Does the RRP Rule apply to all pre-1978 buildings?

The RRP Rule applies to renovation, repair, and painting activities in target housing (most pre-1978 housing) and child-occupied facilities. It does not apply to commercial or industrial buildings unless they are child-occupied facilities. It also does not apply to housing exclusively for the elderly or persons with disabilities (unless children under 6 reside there), to zero-bedroom dwellings, or to housing or components declared lead-free by a certified inspector.

Do I need RRP certification or ODH lead abatement licensing?

It depends on the work. If you are performing renovation, repair, or painting that disturbs lead-based paint but are not permanently eliminating lead hazards, you need RRP certification (EPA-certified renovator and firm). If you are performing lead abatement (permanent elimination of lead-based paint hazards through removal, encapsulation, or enclosure), you need ODH licensing in Ohio. Some projects may require both.

What are the RRP Rule's de minimis thresholds?

The RRP Rule does not apply to minor repair and maintenance activities that disturb 6 square feet or less of painted surface per room for interior activities, or 20 square feet or less for exterior activities. Window replacement is never considered minor maintenance. These thresholds are per room, per project - not cumulative across the building.

EPA RRP Rule Explained - Renovation, Repair, and Painting

Q: What is the RRP Rule?

The Renovation, Repair, and Painting (RRP) Rule (40 CFR 745, Subpart E) is a federal regulation requiring lead-safe work practices during renovation activities that disturb lead-based paint in pre-1978 housing and child-occupied facilities. The rule requires EPA-certified renovators and EPA-certified firms.

What Is the RRP Rule?

The Renovation, Repair, and Painting (RRP) Rule is a federal regulation under the Toxic Substances Control Act (TSCA), codified at 40 CFR 745, Subpart E{target=“_blank”}. It requires contractors performing renovation work in pre-1978 housing and child-occupied facilities to be certified and to follow lead-safe work practices to prevent lead exposure from paint dust and debris.

The RRP Rule is separate from lead abatement regulations. Renovation work under the RRP Rule involves work done for purposes other than eliminating lead hazards (remodeling a kitchen, replacing windows, repairing plaster). Lead abatement is work specifically designed to permanently eliminate lead-based paint hazards. Different rules, different certifications.

When the RRP Rule Applies

The RRP Rule applies when ALL of the following are true:

The building is target housing (most housing built before 1978) or a child-occupied facility (building visited regularly by children under 6, such as daycares and preschools)
The work is a renovation (modification of any existing structure that disturbs painted surfaces)
The work exceeds the de minimis thresholds (more than 6 SF interior per room or 20 SF exterior)

Exemptions

The RRP Rule does NOT apply to:

Housing built in 1978 or later
Housing exclusively for elderly or disabled persons (unless a child under 6 resides there)
Zero-bedroom dwellings (studios, dormitories, military barracks)
Housing or components found to be lead-free by a certified lead inspector or risk assessor
Emergency renovations (immediate action needed to address safety hazards) - but lead-safe practices must be followed to the extent possible, and full compliance resumes after the emergency is stabilized
Minor repair and maintenance activities below de minimis thresholds

De Minimis Thresholds

Activities that disturb painted surfaces below these thresholds are not subject to the RRP Rule:

Interior: 6 square feet or less per room
Exterior: 20 square feet or less

Window replacement is never considered minor maintenance, regardless of the area disturbed. Demolition of painted surface components is also not considered minor maintenance.

Certification Requirements

Certified Renovator

At least one certified renovator must be assigned to each renovation project. To become certified, an individual must complete an EPA-accredited 8-hour initial training course and pass a hands-on skills assessment. Certification is valid for 5 years, after which a 4-hour refresher course is required.

The certified renovator is responsible for:

Ensuring lead-safe work practices are followed
Posting signs and distributing the EPA pamphlet “Renovate Right” to occupants
Ensuring the work area is properly contained
Performing or directing the cleaning verification after work is complete
Preparing required documentation

Firm Certification

Any company performing renovations for compensation in target housing or child-occupied facilities must be certified by EPA (or by the state, if the state has an authorized program). Firm certification is obtained by submitting an application to EPA and paying the fee. Certification is valid for 5 years.

Ohio does not currently operate an EPA-authorized state RRP program, so firm and renovator certifications are issued directly by U.S. EPA.

Lead-Safe Work Practices

The RRP Rule requires the following work practices during renovation:

Pre-Renovation Education

Before starting work, the certified renovator or firm must provide occupants of target housing with EPA’s “Renovate Right” pamphlet (or approved state equivalent). For child-occupied facilities, the pamphlet must be provided to the building owner and to parents/guardians of children using the facility.

Containment

The work area must be contained to prevent dust and debris from spreading:

Interior: Cover floors and objects within 6 feet of the work area with plastic sheeting. Close and seal doors and windows in the work area. Cover HVAC ducts in the work area.
Exterior: Cover the ground with plastic sheeting extending at least 10 feet from the building. Close windows and doors within 20 feet of the work area.

Prohibited Practices

The following practices are prohibited during RRP work:

Open-flame burning or torching of lead-based paint
Use of machines that remove paint through high-speed operation (sanding, grinding, planing, needle gun, abrasive blasting) without HEPA exhaust control
Operating a heat gun above 1,100 degrees Fahrenheit

Cleaning

After the work is complete:

Pick up all paint chips and debris
Mist and remove protective sheeting
Clean all surfaces in the work area using HEPA vacuuming and wet wiping/mopping
The certified renovator must perform a cleaning verification using disposable wet cleaning cloths (for hard surfaces) or visual inspection (for carpeted surfaces)

Waste Handling

All waste from RRP activities must be contained to prevent release of dust and debris. Waste can be disposed of as regular construction debris in most jurisdictions, but check local requirements. Waste does not need to be managed as lead-contaminated hazardous waste unless it fails TCLP testing.

Recordkeeping

Certified firms must maintain records for 3 years after completion of each renovation, including:

Reports certifying lead-safe work practices were followed
Documentation of occupant notification and pamphlet distribution
Certified renovator assigned to the project
Dates and location of the renovation
Cleaning verification records

RRP Rule vs. Ohio Lead Abatement

Requirement	RRP Rule	Ohio Lead Abatement (ODH)
Applies to	Renovation disturbing paint	Permanent elimination of lead hazards
Certification authority	U.S. EPA	Ohio Department of Health
Individual certification	EPA-certified renovator (8-hr course)	ODH-licensed inspector, risk assessor, contractor, worker, or designer
Firm/company	EPA-certified firm	ODH-licensed abatement contractor
Clearance testing	Cleaning verification (visual/wet cloth)	Dust wipe sampling by licensed inspector or risk assessor
Pre-1978 trigger	Yes	Yes (lead-based paint by definition)
Can coexist on same project	Yes	Yes

Resources

EPA RRP Rule Overview
EPA Certified Renovator Training - Find accredited courses
EPA Renovate Right Pamphlet- Ohio Lead Program Overview
Ohio Lead Licensing and Certification - ODH requirements (separate from RRP)