The rule, in language a project manager can use.
The EPA's Renovation, Repair, and Painting Rule (40 CFR 745 Subpart E) governs work that disturbs lead-based paint in pre-1978 housing and child-occupied facilities. This page is a working summary, not legal advice. For the regulatory text, see the EPA's RRP Rule Handbook.
Frequently asked questions
When does the RRP rule apply to my job?
If the home or child-occupied facility was built before 1978 and your renovation disturbs more than six square feet of interior painted surface (or 20 sq ft exterior), the RRP rule applies. Window replacement, demolition, and any project disturbing painted components below those thresholds may also trigger RRP requirements depending on scope.
Do I have to be RRP-certified to bid the job?
EPA RRP requires both a Firm Certification and an individual Certified Renovator on every job. You don't have to be the certified party yourself — most GCs hire a compliance firm to handle the lead-impact portion. We're led by an EPA Certified Renovator and operate the documentation chain end-to-end.
What does the certified firm actually do?
Three regulatory functions: (1) deliver the EPA Renovate Right pamphlet to occupants and collect signed acknowledgments; (2) ensure the renovation follows EPA work-practice standards (containment, prohibited practices, cleaning); (3) verify cleaning with the cleaning verification card test and retain records for at least three years. ECT does all three on every job.
What's the penalty exposure if I get it wrong?
EPA assesses civil penalties up to $47,357 per violation per day (statute-adjusted figure; check current EPA enforcement guidance). Common violations include failing to deliver the pamphlet, using prohibited work practices like open-flame burning or high-speed sanding without HEPA, and failing to perform cleaning verification.
How long do RRP records have to be kept?
EPA requires three years from the date the renovation was completed (40 CFR 745.86). ECT keeps your job folder accessible to you for 39 months — three years plus a 90-day grace window so you have time to download and migrate your copy.
What is 'cleaning verification' and what does the card test prove?
After cleaning, the certified renovator wipes designated areas with a wet cloth and compares the cloth to a standard verification card. If the cloth is no darker than the card, the area passes. If it's darker, you re-clean and re-test. EPA accepts the card test as the standard cleaning verification for non-HUD-funded projects.
This page is a working summary written for general contractors operating in southeast Michigan. It is not legal advice and does not replace EPA guidance, the regulatory text at 40 CFR 745, or counsel from your own attorney. Penalty figures cited are subject to statutory adjustment; check current EPA enforcement guidance for the figure in effect on your job date.