A.Shawn McCadden, a remodeling industry specialist and consultant in Groton, Mass., responds: One of the challenges of the Renovation, Repair, and Painting (RRP) rule is trying to interpret what the text of the rule means. At only eight hours, the required certification training class concentrates on work practices and spends very little time on the nitty-gritty of the actual rule. One place I find helpful for interpretations is the RRP FAQ area of the EPA website, where this question is directly addressed. The EPA's answer is straightforward: "No. Projects that do not disturb a painted surface are not subject to the RRP rule."
In such a situation, to protect yourself and your business, I recommend that you document the condition of the space before you get started - maybe even take a few pictures. Keep this information in the job folder for historical purposes. I also recommend that you make notes in your written contract that your work will not include any demolition...
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