EPA’s Lead Renovation (RRP) Rule: What Contractors and Landlords Must Do
Who needs EPA lead-safe certification for paid work in pre-1978 housing, the Renovate Right pamphlet, the minor-repair exemption and the 3-year records rule.
By Seayora Editorial Team · Published · Facts checked · 4 min read
Short answer: Paid work that disturbs painted surfaces in housing built before 1978 is a renovation under EPA’s Renovation, Repair and Painting rule. The firm must be EPA- or state-certified, a certified renovator must follow lead-safe work practices, and the owner, plus an adult occupant if the owner does not live there, must receive EPA’s Renovate Right pamphlet no more than 60 days before work starts. Minor repairs disturbing 6 square feet or less of painted surface per room inside, or 20 square feet outside, are exempt unless they involve window replacement or demolition.
Key takeaways
- The rule covers renovations for compensation in target housing (pre-1978 homes) and child-occupied facilities (40 CFR 745.82).
- It covers landlords’ in-house maintenance staff as well as outside contractors, according to EPA.
- Give the Renovate Right pamphlet no more than 60 days before work, with a signed acknowledgment or a certificate of mailing at least seven days ahead (40 CFR 745.84).
- Minor repair and maintenance: 6 square feet or less per room inside, 20 outside, no window replacement or demolition (40 CFR 745.83).
- Keep the records for three years after the job (40 CFR 745.86).
Who does the RRP rule apply to?
The rule “applies to all renovations performed for compensation in target housing and child-occupied facilities” (40 CFR 745.82). Target housing is “any housing constructed prior to 1978,” except housing for the elderly or people with disabilities and zero-bedroom dwellings such as studios, unless a child under six lives or is expected to live there (40 CFR 745.103). EPA says firms doing this work “must be EPA- or state-certified and must use certified renovators who follow specific work practices,” and that “this includes in-house maintenance staff and many types of outside contractors” (EPA).
What counts as a renovation?
A renovation is any modification of an existing structure “that results in the disturbance of painted surfaces,” including repairing or removing painted components, window repair, sanding and scraping, removing walls, ceilings, plumbing or windows, and weatherization that cuts into painted surfaces (40 CFR 745.83). A plumber who opens a painted wall to reach a pipe is doing a renovation unless the job fits the minor repair exemption.
What is the minor repair exemption?
Minor repair and maintenance, including minor HVAC, electrical and plumbing work, is work that disturbs “6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities,” uses none of the prohibited work practices, and does not involve window replacement or demolition of painted surfaces. Jobs in the same room within 30 days count as one job (40 CFR 745.83). Work is also outside the rule where a certified inspector, a certified renovator using an EPA-recognized test kit, or a recognized laboratory has found the affected components free of lead-based paint (40 CFR 745.82).
When must the Renovate Right pamphlet be given?
No more than 60 days before work begins in a dwelling unit, the firm must give the owner the pamphlet and either get a written acknowledgment or a certificate of mailing at least seven days before the work. If the owner does not live in the unit, the firm must also give the pamphlet to an adult occupant, with an acknowledgment, a certificate of mailing, or a written certification of delivery explaining why no acknowledgment could be obtained (40 CFR 745.84). Common-area work in multifamily buildings has its own notice rules. The pamphlet requirement does not apply to emergency renovations that respond to a sudden, unexpected event presenting a safety hazard or threatening significant damage, though the work practices still do (40 CFR 745.82(b)).
What records must be kept?
Firms must keep, and make available to EPA on request, “all records necessary to demonstrate compliance” for three years after the renovation is completed, including any determination that lead-based paint was not present, the pamphlet acknowledgments and the work-practice records; a longer state requirement still applies (40 CFR 745.86).
| Question | Rule | Section |
|---|---|---|
| Which homes? | Built before 1978, with exceptions for elderly or disability housing and zero-bedroom units with no child under six | § 745.103 |
| Which work? | Renovations for compensation that disturb painted surfaces | §§ 745.82, 745.83 |
| Who must be certified? | The firm, with a certified renovator directing the work | § 745.89 |
| Pamphlet timing | No more than 60 days before work; mailing at least 7 days before | § 745.84 |
| Minor repair | 6 sq ft per room inside, 20 sq ft outside, no window replacement or demolition | § 745.83 |
| Records | Three years after completion | § 745.86 |
How does this connect to the landlord’s lead disclosure?
They are two different rules. The disclosure rule governs what a landlord tells a tenant before a pre-1978 lease is signed; the RRP rule governs how paid work is done once the tenant lives there. See our lead-based paint disclosure guide.
Frequently asked questions
Does a landlord’s maintenance worker need RRP certification?
EPA says the rule includes in-house maintenance staff. Work in pre-1978 rental housing that disturbs more painted surface than the minor repair limits must be done by a certified firm using a certified renovator.
Is painting a room covered by the RRP rule?
The definition turns on disturbing painted surfaces, and it names surface preparation such as sanding and scraping. Most repainting involves that preparation, so treat it as a renovation unless the job fits the minor repair limits or the surfaces were tested lead-free.
How long before work must I give the Renovate Right pamphlet?
No more than 60 days before work starts. If you mail it, the certificate of mailing must be obtained at least seven days before the renovation.
Sources
- 40 CFR Part 745, Subpart E, Residential Property Renovation, eCFR
- 40 CFR Part 745, Subpart F, Disclosure of Known Lead-Based Paint (definitions, § 745.103), eCFR
- Lead Renovation, Repair and Painting Program Rules, U.S. Environmental Protection Agency
How Seayora helps
Safety records and certifications: Track employee certifications and their expiry dates in the system where the work is scheduled.
This article is general information, not legal advice. Landlord-tenant law varies by state and city and changes often, so check the current rule for your property and talk to an attorney before acting on a dispute.
How we write and check these guides: editorial standards.
Related on Seayora
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- Charging a Customer Quickly — Documentation. One form: the kind of work, labor and parts, the job site — and the card or a pay link, with the right sales tax and the rule behind it.
- Automations — scripts that answer for you — Documentation. Build a branching script that triages a repair report, grades how urgent it is from the answers, sends safety instructions the moment they matter, and opens the work order at the right service level.