What is the EPA’s Renovation, Repair and Painting (RRP) Rule?

As of April 22, 2010, federal law requires 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 under the Renovation, Repair and Painting (RRP) rule. To do that, a firm must send at least one representative to take an 8-hour Lead Safe Renovator – Initial training class; after class, that representative must apply to become a “certified renovator.” Then, federal law requires that a certified renovator be assigned to each job, and that all workers are trained to perform lead-safe work practices.

Required Lead-Safe Work Practices

The certified firm must assign a Certified Renovator to each renovation job it performs. Next,

  • The firm must notify the homeowner or tenants about lead hazards through distributing the “Renovate Right” pamphlet.
    • The firm must document compliance with this requirement.
  • The certified renovator must perform or direct certain key tasks during the renovation and be present on-site during those key tasks, including while:
    • Signs are being posted before the job;
    • The work area is being contained; and
    • The work area is being cleaned post-renovation.
  • The certified renovator must perform cleaning verification after the job is finished.
  • The certified firm and renovator must make sure that other workers on the renovation job follow lead-safe work practices.
  • The certified firm and renovator must prepare and maintain records.

HUD’s Lead Requirements

In addition to EPA’s Renovation, Repair and Painting regulations, the U.S. Department of Housing and Urban Development (HUD) requires compliance with its Lead Safe Housing Rule in target housing receiving HUD assistance. Read about it here.

Lead Poisoning

Mostly, lead poisoning happens by breathing lead dust and ingesting lead chips. Child lead poisoning can cause reduced IQ and attention span, impaired growth and learning, hearing loss, and a range of other health and behavioral effects. Sometimes, people with lead poisoning complain of headaches, stomachaches, irritability, fatigue, loss of appetite and joint and/or muscle pain.

One way to create a lot of lead dust and chips is by disturbing leaded coatings like paint, stain, shellac or varnish through cutting, sawing and sanding. Lead coatings were found pretty much everywhere in the U.S. until 1978 when they were banned by the Consumer Products Safety Commission (lead, a bluish metallic element, made the coatings more durable).