Frequently Asked Questions About the EPA RRP Rule
NCHH has created a list of frequently asked questions concerning lead-based paint, lead poisoning, and the Renovation, Repair, and Painting (RRP) Rule to supplement EPA’s own list (printer-friendly version here).
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Frequently Asked Questions for Consumers
Why should I be concerned about lead poisoning?
Lead isn’t the only metal that is hazardous when ingested, but it is the one most widely found in homes. Lead poisoning is a threat to everyone, not just small children; however, children are most at risk due to two factors: First, children have a tendency to play with and sometimes ingest items found on the floor or outside; and second, their nervous systems are still developing. Lead poisoning may result in severe learning disabilities, reduced IQ, behavioral problems, even death. Even people who appear to have no symptoms may have been poisoned. It only takes a little bit of lead to poison a child. The EPA considers any more than 5 micrograms per deciliter (5 µg/dL; a microgram is one millionth of a gram) to be a level requiring action, but NCHH has recommended that the maximum allowable level should be lowered further. If you suspect that a family member may have come in contact with dangerous levels of lead, contact your family physician immediately. You may also want to contact your local health department. Be safe, not sorry.
What does “RRP” mean? What are “lead-safe work practices” (LSWP)?
“RRP” stands for “Renovation, Repair, and Painting.”
What’s a “renovator”?
For the purpose of EPA’s rule, a renovator is any person who performs home improvements for money or other consideration.
My house was built in 1979. Do I need to worry about lead-based paint in my home?
Probably not. If your home was built after January 1, 1978, you don’t need to worry about lead-based paint in your home, unless someone used old paint that should’ve been thrown out or parts of your home (such as a porch, deck, stoop, or cabinets) have been painted with marine paint, which can contain lead. However, you should be aware of other places where your child regularly spends significant amounts of time, such as at a friend’s house, a day care center, a school, or a relative’s home. You should also understand that lead exposure may come from other sources, such as water, soil, and various consumer products.
I just rented a house (or an apartment in a house) that was built before 1978. Is the landlord supposed to do anything about lead?
Yes! By law, your landlord must give you a copy of an EPA pamphlet called Renovate Right. It doesn’t have to be an original—the landlord can give you a black-and-white copy, as long as it’s complete. If s/he doesn’t provide a copy of this, s/he may be subject to fines by the EPA.
My kids are really smart, and they know better than to eat anything they found on the floor. So I don’t need to worry about anything, right?
Before you assume that it won’t happen to you, answer these questions: Do my kids play with toys? Do my kids ever play on the floor? Do my kids ever leave their toys on the floor? Do my kids ever put their hands or their toys in their mouths? If you answered “yes” to any of these questions, your children are at risk for lead poisoning. Here’s how: The lead dust sticks to the toys on the floor and is transferred to their skin as the children play. The children will either put the toys in their mouths or touch their hands to their mouths at some point and unknowingly ingest the lead. Another example: Children will often put their mouths on painted windowsills containing lead, which tastes sweet. They like what they taste, so they do it again and ingest the lead that way. It doesn’t take very much to make a child ill, either.
How do I know if the company I’m planning to hire for renovation work is properly trained in lead-safe work practices (LSWP)?
The contractor should have two certificates, one issued by the EPA that names the firm (you may be able to search for the company here) and one with a picture of the worker that a training organization issues upon successful completion of the RRP class. Neither certificate guarantees that the renovator will perform quality work, only that they have completed the training and passed the exam. Many companies offer RRP training, so certificate designs may vary in both appearance and size, but all must contain the same basic information: name and address of the worker, the certificate number, the certificate issue and expiration dates; and mention of “40 CFR 745.225,” which is the section of the RRP Rule concerning accreditation of training programs for target housing and child-occupied facilities.
These renovators are going to charge me too much! It’s okay to just do the work myself, right?
It’s not against the law to make your own home improvements; however, if your home was built prior to 1978, you run the risk of contaminating your property with lead dust, which is harmful to children and adults alike. We strongly recommend completing the EPA’s eight-hour lead-safe work practices course from a reputable training company before undertaking any renovation projects in pre-1978 buildings.
What if I just tell the contractor that they don’t have to follow lead-safe work practices in my home? Is there a form I need to sign?
There used to be an opt-out clause that homeowners could sign to allow the renovator to work on their home without following lead-safe work practices, but EPA cancelled it in 2010 since no one can guarantee that children will never live in a particular dwelling. Failing to follow lead-safe work practices will increase your legal liability, will make it harder for you to sell or rent your property, and may cause permanent harm to many people.
How can I tell if my contractor is working lead-safe?
Before hiring any contractor or company, ask to see proof that the company is a “Lead-Safe Certified Firm.” Then verify that the person supervising work on your home has indeed passed the Lead Certified Renovator class. This will be a certificate with a color photo of the worker and a registration number of some type.
How do I report a violation, and whom do I contact if I suspect that lead-safe work practices aren’t being followed?
EPA has a website for filing complaints against contractors who are not working lead-safe. When you visit this link, click on the yellow and black shield that reads “EPA Report Environmental Violations.” NCHH also has a list of the regional RRP contacts and enforcement officers available to consumers.
I heard about a pamphlet that the EPA published called Renovate Right. Where can I get a copy?
You may obtain a free downloadable PDF version of Renovate Right in English from NCHH by clicking here; in Spanish, click here. You may also download it directly from the EPA here. Black-and-white copies are available in bulk from the NCHH web store. Remember, contractors are required to provide a copy of Renovate Right to you before starting work on your home; failure to do so is a violation of the RRP Rule. It does not have to be an original, but it does have to be complete. Older versions are acceptable, but you should disregard anything you read about an opt-out clause, as it is no longer in effect.
I just interviewed a contractor about some work, and the contractor said that RRP was a bunch of baloney. What do you say?
We say that this contractor probably isn’t trained in lead-safe work practices and that you should think twice about hiring this company. The company may charge less, but they’re also giving you less, and your family’s safety is worth too much to skimp on safety.
Frequently Asked Questions for Renovators and Landlords
We’ve grouped landlords and renovator together because the RRP Rule requires landlords who make their own repairs to be certified for lead-safe work practices.
I’m not going to be trained for RRP—so what? What’s EPA going to do about it?
If you’re found to be working on pre-1978 housing with an expired certification or no certification, the EPA will fine you. The fines—as much as $37,500 per infraction—can put you out of business. It would probably be much less expensive to be trained for RRP. EPA has already levied fines against several business for violating existing lead laws. Because they involve ongoing investigations, you won’t hear about them until after the legal matter is settled. Read about about a 2020 fine levied by EPA and DOJ against a major company for failing to follow the RRP Rule or a 2018 action against a celebrity remodeler who didn’t follow RRP.
How do I go about finding a class?
There are classes available in every state and most territories within the United States. You can find a training provider near you by visiting EPA’s training locator, which lists upcoming RRP and DST (dust sampling technician) courses in most states. States that have their own RRP enforcement programs will not be listed in the training locator; however, EPA has included links to each state’s webpage from their site.
Once I take the RRP class, am I able to work everywhere, or will I need to take the class again in other states before I can work there?
Most states will recognize certifications from other states, although there are or will be a few exceptions. Three states that have adopted their own version of the RRP Rule— Alabama, Massachusetts, and Rhode Island—only honor certificates generated from classes taught using their version of the RRP curriculum; however, all of the other states will accept certifications from these states. New Jersey also honors out-of-state certifications but only for residential construction. In order to renovate in multifamily structures, you must have attended a class registered with New Jersey containing a state-specific module, although the class doesn’t have to be taught within the boundaries of that state.
I’ve successfully completed the class. Now what?
Congratulations, you now know how to work with lead safely and responsibly! Before you race off to start renovating that old Victorian, a question: Have you applied to the EPA to become a lead-safe certified firm? EPA requires all renovation companies, from national corporations all the way down to single contractors and landlords who either perform their own repairs or have a handyman on staff, to register their business with them. Download the application. The firm registration costs $300 and is valid for five years. The certificate that you received for passing the Lead Certified Renovator class also expires in five years, so you’ll need to take EPA’s four-hour Refresher class at that time. Note that you must take the Refresher course before your current certification expires; otherwise, you’ll need to take the Initial course again.
I’ve completed the EPA Renovation Firm paperwork, but I’m afraid I won’t have my EPA Lead-Safe Renovation Firm certificate in time for this job I’m starting. Do I need to wait for my certificate to arrive in the mail before I can work?
Obviously, it’s best if you have a copy of your Lead-Safe Certified Firm certificate with you at the jobsite, but if your firm hasn’t received one yet, you can still work on that old Victorian, provided you can prove that your paperwork is in process. According to the National Lead Information Center, having a photocopy of the application that you sent to EPA, along with a copy of the cancelled check, is sufficient until your certification from EPA arrives. (Note that the firm certification is different from the worker certification, and both are required.) Don’t have a cancelled check yet? Our recommendation is to wait for the cancelled check; however, you should at least make sure that you can produce proof of having mailed it to EPA, such as keeping a copy of the check you sent, a receipt for certified mail from the post office, and a photocopy of the application. You can reach the National Lead Information Center at 1.800.424.LEAD (5323).
I just have a small business, just me, my truck, and my tools. I don’t need to register my company with the EPA, do I?
Yes. If you accept money for renovation work, you must register your business with EPA. The firm registration costs $300 and is valid for five years. The certificate that you received for passing the Lead Certified Renovator class also expires in five years; you’ll need to take a four-hour Refresher class at that time.
I’m just doing some work for a friend/family member/my church and am not being paid for my help. Do I need to take the RRP class?
Is it really “helping” if you make them sick or accidentally kill them? You are not required by law to take the course if you are not receiving money for your services, but you should take it or at least study lead-safe work practices before you begin. Just because you’re not being paid doesn’t mean that you can’t poison your friends, their children, family members, or other people you care about because you didn’t take the time to learn how to work lead-safe, and it doesn’t mean you can’t be sued if something goes wrong.
What’s an “e-learning” class?
An “e-learning” class is one of the EPA-approved methods of delivering the RRP training to renovation workers. There are two halves to any RRP class: a lecture module (where the instructor educates the students about the rule and lead-safe work practices) and a hands-on module (where the students actually learn how to prepare a jobsite while observing lead-safe work practices). With e-learning, students are permitted to view the lecture module on their home or work computers, reducing the amount of time spent in the classroom by approximately half. The lecture module must be provided by an EPA-accredited company. At the end of the lecture module, students must take a short exam in order to confirm that they understand all of the concepts discussed in the lecture module. Once they have passed the exam, they may attend a hands-on session, which is typically a four-hour class at a designated training location, during which they work with an training instructor. Some training providers require an exam at the end of the hands-on session. E-learning scores are consistent with those in the typical certified renovator class.
I heard about a pamphlet that the EPA published called Renovate Right. Apparently I’m supposed to be handing this out to my customers (tenants). Where can I get a copy? And what’s the worst thing that can happen if I forget to do it?
You may obtain a free downloadable PDF version of Renovate Right in English from NCHH by clicking here; in Spanish, click here. You may also download it directly from the EPA by clicking here for English or here for Spanish. Black-and-white copies in bulk quantities are available for sale from the NCHH web store. Remember, you are required to provide a copy of Renovate Right to your clients before starting work on their home; failure to do so is a violation of the RRP Rule and may result in stiff fines. You do not have to provide an original—black-and-white copies are permitted, but it must be complete and the language cannot be unaltered. You may use up your old copies, but you should remove the opt-out page in the back of the book, as the opt-out clause is no longer in effect in almost all states.
I just lost a bid on a job to another renovation firm that came in with a lower bid because they’re going to cut corners. I’m no rat, but what should I do?
You should report them, and here’s why: (1) The work they’re doing is unsafe and may result in a public health risk; (2) they’re your competition and are only able to offer lower prices because they’re working illegally, something you’re not willing to do; and (3) businesses that take shortcuts and work illegally (a) leave a blemish on the profession and (b) cheat honest renovators out of much-needed business, virtually stealing the clothes from the backs and the food from the mouths of their children.