule, homeowners and contractors play a crucial role in preventing lead contamination and safeguarding the health of occupants.

There are also fines for non-compliance with the EPA’s RRP rule outlined below that can seriously damage a small firm found guilty of these infractions.

• Negligent Violations: 1 year and/or $2,500 – 25,000 per day;
  • Subsequent convictions 2 years and/or $50,000 per day.
• Knowing Violations: 3 years and/or $5,000 – 50,000 per day;
  • Subsequent convictions 6 years and/or $100,000 per day.

Final Thoughts

While I’m not a fan of the regulatory and documentation burdens of the EPA’s RRP rule which cause an undue burden on small renovation firms I am a huge supporter of the lead-safe work practices that are required.

These practices have resulted in safer job sites, cleaner homes, and more awareness of the dangers of lead paint. In addition, people are better educated on how to keep themselves and their families safe.

Lead paint doesn’t have to be something you are scared of. If you or your contractor follow the lead-safe work practices it is a very manageable risk that can be overcome with little to no health consequences.

The issues show up when you mistakenly hire a renovator or restorer who does not follow lead-safe work practices or isn’t certified by the EPA. You may save a little money, but sacrificing your health for a few bucks in savings isn’t worth it.

The real question is: “Will you choose to be lead safe?”