Per the EPA's Lead Renovation, Repair and Painting Rule (RRP Rule), renovation, repair, and painting projects that disturb lead-based paint in homes, childcare facilities and pre-schools built before 1978 must be performed by firms certified by EPA or certified renovators who are trained by EPA-approved training providers and follow lead-safe work practices.
A permit is required when paint will be disturbed (sanding, damaged, pressure washing, removed, etc.):
- For paint-only projects
- As part of a project (inclusive of a Building Permit)
- Pressure washing a building built before 1978
Exemptions to the need for a permit as per EPA's RRP Rule are as follows:
1. Minor Repairs and Renovation Activities
Minor interior repairs that disturb less than six square feet of surfaces coated with lead paint per room are exempt from the RRP Rule. Exterior construction activities are also excluded as long as no more than 20 square feet of lead-contaminated surfaces are disturbed during the renovations.
It’s important to note that these RRP Rule exclusions are not applicable to window repairs and replacements. Lead-contaminated surfaces such as window sills and sashes should be removed or demolished using the proper work practices for lead safety.
2. Lead-Free Renovations
It’s estimated that nearly 24 million homes in America contain some form of deteriorating lead paint. At least 4 million of those homes are dwellings where one or more children reside
Yes, those statistics sound staggering, but those numbers are slowly dwindling. Since the implementation of lead paint bans in 1978, new construction no longer contains lead-contaminated paints, surfaces, and coated materials. Construction on modern buildings where lead isn’t present is exempt from the RRP Rule.
3. Emergency Construction
Sometimes there’s an immediate need for remediation of issues like storm damage or a burst pipe that can make a home or building unsafe for occupation. Emergency repairs don’t require adherence to the RRP Rule. However, after the work is completed, verified cleaning is necessary before re-entering the residence.
4. Do-It-Yourself Repairs
Homeowners who choose to DIY their home repairs are also exempt. This includes any help a homeowner receives from friends or family during renovations, as long as those people don’t receive payment. Note: The property must be owner-occupied.
5. Projects where paint will not be disturbed
A project may have presumed or confirmed lead-based paint that is intact where the paint or construction activities will not disturb the paint at all. These types of projects may be: painting over the existing intact paint without any sanding, chipping, removal, etc. (Disturbing of the paint), new stucco coat or spray paint over existing paint, placing new siding or drywall over existing wall coverings, or other activities that will not disturb presumed or confirmed lead-based paint.
Although doing your own home renovations might seem like the cheaper, faster option, it’s not a very wise way to work. Instead, always go with an EPA-certified contractor to ensure safe working conditions and proper cleanup, protecting the health of yourself and your family.
Failure to create a Lead-Based Paint Abatement Work Plan or stating that no paint will be disturbed when the project does disturb paint will result in a Stop Work order issued.