Why lead-safe work matters
Lead-based paint was used in more than 38 million homes until it was banned for homes in 1978. When old paint is sanded, scraped or cut, it makes fine lead dust. You often cannot see it, but people breathe it or swallow it.
- Children under 6 are most at risk. Lead harms the developing brain and nervous system and can cause reduced IQ, learning disabilities and behavior problems.
- Pregnant women can pass lead to the unborn baby.
- In adults, lead can raise blood pressure.
- A blood test is the only way to know whether someone has lead poisoning.
Most lead exposure in homes comes from lead dust from deteriorating paint and from contaminated soil. Ordinary renovation and maintenance can make this dust, and it can harm your customers, your workers and even you.
Helping the family prepare
- Explain where the work area is and that people and pets must stay out until the work is finished and cleaned.
- For bigger jobs, the family may want to arrange somewhere else to stay.
- Families may ask for optional lead-dust testing after the job, in addition to cleaning verification.
Who and what the rule covers
The RRP rule covers anyone paid to do work that disturbs paint in housing and child-occupied facilities built before 1978. This includes general contractors, painters, plumbers, carpenters, electricians, landlords and property managers. Window replacement counts as renovation.
Child-occupied facility
A pre-1978 building visited regularly by the same child under 6 on at least two different days a week, for at least 3 hours a day and 6 hours a week, and at least 60 hours a year. Examples include child care centers.
Main exclusions
| Exclusion | Limit |
|---|---|
| Minor repair and maintenance, inside | 6 square feet or less of paint per room |
| Minor repair and maintenance, outside | 20 square feet or less |
| Housing for elderly or disabled persons | Unless a child under 6 lives or will live there |
| Zero-bedroom dwellings (studios, dorms) | Unless a child under 6 lives or will live there |
| Parts tested lead-free | By a certified inspector or risk assessor, or a certified renovator with an EPA-recognized test kit or lab test |
- Window replacement, demolition and prohibited practices are never minor repair.
- Homeowners working on their own home are generally not covered, unless they rent it out, run a child care center in it, or flip houses for profit.
- In an emergency, some steps may be skipped as needed, but cleaning and cleaning verification still apply.
Firm and renovator certification
| Credential | How you get it | How long it lasts |
|---|---|---|
| Certified firm | Apply to EPA (or your authorized state) and pay the fee | 5 years |
| Certified renovator | 8-hour accredited course with 2 hours hands-on | 5 years |
| Refresher, with hands-on | 4-hour refresher course | 5 years |
| Refresher, online only | 4-hour online refresher | 3 years |
- The refresher must include hands-on learning every other time.
- Take the refresher before your certificate expires. If it lapses, you must retake the 8-hour course.
- Firms should apply to renew at least 90 days before expiry. If you apply later and the renewal is not approved by the expiry date, the firm may not do covered work until it is.
- Firms cannot advertise or do covered work without firm certification.
- Training providers must be accredited by EPA or an authorized state or tribe.
- Some states run their own programs. If you work in several states, you may need both EPA and state certification.
EPA does not publish a question bank or test format for the renovator course. Your training provider runs the course and decides when you have completed it.
What the firm and the certified renovator must do
The firm
- Make sure everyone who disturbs paint is a certified renovator or was trained by one.
- Assign a certified renovator to every job.
- Follow the work practice standards.
- Give out the Renovate Right pamphlet before work starts.
- Keep the required records.
The certified renovator
- Trains workers who are not certified in the lead-safe practices for their tasks.
- Is on site while signs are posted, containment is set up and cleaning is done, and is on site or available by phone at other times.
- Regularly directs the work and keeps containment in place.
- Uses an EPA-recognized test kit or sends paint chips to an EPA-recognized lab when asked.
- Performs cleaning verification.
- Keeps copies of the initial and most recent refresher certificates on site.
- Prepares the required records.
Pre-renovation education: Renovate Right
Before work starts in pre-1978 housing, give the owner and the occupants EPA's lead pamphlet, Renovate Right.
| Method | Timing | Proof |
|---|---|---|
| Hand delivery | No more than 60 days before work starts | Confirmation of receipt |
| At least 7 days before work starts | Certificate of mailing | |
| Tenant not home or will not sign | Before work starts | Self-certification of delivery (tenant units only) |
- Child-occupied facilities: give the pamphlet to the owner or an adult representative, and notify parents and guardians or post signs about the work.
- Common areas of apartment buildings: give the owner the pamphlet and notify tenants or post signs. Send a new notice if the scope, location or timing changes.
- Renovate Right tells families to ask to see the contractor's certification and training certificate.
Setting up: signs and containment
Post warning signs before work starts, in the occupants' language, and keep them up until cleaning verification is done. Then contain the work area so no dust or debris escapes.
Interior jobs
- Remove objects from the work area, or cover them with plastic sealed at the seams and edges.
- Close and cover HVAC ducts with taped plastic.
- Close windows and doors, and cover doors with plastic.
- Cover the floor with taped plastic at least 6 feet beyond the work area, or farther if needed. A sealed floor-to-ceiling barrier can be used instead.
Exterior jobs
- Close all doors and windows within 20 feet of the work.
- Cover doors in use with plastic that lets workers pass but holds in dust.
- Cover the ground with plastic at least 10 feet beyond the work area, or farther to catch debris.
- Use vertical containment if a property line, nearby buildings or wind call for it.
Prohibited practices and waste
| Practice | Rule |
|---|---|
| Open-flame burning or torching | Prohibited |
| Sanding, grinding, planing, needle guns, abrasive blasting | Prohibited unless the tool has a shroud or containment and a HEPA vacuum attachment |
| Heat guns | Allowed only below 1,100 degrees F |
- Workers, tools and the outside of waste containers must be free of dust when they leave the work area.
- Contain waste before removal, store it safely at the end of each day, and keep it contained during transport.
Cleaning and cleaning verification
Cleaning an interior work area
- Collect paint chips and debris in heavy-duty bags.
- Remove the plastic sheeting as waste.
- Clean the work area and surfaces within 2 feet of it.
- Clean walls from the top down with a HEPA vacuum or a damp cloth.
- HEPA vacuum all remaining surfaces, then wipe hard surfaces with a damp cloth.
- Mop floors keeping wash and rinse water separate, or with a wet mopping system.
Cleaning verification (interior)
- The certified renovator looks for dust, debris or residue. If any is found, clean again.
- Wipe windowsills, countertops and uncarpeted floors with a wet, white disposable cleaning cloth. Use a new cloth for each section over 40 square feet.
- Compare each cloth to EPA's cleaning verification card. If it is darker, clean again and wipe with a new wet cloth.
- If it fails again, wait until the area is dry or 1 hour, whichever is longer, then wipe with a dry cloth.
Outside, the certified renovator visually inspects the area, and any dust or debris must be removed. Where a contract or another law requires it, dust-lead clearance testing by a certified inspector, risk assessor or dust sampling technician is used instead.
Records
Keep all required records for 3 years after the renovation is finished.
- Proof that the Renovate Right pamphlet was delivered or mailed.
- Any test kit or lab reports showing parts were lead-free.
- Documentation of compliance: the certified renovator's name, trained workers, signs, containment, waste handling, cleaning and the verification results, including how many wet and dry cloths were used.
- Give a copy of the documentation of compliance to the owner and occupant.
A covered job from start to finish
Course quizzes often ask what comes first. This list puts the rule's steps in the order they usually happen on a job in a pre-1978 home.
- Check that the firm is certified and that a certified renovator is assigned to the job.
- Decide whether the work is covered: the age of the building, who lives there, and whether it is more than minor repair and maintenance.
- If asked, test the painted parts with an EPA-recognized test kit or paint chip samples. Otherwise assume lead-based paint.
- Give the Renovate Right pamphlet to the owner and occupants, and keep the proof.
- Train any workers who are not certified in the tasks they will do.
- Post warning signs and set up containment, with the certified renovator on site.
- Do the work without prohibited practices, and keep waste contained.
- Clean the area, with the certified renovator on site.
- Do cleaning verification, or dust-lead clearance testing if the contract or law requires it.
- Take down the signs, give the owner and occupant the documentation of compliance, and keep the records for 3 years.
Key terms
The 16 words and rules to know for this test. Read the list or study them as flashcards: flip each card, then mark it "Know it" or "Still learning".
- RRP rule
- EPA's Lead Renovation, Repair and Painting rule in 40 CFR 745, Subpart E, covering paid work that disturbs paint in pre-1978 homes and child-occupied facilities.
- 1978
- The year lead-based paint was banned for homes. Treat painted surfaces in older buildings as lead-based unless tested lead-free.
- Lead dust
- Fine dust made when old paint is sanded, scraped or cut. It is often invisible and is most harmful to children under 6.
- Child-occupied facility
- A pre-1978 building the same child under 6 visits on two or more days a week, at least 3 hours a day, 6 hours a week and 60 hours a year.
- Minor repair and maintenance
- Work disturbing 6 square feet or less of paint per room inside, or 20 square feet or less outside. Window replacement never qualifies.
- Certified firm
- A business certified by EPA or an authorized state to do covered work. Certification lasts 5 years; apply to renew at least 90 days early.
- Certified renovator
- A person who passed the 8-hour accredited course with 2 hours hands-on. They train workers and perform cleaning verification.
- Refresher course
- A 4-hour course taken before certification expires. With hands-on it lasts 5 years; online only, it lasts 3 years.
- Renovate Right
- EPA's lead pamphlet given to owners and occupants before work: hand delivered within 60 days before, or mailed at least 7 days before.
- Interior containment
- Cover the floor with taped plastic at least 6 feet beyond the work area, close and cover HVAC ducts, and cover doors.
- Exterior containment
- Close doors and windows within 20 feet of the work and cover the ground with plastic at least 10 feet beyond it.
- Prohibited practices
- Open-flame burning or torching, and power sanding or blasting without a shroud and HEPA vacuum. Heat guns must stay below 1,100 degrees F.
- HEPA vacuum
- A vacuum with a high-efficiency filter, used to clean walls top down and all remaining surfaces after lead work.
- Cleaning verification
- The renovator wipes sills, counters and floors with a wet white cloth and compares it to EPA's card. Use a new cloth per 40 square feet.
- Cleaning verification card
- EPA's card used to judge a wipe cloth. If the cloth is darker, clean again; after a second failure, wait and use a dry cloth.
- Record keeping
- Keep all RRP records, including pamphlet proof and the documentation of compliance, for 3 years after the job ends.