EPA RRP Rule: Lead-Safe Work Practices for Pre-1978 Renovations

Scope: where RRP applies

Target Housing

Any housing constructed before 1978, excluding:

• Housing for elderly or persons with disabilities — unless a child under six resides or is expected to reside there.
• Zero-bedroom dwellings (studios) — unless a child under six resides or is expected to reside.

Child-Occupied Facility

A building (or portion) constructed pre-1978 visited regularly by the same child under six:

• At least two different days within any week.
• Each visit at least three hours.
• Combined weekly visits at least six hours.
• Combined annual visits at least 60 hours.

Examples: day care centers, preschools, kindergarten classrooms.

Primary source: epa.gov/lead/renovation-repair-and-painting-program.

Firm certification

• All firms — including sole proprietorships — performing renovation, repair, or painting work disturbing paint in pre-1978 target housing or child-occupied facilities must be certified by EPA or an authorized state.
• Certification valid for five years.
• Renewal required; lapsed firm certification invalidates current work.
• Application and fees through EPA (or authorized state agency).

Certified Renovator on each job site

Each certified firm must have at least one Certified Renovator assigned to each job site where lead-based paint is disturbed:

• Training: 8-hour EPA- or state-approved course with hands-on learning.
• Refresher training: required periodically to maintain certification.
• On-the-job training to non-certified workers is the Certified Renovator's responsibility.
• Overall compliance with lead-safe work practices on the job site.

Lead-safe work practices

• Containment of the work area to prevent dust and debris escape.
• Prohibited high-dust practices: open-flame burning, heat guns above 1,100°F, power tools without HEPA exhaust control.
• Thorough cleanup procedures with cleaning verification.
• Pre-1978 building assumption — assume lead-based paint present unless testing proves otherwise.
• Worker and occupant protection during and post-renovation.

Pre-renovation education — the Renovate Right pamphlet

• Before renovation begins: distribute EPA's "Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools" pamphlet to the owner and any adult occupants.
• Firm must document compliance with this distribution requirement.
• Spanish-language version available for distribution where appropriate.

State authorization status in the Mid-Atlantic

EPA administers RRP directly in some states; others have been authorized to administer the program:

• Pennsylvania — EPA-administered RRP program. Firms certify with EPA.
• New Jersey — EPA-administered RRP program.
• Maryland — MDE-administered; MD has been authorized for RRP.
• Delaware — EPA-administered.
• Virginia — VA Department of Professional and Occupational Regulation (DPOR) handles parallel lead-based paint worker/supervisor licensing; EPA RRP still applies federally.

State authorization status is subject to change; verify current status before firm certification renewal.

RRP interaction with other requirements

• NESHAP asbestos often layers on top of RRP for renovations in older buildings. See our NESHAP asbestos essay.
• OSHA Lead in Construction — 29 CFR 1926.62 — worker protection standard separate from RRP.
• HUD Lead Safe Housing Rule for federally-assisted housing.
• State lead abatement programs (MD Lead Reduction Program, for example) for higher-hazard remediation.
• Local rental licensing may impose additional lead disclosure/abatement requirements.

Common contractor missteps

• Assuming "it's just painting" doesn't trigger RRP. Painting can disturb existing paint; if it disturbs lead-based paint in pre-1978 buildings, RRP applies.
• Using non-certified subcontractors. All firms involved need certification.
• Missing the Renovate Right distribution. Firms must document this step.
• Cleanup verification skipped. RRP requires specific cleaning verification — not just visual check.
• Letting firm certification lapse. Five-year cycle; renewal not automatic.
• Assuming painting over lead counts as abatement. It doesn't. Encapsulation is different from abatement; RRP addresses renovation (disturbance), not full abatement.
• Using prohibited practices like heat guns >1,100°F. Explicitly forbidden.
• Ignoring the child-occupied facility definition. Day cares and preschools are covered even if not residential.

Enforcement

• EPA or authorized state agency conducts investigations.
• Civil penalties up to $40,000+ per violation per day (adjusted for inflation).
• Settlement agreements with remediation and reporting commitments common.
• Criminal penalties for knowing violations.
• Investigations often triggered by consumer complaints, post-renovation child elevated blood lead levels, or landlord/tenant disputes.

What contractors and owners should do

If you're a contractor working pre-1978 residential or child-care facilities: firm certification + Certified Renovator staffing is non-negotiable.

If you manage or own pre-1978 rental housing: verify RRP compliance for all contractors you engage; document Renovate Right distribution.

If you're a child care center in pre-1978 building: understand RRP covers you and train your maintenance staff accordingly.

If you're planning a major renovation: RRP + NESHAP asbestos + OSHA lead-in-construction are all simultaneously applicable. Budget and plan accordingly.

For state-specific construction context, see our essays on PA UCC, Philadelphia Pre-Permit Approvals, Baltimore CHAP, and other city permit essays.

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