The RRP rule for landlords and contractors

The federal Renovation, Repair and Painting rule, usually called the RRP rule, applies when paid work disturbs paint in most pre-1978 rentals and other older homes. For landlords and contractors, the rule is really about one thing: stopping lead dust from spreading by using certified firms, trained renovators, resident notices, safe work practices, careful cleanup, and solid records.

What the RRP rule covers

EPA’s RRP rule covers paid renovation, repair, and painting work that disturbs painted surfaces in housing built before 1978 and in pre-1978 child-occupied facilities.

That means the rule can reach a lot more than big remodels. It can apply to painting prep, plumbing, electrical work, carpentry, window replacement, maintenance, and turnover work between tenants if the job disturbs paint.

It also covers more than traditional contractors. Residential rental owners and property managers can be covered too. So can sole proprietors and specialty trades.

The key question is not whether the job is called a renovation. The key question is whether paid work will disturb painted surfaces in a covered older property.

The RRP rule is separate from the federal disclosure rule for most pre-1978 rentals. If you need a refresher on that leasing rule, see The federal lead disclosure rule for pre-1978 homes.

When the rule applies and when it may not

A simple way to screen a job is to walk through this checklist:

1. Was the housing or facility built before 1978?
2. Is the work being done for compensation?
3. Will the work disturb painted surfaces?
4. Is the job outside one of the rule’s limited exemptions?

Some common exemptions matter a lot in rentals.

First, the rule does not apply to housing built in 1978 or later.

Second, some housing types are excluded unless a child under age 6 lives there or is expected to live there. That includes housing for elderly or disabled persons and zero-bedroom dwellings such as many studio apartments and dorm-style units.

Third, minor repair and maintenance can be exempt if the work disturbs no more than 6 square feet of painted surface per room inside, or no more than 20 square feet on the exterior. But that exemption is narrower than many owners expect. It does not include window replacement. It also does not include jobs involving demolition or prohibited work practices. And if smaller jobs happen in the same room within the same 30 days, EPA says they count together for deciding whether the job is still minor.

Fourth, the rule does not apply to components that have been found lead-free by a certified inspector or risk assessor, or by a certified renovator using an EPA-recognized test kit or paint chip samples analyzed by an EPA-recognized lab.

A helpful practical point: painting by itself is not automatically covered. If a wall is simply repainted with no sanding, scraping, or other surface disturbance, EPA says that is not renovation under the RRP rule.

What landlords need to know

Landlords sometimes assume the rule only applies when they hire an outside contractor. That is not how EPA treats rental work.

If a landlord does covered renovation work in a pre-1978 rental unit personally, EPA treats that work as compensated. The landlord must have firm certification and must use, or be, a certified renovator.

If the landlord’s employee does the covered work, the landlord must have firm certification and the employee must be a certified renovator.

If the landlord hires an outside renovation firm, the landlord does not need to become a certified renovation firm just for that job. But the hired firm must be properly certified and must use a certified renovator who directs the work and gives on-the-job training to any non-certified workers.

One unusual edge case is worth knowing. If a tenant does the labor and receives no money, no rent credit, and no other compensation, EPA says the RRP rule does not apply to that work. Even then, owners should think carefully before allowing it. Separate lease duties, insurance rules, and state or local safety laws may still create risk.

Certification and training basics

For covered jobs, the firm matters and the person in charge matters.

The firm doing the work must be certified. EPA says that includes all firms, even sole proprietorships. In EPA-administered areas, firm certification or recertification costs $300 and is good for 5 years.

Each covered job must have a certified renovator assigned to it. To become a certified renovator, a person must complete an EPA-accredited initial course that lasts 8 hours and includes 2 hours of hands-on learning.

To stay certified, the renovator must take a refresher course before the current certification expires. EPA says the refresher is 4 hours, and hands-on learning is required every other refresher cycle. An online refresher gives a 3-year certification period, while a hands-on refresher gives a 5-year certification period.

Other workers on the job do not all have to hold renovator certificates, but they must either be certified renovators or receive documented on-the-job training from the certified renovator assigned to the project.

State rules can change the path. Some states run their own EPA-authorized RRP programs instead of EPA’s federal program, so the application process, fees, and paperwork can differ. If you work across state lines, you may need both EPA and state certification. Start with the site’s state-by-state pages and search your city, county or ZIP if you are checking local rental lead rules too.

What must happen before work starts

Before covered work begins in pre-1978 housing, the firm must give EPA’s Renovate Right pamphlet to the owner and occupants.

If the pamphlet is hand-delivered, it can be given anytime before the renovation begins, as long as the job starts within 60 days after delivery. If it is mailed, EPA requires mailing at least 7 days before the start of renovation.

In common areas of multi-family housing, the firm must either distribute renovation notices to tenants or post informational signs about the job. Those notices or signs must describe the nature, location, and dates of the renovation, and tenants must also get the pamphlet or information about how to get it for free.

Good records are part of compliance, not an extra. EPA requires firms to keep records for 3 years. That includes proof of pamphlet delivery, the renovator’s training records, worker training documentation, the renovator assignment, and other required job records.

This notice step is separate from local rental lead paperwork. If you are trying to sort out whether a rental also needs an inspection, certificate, or turnover testing, see Lead-safe certificates for rentals: who needs one and the Rental lead-safe check.

Lead-safe work practices during and after the job

The heart of the rule is safe setup, safe work, and safe cleanup.

Before work begins, the firm must contain the area so dust and debris do not leave the work area. Warning signs must be posted clearly, and EPA says they should be in the language of the occupants.

For interior work, common setup steps include removing or covering items, closing and covering ducts, closing doors and windows, and covering the floor with plastic at least 6 feet beyond the renovation area, or farther if needed to contain dust.

For exterior work, the rule requires closing all doors and windows within 20 feet of the renovation. Ground cover must extend at least 10 feet beyond the work area, or farther if needed to catch falling debris. If the property line is too close, the firm must use vertical containment or equivalent extra precautions.

EPA also bans certain practices during covered renovations. These include open-flame burning or torching of painted surfaces, high-speed paint removal tools such as sanding or grinding unless they have shrouds or containment and a HEPA vacuum attachment, and using a heat gun above 1100 degrees Fahrenheit on painted surfaces.

Cleanup is not optional. After the job, the firm must clean until no dust, debris, or residue remains. For interior jobs, EPA requires cleaning verification by the certified renovator. Dust testing is not automatically required by the federal RRP rule, but a contract or another federal, state, territorial, tribal, or local rule may require it. If you are sorting out that difference, see Lead dust clearance testing, explained.

How RRP fits with state and local rental lead laws

The RRP rule is a federal renovation rule. It is not the same thing as a rental lead-safe certificate, a lead inspection, a risk assessment, a clearance test, or a local rental license condition.

In some places, a landlord may fully follow the RRP rule and still have separate city, county, or state duties. Local laws may require turnover inspections, recurring lead-safe certificates, dust testing after work, tenant notices, or use of specifically licensed or certified professionals.

That is why it helps to treat RRP as one layer of compliance, not the whole picture. Use it alongside your leasing duties, local rental registration rules, and any state lead program requirements.

Because state and local lead rules can add extra steps, confirm the current requirements with the relevant official state lead program, health department, or local housing office before you start work.

Frequently asked questions

Does repainting always trigger the RRP rule?

No. EPA says painting is not considered renovation if the surface is not disturbed first. If there is no sanding, scraping, or similar prep that disturbs paint, the RRP rule does not apply. Once prep work starts disturbing painted surfaces, the rule may apply.

If I own the rental and do the work myself, do I still need certification?

Usually yes, if the job is covered. EPA says a landlord doing covered work in a pre-1978 rental is performing work for compensation because the activity is tied to rent income. In that situation, the landlord must have firm certification and must use, or be, a certified renovator.

If a tenant does the work for free, does the RRP rule apply?

Not under EPA’s rule, if the tenant receives no money, no rent credit, and no other compensation. But that does not make the arrangement risk-free. Other housing, safety, insurance, or local lead rules may still matter.

Does RRP compliance give me a rental lead-safe certificate?

No. RRP compliance and rental lead-safe certificates are different things. Depending on where the property is located, you may still need a separate local or state inspection, paperwork filing, dust test, or certificate before renting, re-renting, or renewing a unit.