EPA Lead Laws: RRP Rule April 22nd, 2010

As of April 22 2010, property owners or contractors who perform projects that disturb lead-based paint in facilities built before 1978 must be certified and must follow the pre-existing lead safe work practices.

Watch the RRP Rule Overview Video


Exemptions to the RRP Rule

  • Less than six ft of lead-based paint is disturbed in a room
  • Less than twenty feet of lead-based paint is disturbed on the exterior
  • Homeowners working their own home
  • The work area has been professionally tested for lead and is lead-free
  • *Window replacements do not qualify for exemption

  • Property Owners/Managers

  • When renovating or repairing over two feet of a pre-1978 building, you must provide tenants with the EPA’s lead hazard pamphlet: “Renovate Right: Important Lead Hazard Information” and document that each tenant received it.
  • Contractors are required to show you their certification and give you the EPA’s lead hazard pamphlet
  • Contracts should specify which parts of the building are in the work area, specify which lead-safe practices will be used, and specify that the contractor is responsible for verifying that the work area was thoroughly cleaned upon completion
  • Make sure contractors have a separate entrance to the work site and turn off heating and air systems
  • Watch Property Managers FAQ Video
  • Owners and managers are required to disclose information about lead-based paint before a lease takes effect or before a property is sold.

    Becoming Certified: Property Owners

  • Property owners must submit an application for certification and payment to the EPA. The EPA has 90 days to approve or disapprove the application.

  • Contractors

  • When renovating a pre-1978 building, you must provide your client with a copy of your training certificate and provide tenants with the EPA’s lead hazard pamphlet (“Renovate Right: Important Lead Hazard Information”)
  • Keep records to demonstrate that you and your workers have all been trained. Specific requirements for recordkeeping must be met.
  • Follow all pre-existing lead safe work practices


  • Becoming Certified: Contractors

  • Contractors must submit an application for certification and payment to the EPA. The EPA has 90 days to approve or disapprove the application.
  • Contractors must take a RRP renovation certification course

  • If a contractor has already taken a renovation training course, they are required to take a refresher course to become certified.

  • The Lead Safe Information Class - New EPA Renovation, Repair and Painting Rule: April 20th

      With the seminars focus on legal implications, compliance and protection for property owners. Under this format we will encompass the requirements a property owner needs to undertake to become a certified renovator as well as all of the other regulatory requirements they will need to meet. This class does not entitle or certify participants to perform certified renovation work but is designed to build awareness about the new lead safe laws. This seminar is sponsored by Neace Lukens and taught by Robert Karl, Partner and Environmental Practice Leader, Ulmer & Berne and Paul Duggan, Environmental Practice, Bliss & Glennon.

      Time: 3:00 PM to 4:30 PM April 20, 2010

      Location: Crown Centre, 5005 Rockside Road, Independence, OH 44131 - lower level auditorium