Before starting work, the author tests painted surfaces with a portable XRF analyzer to find out whether lead levels are high enough to require RRP compliance.
Before starting work, the author tests painted surfaces with a portable XRF analyzer to find out whether lead levels are high enough to require RRP compliance.
By the EPA's estimates, 80 percent of contractors who are working on pre-1978 housing are still uncertified under the Renovation, Repair, and Painting (RRP) rule. Competing against those guys is tough, because they don't have to factor compliance costs into their bids. So we've developed some practical strategies for our small remodeling company that have reduced our costs and made lead-safe remodeling less of a burden. This makes our bids more competitive and has allowed us to close on a higher percentage of jobs than we did when we first became RRP certified. If you take the time to read the rule, you'll see that it's not necessarily difficult or time-consuming to work safely and legally around lead-based paint.

Know the Law

Back when the RRP was first introduced, I asked a representative of a large replacement window installer how the new rule was going to affect his company's business. He explained that staff members had examined the law carefully and found ways to reduce compliance costs to about $25 per window, a cost that they felt they could absorb. They weren't even going to mention RRP in their sales pitch.

To find out how this company could do that, I studied the law more closely. What I discovered is that a lot of what is taught in the usual day-long renovator course can't be found in the rule itself.

The original course manual - a joint collaboration between the EPA, HUD, and CDC (Centers for Disease Control) - was written before the final rule was published, so the course incorporates various work and safety methods that meet HUD and OSHA requirements but don't apply to many renovators and contractors. Compounding the confusion, many course instructors simply don't know the rule very well.

For example, disposable suits and booties are routinely discussed in the course, but they're not mentioned in the actual law. When I took the course, my instructor taught the class that if we were replacing several interior doors, we would need to cover the floors in the rooms on either side of each door with plastic, move furniture out of the rooms, cover the vents, and seal off the windows and any other doors - plus wear disposable suits, masks, hats, gloves, and booties while on the job. In reality, though, that project doesn't even require RRP compliance. If the only paint being disturbed is on the door hinges, the job falls under the RRP's minor repair and maintenance exception. Other cases where RRP compliance probably isn't needed include installing gutters, shutters, crown molding, and even new siding over original siding.

The RRP rule can be found at epa.gov/lead. Look for the link that says "Renovation, Repair and Painting" (under the heading "On this Web site") and click on it. Then click on the link that says "Read EPA's Regulations on Residential Property Renovation at 40 CFR 745, Subpart E."

Basically, the rule requires that contractors contain the work area, minimize dust, and clean up thoroughly. On pre-1978 housing, you need to follow RRP work rules whenever you're disturbing more than 20 square feet of paint on the exterior or 6 square feet (per room) of paint on the interior. If you can show by testing that the paint contains no more than 1 mg/cm squared (0.5 percent by weight) of lead, the RRP doesn't apply. Otherwise, the rule requires that you do the following:

  • Create a containment area, usually by covering the ground or floor with plastic. On exterior projects, the containment area must extend at least 10 feet around the perimeter of the work area; if the neighboring property line is within 10 feet, vertical containment is also required. On interior projects, the floor should be covered to at least 6 feet from the work area. It's up to the renovator to determine if the containment area needs to be extended to catch all of the dust and debris, or whether vertical containment is needed.
  • Remove furniture from the containment area or cover it with plastic, sealing the edges with tape.
  • Close windows and doors in the containment area; doors should also be covered with plastic. Entry doors into the work area must be able to contain dust and debris.
  • Cover and seal hvac vents within the containment area with plastic.
  • Post appropriate warning signs.
  • Follow proper cleanup and recordkeeping procedures.
 
Dean Lovvorn