Does the RRP rule apply to my job? A step-by-step check

Step 1: Is the building target housing or a child-occupied facility?

Target housing is housing built before 1978. Section 745.103 excludes housing for the elderly or persons with disabilities, and 0-bedroom dwellings, unless a child under 6 lives there or is expected to live there. Rental units count. So do common areas of apartment buildings.

A child-occupied facility is a pre-1978 building, or part of one, that the same child under 6 visits regularly. Section 745.83 sets the test: at least two different days in the same week, at least 3 hours each day, at least 6 hours in the week, and at least 60 hours in the year. Day care centers, preschools, and kindergarten classrooms are the usual examples.

If you do not know the build year, check county property records or ask the owner in writing. Keep the answer with the job. A guess is hard to defend later.

• Built before 1978?
• Housing, or a building a young child visits regularly?
• Elderly, disability, or 0-bedroom housing? Check whether a child under 6 lives there or is expected to.
• Record where the build year came from.

Step 2: Is it a renovation, and is someone paying for it?

Section 745.83 defines renovation as changing an existing structure in a way that disturbs painted surfaces. That includes repair, remodeling, painting prep, window replacement, and trade work such as plumbing, electrical, and HVAC when it cuts or removes painted material. Work done as part of a lead abatement falls under different rules.

The rule covers work done for compensation. EPA treats rent as compensation, so work in rental housing by a landlord or the landlord's staff is usually covered. A homeowner working on their own home is not covered by the federal RRP rule, though they should still work lead-safe.

Step 3: Is it small enough to be minor repair and maintenance?

Minor repair and maintenance is outside the rule. Section 745.83 sets the limits: 6 square feet or less of painted surface per room inside, or 20 square feet or less outside. When you remove a painted part, the whole surface of that part counts.

Three things cancel the exception no matter how small the area: window replacement, demolition of painted surface areas, and any practice that section 745.85(a)(3) prohibits or restricts, such as open-flame burning. Jobs in the same room within the same 30 days count as one job, so you cannot split a large job into small visits.

Example: an electrician cuts two outlet holes and a small chase in one bedroom wall, about 3 square feet in total. That can be minor repair. Replacing one window in the same room is not, even though the painted area is small.

• Measure the painted area to be disturbed in each room.
• Inside: 6 square feet or less per room.
• Outside: 20 square feet or less.
• No window replacement.
• No demolition of painted surfaces.
• No prohibited practices.
• Add up all work in the same room over 30 days.

Step 4: Has someone shown the parts are lead-free?

Section 745.82(a) lists three ways to show that the parts you will disturb are free of lead-based paint. A certified inspector or risk assessor makes a written determination, and the firm keeps a copy. Or a certified renovator tests each affected part with an EPA-recognized test kit. Or a certified renovator collects a paint chip from each part and an EPA-recognized lab finds it lead-free.

The test must cover every part the job will disturb. One clean result on a door does not clear the window trim. Our test kit records guide explains what to write down. Section 745.87(e) says lead-based paint is assumed to be present unless one of these steps shows otherwise.

Step 5: Is it an emergency?

Section 745.82(b) defines an emergency renovation as unplanned work after a sudden, unexpected event, such as a burst pipe, that is a safety or public health hazard or threatens significant property damage if not fixed right away.

An emergency does not remove the rule. It skips the pamphlet step and, only as far as the emergency requires, the sign, containment, waste, training, and certification steps. Cleaning, cleaning verification, and records still apply. Section 745.86(b)(6) says the firm must write down the nature of the emergency and which steps it did not follow.

Record the answer either way

If the job is covered, start the full process in our RRP compliance checklist. If it is not covered, keep a short note on why: the build year source, the measured area, or the lead-free determination. That note is what you show if someone asks later.

State, Tribal, and local programs can be stricter. Some cover more buildings or set smaller limits. Check the program for the job's location before you rely on a federal exception.

Questions contractors ask

Does painting count if I only wash and paint? If the prep does not disturb painted surfaces, it may not be a renovation. Scraping and sanding do disturb them.

Can the owner sign away the rule? No. EPA removed the owner opt-out in 2010.

Does the rule apply to commercial buildings? Only where a child-occupied facility is inside. Section 745.83 says that then includes common areas young children use routinely, such as restrooms and cafeterias, and the exterior walls right next to those areas. Hallways and stairs they only pass through are not included.