40 CFR 745 Subpart E: EPA Lead RRP Rule

Regulatory citation: Toxic Substances Control Act; 40 CFR Part 745, Subpart E, Residential Property Renovation

What Is EPA's Lead Renovation, Repair and Painting Rule?

The Lead Renovation, Repair and Painting (RRP) rule requires contractors who disturb painted surfaces in pre-1978 homes and child-occupied facilities, such as child care centers and schools, to be certified and to follow lead-safe work practices. It applies to renovators, painters, electricians, plumbers, property managers and others who do this work for compensation.

Why the RRP Rule Matters

Renovation activities like sanding, cutting and demolition can create hazardous lead dust. Even small amounts can harm children and pregnant women, causing lasting damage to the brain and nervous system.

Core Requirements

1. Firm Certification

Firms performing covered work must be certified by EPA, or by a state, tribe or territory authorized to run its own RRP program.

2. Certified Renovators

Each job must be directed by a certified renovator who has completed accredited training. The certified renovator is responsible for the lead-safe work practices and for training other workers on the job.

3. Pre-Renovation Education

Before work begins, firms must give owners and occupants EPA's Renovate Right pamphlet, no more than 60 days before starting, and keep a record that it was provided.

4. Lead-Safe Work Practices

Firms must contain the work area, minimize dust and clean thoroughly afterward. Certain practices are prohibited, including open-flame burning, using power tools without HEPA exhaust control and using heat guns at 1,100°F or higher.

5. Cleaning Verification

After cleaning, the certified renovator must verify the work area is clean using the cleaning verification procedure or, where required, dust clearance testing.

6. Recordkeeping

Firms must keep records showing compliance, such as pamphlet acknowledgments and work practice checklists, for three years after completing the renovation.

Common Compliance Approaches

Check the Build Year First

Confirm whether a home or facility was built before 1978 during quoting, and assume lead paint is present unless testing shows otherwise.

Use Job Checklists

A standard RRP checklist helps crews follow containment, cleaning and verification steps consistently.

Know the Minor Repair Exemption

Small jobs disturbing less than 6 square feet per room inside, or 20 square feet outside, are exempt from most work practice requirements, unless they involve window replacement, demolition or prohibited practices.

Example: Lead RRP in Practice

A contractor is hired to replace kitchen cabinets and repaint walls in a 1965 house where a toddler lives. The EPA-certified firm gives the family the Renovate Right pamphlet, then a certified renovator sets up plastic sheeting and a sealed entry, uses a HEPA-equipped sander, and bags debris daily. After a HEPA vacuum and wet cleaning, the renovator completes cleaning verification before the family returns to the kitchen.

Related regulations: EPA Asbestos NESHAP, EPA Hazardous Waste Generators, OSHA Respiratory Protection.

Note: This summary reflects federal EPA requirements. Many states run authorized programs with additional or stricter rules. Always check the current regulation text and your state environmental agency's requirements.

Frequently Asked Questions

Does the RRP rule apply to my project?

The RRP rule applies to paid renovation, repair or painting work that disturbs painted surfaces in housing built before 1978 or child-occupied facilities, unless the area has been tested and found free of lead-based paint or the minor repair exemption applies.

Do homeowners need to be RRP certified?

No. Homeowners working on their own owner-occupied homes are not covered by the RRP rule, but EPA recommends they follow lead-safe practices. Landlords and property managers who do the work themselves in rental housing are covered.

How long do RRP records need to be kept?

Firms must keep records demonstrating compliance with the RRP rule for three years after the renovation is completed.