The Renovation, Repair, and Painting Rule
The EPA’s lead-related Renovation, Repair and Painting (RRP) Rule became fully effective on April 22, 2010, causing a tectonic shift in the remodeling industry. The law affects remodelers, window installers, painters, HVAC specialists, and contractors, as well as plumbers and electricians, and is backed by fines totaling up to $37,500 per violation, per day.
RRP's primary objective is to contain the lead paint dust that almost any job performed in an older home can generate, and with good reason: Lead dust is toxic to humans and can lead to brain damage in children. The law directs contractors to keep a lid on dust by applying three seemingly simple steps: sealing off the work area, minimizing dust while working, and cleaning up thoroughly.
Use this guide to help navigate the rule while protecting your workers, customers, and yourself from the dangers of lead, and your business from the liability of failing to follow the letter of the law.
By the Numbers
Lead paint Was used in an estimated 38 million homes in the United States prior to 1978.
Why Remodelers and Contractors Should Care
Children are particularly susceptible to lead, which is considered poisonous to humans. Lead can affect children’s brains and nervous systems, causing reduced IQ, learning disabilities, and behavioral problems. Nearly 500,000 children in the United States had elevated blood lead levels in 2007, according to the Centers for Disease Control. (See Elevated Blood Levels chart.)
Lead is also harmful to adults, which means that workers in the building trades should take steps to protect themselves. Lead dust is the biggest problem because it's easily ingested on the job site, through breathing or eating. Exposure to lead dust can result in high blood pressure, reproductive problems in both men and women, nerve disorders, memory and concentration problems, and muscle and joint pain. Pregnant women who ingest lead can transfer it to their fetuses.
If none of the above is reason enough, consider this: Contractors who are found in violation of the RRP rule can be fined up to $37,500 per occurrence, per day—meaning multiple violations over multiple days can quickly add up to several workers’ annual salaries.
Elevated Blood Levels
While elevated blood lead levels in children have decreased in the last decade, more than 500,000 kids are still at risk today.
RRP FAQs
What is the rule?
Contractors and companies performing work on homes built before 1978 must be certified in lead-safe work practices, use those practices on the job site, and document compliance with the rule. If you live in Wisconsin, Iowa, North Carolina, Mississippi, Kansas, Rhode Island, Utah, Oregon, Massachusetts, or Alabama, check your state's specific training requirements, which may differ from EPA's.
Why should I care?
Lead dust, which is created when lead-based paints are disturbed, is poisonous and poses significant health risks to children, including long-term brain damage. In adults, exposure can lead to reproductive problems, highblood pressure and memory loss. If that's not enough, non-compliance can result in fines of up to $37,500 per violation, per day.
What are the basic steps to containment?
Recommended and required containment steps include sealing off the site prior to beginning work with plastic shrouds and the use of negative pressure. Workers should conduct demolition with care and avoiding hammering or tearing at existing materials, using HEPA filter-equipped vacuum attachments and shrouds on tools such as sanders and drills. After work is complete, workers must dispose of all site waste in properly sealed, heavy-duty plastic bags, cleaning the area thoroughly with both wet and dry mops, and comparing wipe cloths against EPA test cards to make sure the site is compliant. (See RRP on the Job: A Step-by-Step Guide below.)
How much will this cost?
Certain costs are fixed, such as the fees for EPA company certification ($300) and individual training ($200–$400 per person). Others are more fluid. The EPA estimates that costs will run between $8 to $167 for most jobs. Remodeling magazine estimates additional costs to be as much as 10 times higher, when you take into account increased overhead for training, legal and professional fees, insurance, and increased labor and material costs. The bottom line for the homeowner will mean a price that’s higher by 8 to 15 percent. (See Quick Cost Calculator below.)
How much longer will jobs take?
It depends on the job, but Remodeling estimates an additional 6.5 to 15.5 hours of labor for a gut remodel of a typical 6x8, circa-1920 lath, plaster, and tile bathroom.
Do you need more workers?
Not per se, but best practice calls for one worker to stand behind a shroud and pass sealed waste to a second standing outside of it. In those instances, a second person would be needed to comply to the rule.
Are unlicensed contractors at an advantage?
No. The rule applies to work done for compensation. Whether a remodeler is licensed or not does not excuse him or her from compliance with the rule.
RRP on the Job: A Step-by-Step Guide
1. In homes built before 1978, inform homeowners of lead hazards, supply EPA-approved “Renovate Right” brochure, and have them acknowledge in writing that they’ve received it.
2. Post signs stating lead hazards to homeowners and passers-by.
3. Recommended. Testing for lead is not required by the law. However, if you choose not to test for lead, you must assume that lead is present and observe all required job site practices. Test for lead by using an EPA-approved test kit. If the test does not indicate the presence of lead, you do not have to follow RRP procedures.
4. Create a barrier around the work area by applying plastic sheathing on walls, floor, and in doorways. Create a seal using tape.
5. Recommended. Set up a HEPA fan in a window to establish negative pressure.
6. RRP (not to mention OSHA) rules require workers to be protected from lead exposure. Remodelers can meet this requirement by having employees use a disposable respirator and wear coveralls, head cover, gloves, booties, and eye protection.
7. Any power tool being used should be equipped with a HEPA filter or shroud. Instead of hammering on something during demolition, pull it apart. Avoid the use of open flames or a heat gun at a temperature greater than 1100 °F.
8. During cleanup, place work site waste in heavy-duty trash bags. Crimp the top of the bag closed with tape, fold the end over itself, and then tape again. Clean the outside of the bag with a wet wipe or HEPA vacuum—or put the bag inside a second trash bag that has been kept clean of lead dust. Whatever the method used, the contents of the bag must be sealed and the outside of the bag must be clean when it leaves the work environment.
9. Keep the separation between the work area and the rest of the house secure. For example, have the worker inside the sealed area pass the cleaned and taped trash bag to a second worker on the outside, who should place it in a covered bin for transport out of the home.
10. Upon completion of the work, take steps to meet what the EPA calls the “cleaning verification process.” This will involve cleaning visible dust and debris; testing walls and floors with a cloth sweeper until it comes up lighter than the EPAapproved sample card; and proper disposal of plastic sheets and other protective equipment.
The RRP Rule Timeline
Part of the complexity involved with breaking down the RRP Rule comes from the fact that it’s been in development for nearly two decades. This timeline tracks the RRP’s history and major milestones along the way to becoming law:
1992 - Congress passes the Residential Lead Based Paint Hazard Reduction Act, mandating the EPA to study the hazards created by lead dust during renovations, and to draft subsequent rules.
1996 - While missing the congressional deadline, EPA's research shows significant amounts of lead dust are generated during renovation and remodeling jobs. At the behest of environmental and housing advocates, the agency promises forthcoming regulation.
2005 - After languishing for the better part of a decade, the issue gains new life amid lawsuits from advocacy groups. Sen. Barack Obama of Illinois emerges as a leading proponent of reducing lead-related health risks for children. The EPA issues a proposed rule in December.
April 22, 2008 - EPA issues its final Renovation, Repair and Painting Rule. The rule requires contractors to become certified in lead-safe work practices, and to implement those practices on the job site while documenting that they’ve done so. An “opt-out” provision is included for homeowners who sign a waiver stating no children younger than 6 or pregnant women are present in the home.
2009 - The Sierra Club and other environmental groups successfully sue the EPA to remove the opt-out provision of the law, meaning that it applies to nearly all homes built before 1978, with a few specific exceptions.
April 22, 2010 - The EPA’s Renovation, Repair and Painting (RRP) Rule takes full effect on Earth Day. Contractors are now required to be certified in lead-safe work practices, and use those practices on the job site.
Oct. 1 and Dec. 31, 2010 - Due to a shortage of EPA-certified trainers, remodeling firms and individual remodelers get an extension to become RRP certified, at least for a few months. The deadline is stretched to Oct. 1, 2010, for remodeling firms, and Dec. 31, 2010, for individual remodelers.
Jan. 1, 2011 - Contractors and companies conducting work on more than 6 square feet of the interior or 20 square feet of the exterior, at a home built before 1978, must be RRP-certified, must use lead-safe practices, and must document their compliance. The EPA quotes fines up to $37,500 per violation, per day, for those who don’t. However, enforcement of the rules has not yet begun.
Work Checklist
EPA RRP Tools and Supplies List:
Barriers, signs, and EPA “Renovate Right” RRP brochures (to give to residents)Masking tape, duct tape, and/or painters tape
Stapler/staples
Spray adhesive
Heavy plastic sheeting
Wood dowels
Heavy plastic trash bags
Utility knife or scissors
Wet/dry sandpaper, sanding sponge
Misting bottle, pump sprayer (to moisten areas before scraping or sanding)
Shaving cream (apply to an area before drilling to catch dust as it emerges)
Cat litter (to soak up and contain contaminated spills)
Tack pads
Chemical stripper
Power tools with HEPA filter-equipped vacuum attachments/shrouds
Low-temperature heat gun
Heavy-duty plastic bags
HEPA vacuum cleaner, beater bar and filters
Paper towels
Disposable wipes (white)
Dry electrostatic cloths/wipes
Cleaning Verifications Card (CVC)
Mop and disposable mop heads
General-purpose cleaner
Mop buckets
Cleaning buckets
Shovel and rake
Flashlights
Required signage (in language[s] of residents)
Barrier/caution tape
Orange cones
Approved test kits
Filtration system for cleaning toxic water before disposal
Pump and hose to drain filtered water into house sewer system for disposal
Forms and checklists
Personal Protective Equipment
Eye wear
Painters’ hats
Cloth gloves
Coveralls
Latex gloves or alternative, such as nitrile
Disposable shoe covers or “booties”
N-100-rated disposable respirator
Additional Resources
EPA RRP Page for Contractors"Renovate Right" brochure to provide to homeowners
EPA's fact sheet on the new rules
EPA's sample work site documentation checklist
ShawnMcCadden.com. general RRP information, RRP supplies list, RRPedia Page
National Center for Healthy Housing Web site’s RRP Section
Remodeling's RRP Overview Page
This article was prepared by the editors of Replacement Contractor magazine in conjunction with consultant and RRP Certified Renovator, Shawn McCadden.
