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May I use the pamphlet “Protect Your Family From Lead in Your Home” to meet my obligations for pre-renovation education under the RRP Rule?
Answer: No. As of December 22, 2008, only the pamphlet “ Renovate Right ” may be used to comply with the pre-renovation education requirements of the RRP Rule. “ Protect Your Family ” is still available for use during real-estate sales and lease transactions and for general information. Question Number…
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Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?
Yes, as long as the installation does not disturb more than six square feet of painted surface per room within a 30-day period. Question Number: 23002-15404 Find a printable PDF copy of all frequent questions pertaining to lead .
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If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?
Yes. To qualify for the exception for minor repair and maintenance activities, the total amount of exterior paint disrupted must be 20 square feet or less. In addition, the job must not use prohibited practices or involve window replacement or demolition of painted surfaces. Question Number: 23002-18379 Find a printable…
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If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Yes. Although making the hole disrupts less than six square feet of painted surface, using a hammer to make the hole is demolition of the surface, so the minor repair and maintenance exception does not apply. Making the hole using a cut-out technique that does not destroy the section of…
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My firm is replacing windows in a condominium. Is this type of exterior work considered work in a common area, and if so, must other owners and occupants be informed about the job?
Exterior renovations of multi-unit target housing are considered renovations of a common area. A common area is a portion of a building that is generally accessible to all residents or users of the building. Renovations in common areas of multi-unit target housing, such as condominiums, must be performed in accordance…
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Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the owner or occupant. What is the difference between a certificate of mailing and certified mail?
A certificate of mailing is a receipt showing evidence of mailing, while certified mail provides proof of mailing and delivery of mail. When using the certificate of mailing option, no record is kept at the mailing office and a receipt is not obtained when mail is delivered to the addressee…
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What is a renovation?
The Lead Renovation, Repair, and Painting (RRP) Rule covers activities that modify an existing structure and that result in the disturbance of painted surfaces. All types of repair, remodeling, maintenance, modernization, and weatherization projects are covered, including projects performed as part of another Federal, State, or local program, if the…
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When installing a roof, my firm does not create dust by directly sanding or cutting painted surfaces, but we do hammer the unpainted side of the lumber from above. Does the RRP Rule apply to this work?
The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. If hammering painted components, even on the unpainted side, disturbs paint, creating dust or chips, the RRP Rule applies. Question Number: 23002-23787 Find a printable PDF copy of all frequent questions pertaining to lead .
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When multiple contractors are involved in a single renovation, must every contractor provide pre-renovation education? Can a certified firm assign its responsibility to a property management company?
All firms performing, offering or claiming to perform renovations are responsible for ensuring compliance with the pre-renovation education requirements of the RRP Rule. However, it is unnecessary for the same notifications and information to be given out repeatedly during a single renovation. Accordingly, a firm may discharge the task by…
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When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or…
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I am planning on sending the pamphlet via certificate of mailing to a tenant who occupies a unit scheduled to be renovated. Does the tenant’s name need to be addressed on the mailing, or is it acceptable to address the envelope to Attn: Tenant/Occupant?
Answer: The tenant’s name and address must be indicated on the mailing. The RRP Rule requires a renovator to provide the “Renovate Right” pamphlet to an adult in each unit. Therefore, the name and address of an adult occupant in each unit must be indicated on the mailing. The renovator…
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Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been painted?
Answer: The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. Therefore, renovations that disturb stucco are subject to the RRP Rule only if the stucco has been painted. Question Number: 23002-14025 Find a printable PDF copy of all frequent questions pertaining to lead .
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Are Department of Energy weatherization projects covered under the RRP Rule?
Answer : The Lead Renovation, Repair, and Painting (RRP) Rule defines “renovation” to include weatherization projects such as cutting holes in painted surfaces to install blown-in insulation or to gain access to attics, and planing thresholds to install weather stripping. Other types of weatherization projects, such as window replacement, are…
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If working in target housing occupied by persons who are blind, how should a firm comply with the pre-renovation information distribution requirements?
EPA’s pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools is currently not published in a Braille format. In addition to distributing the regular pamphlet, a firm working in such an environment should take extra precaution to ensure that the owner and occupants are…
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If a firm completely blocks access to a common area for the duration of a renovation, does the renovator still have to provide notifications to all tenants?
When tenant accessibility to a work site within a common area can be precluded for the duration of a renovation, EPA considers that work site to be temporarily excluded from the common area of the building for pre-renovation education purposes because it is not accessible to the residents and users…
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