My firm removes and replaces garage doors made up of multiple panels, each of which has an exterior painted surface area of <20 square feet. If we disturb the paint on just one of the door panels, is that activity subject to the Lead Renovation, Repair and Painting (RRP) Rule?

An activity that disturbs less than 20 square feet of exterior painted surface and otherwise meets the definition of minor repair and maintenance is not subject to the RRP Rule. However, the RRP Rule provides that when removing painted components, or portions of painted components, the entire surface area removed is the amount of painted surface disturbed.

In this case, application of the RRP Rule is dependent on how much of the garage door your firm intends to remove and replace. If you disturb a painted surface on a single panel while removing and replacing the entire garage door (i.e., all the panels), you must aggregate the surface area of all the panels. Similarly, if you disturb a painted surface on a single panel while removing and replacing more than one panel, you must aggregate the surface area of those panels being removed to determine whether or not the RRP Rule applies. If, however, you disturb a painted surface on a single panel while removing and replacing only that panel, and the activity disturbs less than 20 square feet of exterior painted surface and otherwise meets the definition of minor repair and maintenance (e.g., not demolition or using prohibited practices), such an activity would be considered minor repair and maintenance, and therefore would not be subject to the RRP Rule.

Question Number: 23002-31779

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