RRP (AKA Renovation, Repair, and Painting) vs. Lead Paint Abatement

What is the difference between lead paint renovations and lead abatement projects?

Contractors doing work in older homes need to know the difference between what is classified as a Renovation activity versus a Lead Abatement job, as confusing the two may be very costly to a contractor if they misrepresent the work they are doing for their client. The main difference between Lead Renovation and Lead Abatement work is the intent of the work itself. Lead Abatement means any activity where the intent is to permanently eliminate lead paint hazards from the home, building, or structure in question.

Lead Abatement is generally performed in three circumstances:

  • In response to a child with an elevated blood lead level
  • In response to a property with a lead violation imposed upon it
  • Or in housing receiving HUD financial assistance
With Lead Abatement, a government agency is involved from the very beginning, and ultimately, the end result is making a “Lead Free” claim about that home, building or structure, which means that the threat of lead has been removed. Any individual working as an employee on a Lead Abatement job must be certified as a Lead Worker, and work under a Certified Lead Supervisor.

In contrast, Lead Renovation activities are generally defined as any work performed in a pre-1978 residential property where lead-based paint may be disturbed as a result of that work. Again, the intent here is to perform a renovation on the home in question, or routine repair, maintenance or painting work – a renovator’s intent is never to permanently eliminate lead paint hazards or make a “Lead Free” claim about a home, building, or structure – that would be considered a misrepresentation, or fraud. Renovations are performed for many reasons, most having nothing to do with lead-based paint. Renovations involving activities designed to update, maintain, or modify all or part of a building, are covered by the Lead Renovation, Repair, and Painting (RRP) Rule if lead-based paint does in fact show up during pre-renovation lead testing. Activities that are subject to the Lead RRP Rule include:

  • Remodeling and repair or maintenance
  • Electrical work
  • Plumbing
  • Painting preparation
  • Carpentry
  • Window replacement
To be in compliance with the RRP Rule, at least one supervisor on a qualifying job must be trained and certified as a Lead Renovator.

  RENOVATION (RRP) LEAD ABATEMENT
Training 8 hours 16 hours for Workers,
32 hours for Supervisors
Notification Not Required Pre-Abatement Notification
Required to EPA or State
Occupants Distribute the Renovate Right pamphlet Prepare an Occupant
Protection Plan
Clearance Cleaning Verification (CV) Procedure
performed by assigned Renovator
3rd-Party Dust Clearance
performed by a Lead
Inspector or Risk Assessor
Reporting Written report to client detailing
test kit results and post-renovation
checklist within 30 days of invoice
Lead Abatement Final
Report and "Lead Free"
Claim
On-Site Renovator needs to be on site to
oversee setting up containment
and final cleanup
Supervisor is on site when
any work is conducted

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