I do residential repaints.

The EPA RRP Rule (40 CFR 745, Subpart E) applies to any renovation, repair, or painting that disturbs painted surfaces in pre-1978 target housing or child-occupied facilities (daycares, schools).

It applies to you if you disturb:

• > 6 ft² interior painted surface per room, OR
• > 20 ft² exterior painted surface, OR
• Any window replacement or demolition of painted components.

Exemptions: Minor repair/maintenance (< 6 ft² interior / < 20 ft² exterior unless using prohibited practices like open-flame burning, power sanding without HEPA, or heat guns > 1100°F). Emergency renovations have relaxed timing but still require cleanup/verification.

What you MUST have/do:

1. Firm Certification: Apply to EPA (or authorized state) – $300–$500/5 yrs.
2. Certified Renovator: You (or an employee on-site) must complete an 8-hr EPA-accredited course (valid 5 yrs; 4-hr refresher).
3. Pre-Renovation: Distribute EPA pamphlet "Renovate Right" to owner/occupants; obtain signed receipt or document refusal.
4. On-Site: Post warning signs; isolate work area (plastic, containment); use HEPA vacuums/shrouded tools; no open flames, heat guns > 1100°F, or dry scraping large areas.
5. Cleanup & Verification: HEPA vac → wet wipe → Cleaning Verification (white glove/wipe test per §745.85) or Clearance Testing (dust wipes by certified inspector if requested/HUD job).
6. Records: Keep training certs, pamphlet receipts, checklists, verification photos for 3 years.

State Note: 14+ states (e.g., WA, OR, CA, MA, RI, ME, VT, NH, NY, NJ, MD, VA, NC, GA) run their own programs—stricter rules/fees often apply. Check your state.

Bottom line: If you scrape/sand/disturb > de minimis in pre-1978 homes, you need Firm Cert + Renovator Cert + containment/HEPA/verification paperwork before you start.

The EPA’s Renovation, Repair and Painting (RRP) Rule (40 CFR Part 745, Subpart E) applies to you if you perform work for compensation in pre-1978 residential housing or child-occupied facilities that disturbs more than 6 square feet of interior painted surface or 20 square feet of exterior painted surface per room, or involves window replacement, demolition, or prohibited practices (like open-flame burning or heat guns above 1100°F).

It applies to you as a residential repainter when:

• The home was built before 1978 (lead-based paint was banned for residential use in 1978).
• You are disturbing painted surfaces (scraping, sanding, cutting, drilling, etc.) — not just applying new paint over intact surfaces.
• The disturbed area exceeds the thresholds above per room.

What you need to have/comply with:

1. EPA RRP Certification (for your firm) — you or your company must be certified by an EPA-accredited trainer.
2. Certified Renovator — at least one supervisor on-site must have completed an 8-hour EPA-approved RRP training course.
3. Work Practices — use containment (plastic sheeting), HEPA vacuums, wet methods, and proper cleanup. No dry sanding or scraping without controls.
4. Recordkeeping — keep records of training, work practices, and occupant notifications for 3 years.
5. Pre-renovation Education — provide the EPA’s “Renovate Right” pamphlet to occupants/owners before work begins.
6. Signage — post warning signs at work area entrances during work.

If you only paint over intact, undisturbed surfaces (no sanding/scraping) in pre-1978 homes, the RRP rule does NOT apply. But if you’re doing any surface prep that creates dust, you’re likely covered.

Unsafe or unlicensed? No — this is a trade-specific rule, not a license like electrical or plumbing. But non-compliance risks fines up to $41,456 per violation per day (as of 2024). Get certified — it’s cheap, fast (1-day course), and protects you, your workers, and clients.

Source: EPA RRP Rule, 40 CFR §745.80–§745.92. epa.gov/lead