Lead Paint RRP Protocol Reference

Why this reference exists

Any home built before 1978 is presumed to contain lead-based paint somewhere. Federal law (EPA Renovation, Repair + Painting rule, "RRP") requires certified firms + certified renovators to perform any disturbance of more than 6 square feet of interior or 20 square feet of exterior painted surface in target housing. Penalties run per violation, per day, and EPA counts each uncertified job separately. RRP certification is the legal minimum for any painter taking work on pre-1978 homes.

This reference is the daily working summary, not a substitute for the 8-hour EPA-required training every renovator must complete.

Who must be certified

Firm certification: any company doing renovation, repair, or paint work disturbing covered amounts in pre-1978 housing or child-occupied facilities (pre-1978 schools, daycare).

Renovator certification: at least one person on every job must be a Certified Renovator. They train + oversee non-certified workers + perform critical tasks (post-cleaning, dust wipe).

State alternative: some states (MA, RI, OH, AL, KS, GA, NC, MS, WI, IA, OR, UT, VT) administer their own program - verify with state agency.

Target housing definition

• Built before 1978
• Single-family or multifamily residential
• Renovation that disturbs > 6 sq ft interior OR > 20 sq ft exterior of painted surfaces
• ALSO any window replacement (any amount) - windows are presumed
• ALSO any demolition

Exemptions:

• Built 1978 or later
• Zero-bedroom dwelling (efficiency without sleeping area + bathroom)
• (Removed) The owner opt-out for owner-occupied housing with no child under 6 and no pregnant occupant was eliminated by EPA in 2010. There is no opt-out today; a signed waiver from the homeowner does not exempt the job
• Component testing certified lead-free by Certified Inspector or Certified Risk Assessor

Pre-work requirements

Step 1: Confirm target housing

Year built (county records, owner statement, MLS). If in doubt, treat as target housing.

Step 2: Test (optional, opens shortcuts)

Certified Inspector uses XRF analyzer or chip testing:

• Component-by-component results
• Lead-free components don't need RRP protocols on that component
• Costs about what a standard home inspection costs, and it is customer-paid
• Worth it when the house is large or the scope is repeat work, because every component that tests clear drops out of RRP for good

If NOT testing: assume lead-based paint present + apply RRP everywhere.

Step 3: Pamphlet distribution

Provide "Renovate Right" EPA pamphlet to owner + occupants BEFORE work begins. Document delivery date + signature. For multi-family: notify each tenant. EPA-provided PDF; print + carry copies on every visit.

Step 4: Written agreement

Customer signs acknowledgment that:

• Pamphlet received
• Work involves lead paint hazards
• Firm is RRP certified (firm number on the document)
• Worker is RRP certified (renovator number)

Work practices

Containment:

Interior:

• Cover floor + furniture with 6-mil plastic sheeting
• Plastic out 6 ft from the work area in all directions, or far enough to contain the dust, whichever is greater
• Doorways sealed with plastic + tape
• HVAC vents covered + system off in work zone

Exterior:

• Plastic ground containment 10 ft out (20 ft if working over 3 stories)
• Plastic vertical at corners
• Cover plants + adjacent surfaces

Prohibited methods:

• Open-flame burning or torching
• Power sanding / grinding / blasting WITHOUT HEPA vacuum attachment
• Heat guns above 1100°F
• Dry scraping over 1 sq ft without containment
• Throwing debris from open windows

Acceptable methods:

• Wet scraping (mist water during scraping)
• HEPA-vacuum-attached sanders
• Low-heat (under 1100°F) heat guns
• Chemical strippers (rated for lead paint)
• Manual scraping with mist
• HEPA shroud + power tool

During work:

• Wear disposable suit + N95 minimum (P100 for heavy dust)
• No eating, drinking, smoking in work zone
• Wash hands + face before leaving zone
• Remove work clothes before leaving site
• Vacuum suits + tools with HEPA before exit

Cleanup

Daily:

• HEPA vacuum all surfaces in work zone
• Wet-wipe horizontal surfaces
• Bag debris (double-bag in 6-mil contractor bags, labeled)
• Roll plastic inward to trap dust; bag

Final:

• HEPA vacuum thoroughly
• Wet-mop floors (Spic + Span or TSP)
• Dispose of plastic containment + bags as construction waste (most states; check local - some require lead-paint debris disposal as hazardous)
• Verify work zone visually clean

Cleaning verification (federal rule):

Two options:

1. Cleaning verification (Card method): Certified Renovator wipes specific surfaces with wet disposable cleaning cloth + compares to EPA verification card. If cloth darker than card, re-clean.

2. Dust clearance testing (some states require): independent dust-wipe samples to lab. Lab results pass = job complete.

Most jobs use the card method; states like MA + RI may require clearance testing.

Documentation (retain 3 years)

Every RRP job:

• Firm certificate (copy in job file)
• Renovator certificate (copy)
• Pre-renovation pamphlet receipt (signed)
• Written description of work
• Photos of containment + cleanup
• Cleaning verification documentation
• Any testing results
• Customer's signed acknowledgment

Customer + worker training

Talking points for customers (especially with young children):

• Visible lead paint chips: don't sweep up (creates dust); HEPA vacuum + damp mop
• Children should not be in the work area during or 24 hours after
• Pets out of work area
• Don't sand, scrape, or strip without RRP-certified pro
• Lead in water + soil are separate hazards (different testing)

Workers should be reminded:

• Lead exposure is cumulative
• Wash hands BEFORE eating
• Annual blood-lead test if regularly working on pre-1978 homes
• Pregnant + planning-to-be-pregnant workers should not do RRP

Penalties + enforcement

• Federal civil penalties assessed per violation, per day of noncompliance
• State agency fines on top of that where the state runs its own authorized program
• Loss of RRP certification
• Civil liability if a child is found with elevated blood lead
• Criminal liability in egregious cases

EPA does conduct inspections; tipster complaints + competitor complaints are real enforcement triggers.

References

• EPA RRP Rule (40 CFR 745 Subpart E)
• EPA "Renovate Right" pamphlet (English + Spanish)
• HUD Guidelines for Evaluation + Control of Lead-Based Paint
• State RRP program offices (variable, check yours)
• Manuall internal: Surface Prep for Painting