Photo: Multi Housing

Renovation, Repair and Painting (RRP) Regulations:


Renovation, Repair and Painting (RRP) Regulations

As of April 2010, owners of market-rate properties built before 1978 will have to comply with EPA lead safety regulations that govern common renovation and repair activities.  (Age-restricted properties with no children occupying them and properties that have been certified to be free of lead-based paint by a state inspector are exempt from the RRP regulations.)

Under the regulations, if renovation or repair work undertaken on a covered property disturbs more than six square feet of surface area for interior work or 20 square feet for exterior work, the work must be carried out by a trained and certified renovator. 

In addition, residents must be notified and provided with a copy of an EPA pamphlet, Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools.  (This is a different pamphlet than the EPA's Protect Your Family pamphlet that owners are required to provide to residents at the time of lease signing.)  There are also recordkeeping requirements imposed on owners or the third-party contractors they hire to undertake work covered by the regulations.

Importantly, the RRP rules expands existing Lead Safe Housing (LSH) rules that has imposed comparable—but not identical—compliance obligations on pre-1978 properties that receive federal assistance, including Section 8 vouchers.    Under the RRP rules, federally assisted properties must comply with the more stringent elements of both the LSH and RRP regulations. 

Recent Developments
On June 18, 2010, EPA announced that it would delay enforcement of parts of the RRP rule.  Specifically, EPA extended the deadline for workers to sign up for a lead-safe training class to September 30.  Training must be completed by December 31.  EPA will also not take enforcement actions for violations of the rule's firm certification requirement until October 1.  Importantly, EPA is not delaying enforcement actions for those found to be in non-compliance with the rule's lead-safe work practice requirements. 

On August 23, EPA’s Office of Enforcement and Compliance Assurance issued a Consolidated Enforcement Response and Penalty Policy for the RRP rule.  The document provides information on the factors federal enforcement officials will take into account in assessing civil administrative penalties for violations of various provisions of the RRP rule.  .

EPA is in the process of amending the rules in a series of rulemakings as a result of a lawsuit brought against it by the Sierra Club.  For more information  on the latest rulemakings and other developments, see NMHC's Guidance.

Final Regulations and Guidance Materials

Amendments to the Rules

Third-party Guidance, Advisories, and Resources

  • EPA Outreach: Complying with the RRP Regulations
    EPA is reaching out to the regulated community with this memo to inform them about the Renovation, Repair and Painting Rule which establishes performance criteria for activities on pre-1978 residential properties.
  • EPA-Approved Lead Paint Test Kits
    Identifies which commercially available chemical spot tests can be used to test for the presence of lead-based paint to comply with the Renovation, Repair and Painting Rule. (April 2012)
  • EPA Fact: RRP and Natural Disasters
    Describes how provisions of the RRP rule apply to repairs and renovations done in response to natural disasters, such as floods and hurricanes.
  • OSHA Lead in Construction Advisor
    Interactive, online system produced by OSHA in response to NMHC/NAA requests. Asissts workers understand and comply with federal rules for workers who deal with lead-based paint. (September 1999)

NMHC Compliance Guidance