What Is the EPA RRP Rule?
The Lead Renovation, Repair and Painting (RRP) Rule is a federal regulation administered by the U.S. Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA). It became enforceable in April 2010 and applies to renovation, repair, and painting work in housing and child-occupied facilities built before 1978 that may disturb lead-based paint.
The rule was created in response to evidence that renovation activities — even routine ones like sanding, cutting, or replacing windows — can generate significant amounts of lead dust, posing serious health risks, particularly to young children.
Who Does the RRP Rule Apply To?
The rule applies to:
- Renovation contractors: Any firm paid to perform renovation, repair, or painting work in covered buildings must be EPA-certified and follow RRP work practices.
- Landlords: Landlords who perform their own renovation work in pre-1978 rental properties are subject to the rule.
- Property managers: Those who hire contractors for covered work must ensure the contractors are certified.
The rule does not apply to owner-occupants doing their own work in their own home (though safe work practices are strongly recommended), or to properties confirmed to be free of lead-based paint by a certified inspector.
What Buildings Are Covered?
The RRP Rule covers:
- Residential dwellings built before 1978
- Child-occupied facilities built before 1978 — defined as buildings where children under age six spend significant time (schools, daycare centers, etc.)
Commercial buildings, industrial facilities, and housing for the elderly or disabled (without children) are generally not covered, though other OSHA regulations may apply.
Key Requirements Under the RRP Rule
1. Firm Certification
Any company performing covered renovation work must be certified by the EPA (or an EPA-authorized state program). Certification must be renewed every five years. Firms apply through the EPA's online portal and pay the required fee.
2. Certified Renovator Training
At least one individual on each job site must be a Certified Renovator — someone who has completed an eight-hour accredited training course. Certified Renovators are responsible for directing compliance with RRP work practices on site.
3. Pre-Renovation Education
Before starting work, contractors must provide occupants (or owners, in the case of rental properties) with the EPA's Renovate Right pamphlet and obtain a signed acknowledgment. This requirement ensures occupants are informed of potential lead hazards before work begins.
4. Work Practice Standards
Certified Renovators must follow specific work practice requirements during the project:
- Contain the work area to prevent the spread of dust and debris
- Use plastic sheeting to cover floors and furniture within the work zone
- Close windows and doors in the work area
- Avoid prohibited practices such as open-flame burning, dry sanding, or using high-speed power tools without HEPA vacuum attachments
5. Post-Renovation Cleaning and Verification
After the work is complete, the Certified Renovator must perform a thorough cleanup using HEPA vacuums and wet wiping, followed by a visual inspection or cleaning verification test to confirm the area meets cleanliness standards before occupants return.
6. Recordkeeping
Firms must retain records of compliance for a minimum of three years. This includes signed pre-renovation disclosure forms, training certifications, and cleaning verification documentation.
Penalties for Non-Compliance
Violations of the RRP Rule can result in significant civil penalties. The EPA has the authority to assess fines per violation per day of non-compliance. State-run programs may impose additional penalties. Beyond financial risk, failure to comply exposes contractors and property owners to liability if occupants suffer harm from lead exposure.
State Programs
Many states have received EPA authorization to run their own RRP programs. In authorized states, contractors must be certified under the state program rather than directly through the EPA. State requirements may be more stringent than federal minimums. Check with your state environmental agency to confirm which rules apply in your jurisdiction.
A Compliance Checklist for Contractors
- Confirm your firm's EPA (or state) certification is current.
- Assign a Certified Renovator to every covered job site.
- Provide the Renovate Right pamphlet and obtain signed acknowledgment before work begins.
- Set up proper containment before disturbing any painted surfaces.
- Avoid all prohibited work practices.
- Conduct post-work cleaning and verification.
- Maintain all required records for at least three years.