Renovation, Repair and Painting Program: Work Practices
If you are a renovation firm, then we recommend you read through all of the subjects below to learn how to fulfill your legal requirements to protect yourself, your employees and your clients from the dangers of lead exposure.
Overview | Firm Certification | Renovator Training | Work Practices | Resources
EPA's Lead Renovation, Repair and Painting (RRP) Rule requires specific work practices when lead paint is disturbed by renovation activities. These practices minimize the creation of dust and debris, prevent it from leaving the work area and require cleaning of the work area to ensure occupant safety.
On this page you'll find:
Work Practice Requirements
Work practice requirements include pre-renovation education requirements as well as lead-safe work practice requirements.
- Pre-renovation education requirements:
- Firms that perform renovations for compensation in residential houses, apartments and child-occupied facilities built before 1978 are required to distribute EPA's lead hazard information pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools before starting renovation work.
- The firm must document compliance with this requirement; EPA's pre-renovation disclosure form may be used for this purpose.
- Training, certification and work practice requirements:
- Firms are required to be certified, their employees must be trained in the use of lead-safe work practices (either as a certified renovator or on-the-job by a certified renovator) and lead-safe work practices that minimize occupants’ exposure to lead hazards must be followed.
- Examples of lead-safe work practices include:
- Work-area containment to prevent dust and debris from leaving the work area;
- Prohibition of certain work practices like open-flame burning and the use of power tools without High Efficiency Particulate Air (HEPA) exhaust control; and
- Thorough clean up followed by a verification procedure to minimize exposure to lead-based paint hazards.
Recordkeeping
- Records required to be on the job site:
- Copies of the certified renovator's initial and most recent refresher course completion certificates.
- Records required to be maintained for each job for a period of three years:
- Copies of the certified renovator's initial and most recent refresher course completion certificates.
- Non-certified worker training documentation.
- Designation of a certified renovator to the job.
- Information on and results of use of EPA-recognized test kits or paint chip samples by a certified renovator who acted as the representative of the certified firm at the job site and who conducted testing for the presence of lead-based paint on surfaces to be affected by the renovation.
- Lead-based paint inspection reports provided by a certified lead inspector or certified lead risk assessor, if applicable.
- Proof of owner/occupant pre-renovation education.
- Any other signed and dated documents from the owner(s) and/or residents regarding conduct of the renovation and requirements in the EPA RRP Rule.
- All reports required from the certified firm and the certified renovator by the EPA RRP Rule.
Additional Requirements when Working in HUD housing
In addition to EPA's RRP Rule, 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 HUD's requirements and review a comparison between HUD’s Lead Safe Housing and the RRP Rule to understand how to comply with both.