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. Fines for non-compliance: up to per violation. 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)
• Owner-occupied housing where NO child under 6 or pregnant person lives there + owner signs opt-out
• 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
• Test cost: typical inspection
• Customer-paid; opens later shortcuts if many components are clear

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 5 ft from work zone in all directions
• 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

• State agency fines additional
• 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