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• The Lead Renovation, Repair and Painting (RRP) Rule provisions require exterior containment. At what point is the wind too strong to allow work to continue?

  The work practices for exterior projects are based on a performance standard -- the certified renovator or a worker under the direction of the certified renovator must contain the work area so that dust or debris does not leave the work area while the renovation is being performed. The certified…

  • Last published: November 19, 2024

• Under the Lead Renovation, Repair and Painting (RRP) Rule, is composite sampling acceptable for clearance in lieu of cleaning verification?

  Yes. Under the RRP Rule , cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another Federal, State, Territorial, Tribal or local law or regulation requires: The renovation firm to perform dust clearance sampling at the conclusion of…

  • Last published: January 13, 2025

• Under the Lead Renovation, Repair and Painting (RRP) Rule, what type of container is adequate for on-site storage of debris? 

  At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure or behind a barrier that prevents release of dust and debris out of the work area and prevents access to…

  • Last published: November 19, 2024

• May the renovator training provider give the exam orally?

  Yes. There is no requirement that the course test be conducted in writing. Each individual must successfully complete the hands-on skills assessment and receive a passing score on the course test to pass any course. Question Number: 23002-19573 Find a printable PDF copy of all frequent questions pertaining to lead…

  • Last published: November 21, 2024

• Did the final TSCA section 403 rule say who may make a hazard determination?

  Answer: No. Although the TSCA section 403 rule defines a hazard determination, it did not specify who may make hazard determinations. The TSCA section 403 rule amended the work practice standards in 40 CFR 745.227 by adding 745.227(h) - “Determinations,” which explains what constitutes lead-based paint, a paint-lead hazard, a…

  • Last published: January 13, 2025

• I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of painted wood siding that tested positive for lead. The underlying painted surface is greater than twenty square feet. Must I comply with the Rule when removing the aluminum siding?

  Answer: The work practices for exterior projects are based on a performance standard – if the activity disturbs a painted surface (generally, by creating paint chips or dust) in excess of 20 square feet, the work area must be contained so that dust or debris does not leave the work…

  • Last published: October 29, 2024

• Must notifications for common area renovations always be provided to every unit in a multifamily housing complex?

  Answer: Not necessarily. When renovations are to be performed in common areas of multi-family housing (i.e., those portions of the property generally accessible to all residents/users), the RRP Rule requires that each “affected unit” be notified in writing. See 745.84(b)(2). As a general matter, all units in the housing are…

  • Last published: November 20, 2024

• In a typical co-operative apartment building, occupants do not own the individual units; rather they “own” an undifferentiated share in the entire building and then “rent” back a specific unit from the co-operative corporation. Similarly, in a typical condominium building, owners of individual units jointly own the common areas of the building. For purposes of the pre-renovation education requirements, who are the “owners” in such situations?

  Answer: EPA recognizes that co-operative apartments (“co-ops”) and condominiums (“condos”) can be structured in a variety of ways. For example, in the case of co-ops, a corporation (sometimes referred to as a “co-op association”) is often established and owns all the units and common areas comprising the co-op; in such…

  • Last published: November 20, 2024

• When a unit is not occupied by its owner, 40 CFR 745.84(a)(2) states that the “Renovate Right” pamphlet must be provided to an adult occupant prior to beginning any covered renovation activities. What does EPA consider an “adult” for these purposes?

  Answer: For purposes of receiving the pamphlet pursuant to the pre-renovation education requirements, EPA believes that “adult” means a person who has reached 18 years of age. Question Number: 23002-33372 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 20, 2024

• What is the “work area?”

  Answer: The “work area” is the area established by a certified renovator to contain the dust and debris generated from a renovation. In other words, the work area is defined by the containment measures established by the certified renovator. While a renovator has some discretion in setting up a sufficient…

  • Last published: November 20, 2024

• The drinking water I receive from a public water system has an unfamiliar odor and a slight discoloration. I am concerned that this is an indication of lead in my drinking water. What can I do to determine if lead is in my drinking water?

  Answer: You cannot see, taste, or smell lead in drinking water. To determine if lead is in your drinking water, contact your local water supplier and ask for a copy of your Consumer Confidence Report. This report lists the levels of contaminants that have been detected in the water, including…

  • Last published: November 5, 2024

• What is the water system doing about lead in drinking water?

  Answer: In accordance with the Lead and Copper Rule, your water system is required to test water collected from a number of households in your community for levels of lead and copper. Depending upon the number of people served by your water system and the levels of lead and copper…

  • Last published: November 5, 2024

• Is there a guidance document that outlines sampling techniques for testing lead in public drinking water systems?

  Answer: Sampling techniques for testing lead in drinking water are outlined in EPA's approved methods for compliance monitoring of lead in drinking water. In addition, EPA has several guidance documents associated with Lead and Copper Rule water quality and tap monitoring on our website here: https://www.epa.gov/dwreginfo/lead-and-copper-rule-implementation-tools#WQ . This guidance does…

  • Last published: November 5, 2024

• A water system is on reduced monitoring for lead and copper. If this system adds new or revised treatment, must the system resume lead and copper sampling as a new system?

  Answer: The state may require a system to resume sampling and collect the number of samples specified for standard monitoring or take other appropriate steps such as increased water quality parameter monitoring or re-evaluation of its corrosion control treatment (40 CFR 141.86(d)(4)(vii)). Question (23002-32405) Find a printable PDF copy of…

  • Last published: November 5, 2024

• Is anyone exempt from paying fees under the Fee Rule for Abatement and Renovate, Repair and Painting (RRP) Programs?

  Yes. TSCA section 402(a)(3) exempts state, local government and non-profit training programs from federal accreditation fees. However, it does not provide an exemption for the certification fees of firms or individuals. Question Number: 23002-33302 Find a printable PDF copy of all frequent questions pertaining to lead .

  • Last published: November 5, 2024