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RRP Rule:  Lead-Safe Work Practices Requirements

Work Practices Requirements ensure that the dangerous lead chips and lead-containing dust generated by your work do not contaminate living and other areas where they can cause damage to human health, especially in children.

• Work-area containment to prevent dust and debris from leaving the work area

• Prohibit certain work practices like open-flame burning and the use of power tools without HEPA exhaust control
• Thorough clean up followed by a verification procedure to minimize exposure to lead-based paint hazards.

All renovations must be performed by certified firms using certified renovators.  Firms must post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area.  These signs should be in the language of the occupants. 

• Prior to the renovation, the firm must contain the work area so that no dust or debris leaves the work area while the renovation is being performed. 
• Work practices listed below are prohibited during a renovation: 
• Open-flame burning or torching of painted surfaces; 
• Use of machines that remove paint or other surface coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, unless such machines have shrouds or containment systems and are equipped with a HEPA (HEPA means high-efficiency particle accumulator) vacuum attachment to collect dust and debris at the point of generation. Machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system; and 
• Operating a heat gun on painted surfaces at temperatures above 1100 degrees Fahrenheit. 
• Waste from renovations: 
• Waste from renovation activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal. 
• At the conclusion of each workday and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored to prevent access to and the release of dust and debris.
• Waste transported from renovation activities must be contained to prevent release of dust and debris.

For all interior renovations, these additional steps must be followed.  The firm must: 

1. Remove all objects from the work area or cover them with plastic sheeting with all seams and edges sealed.
2. Close and cover all ducts opening in the work area with taped-down plastic sheeting. 
3. Close windows and doors in the work area. Doors must be covered with plastic sheeting.
4. Cover the floor surface with taped-down plastic sheeting in the work area a minimum of six feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater. If a vertical containment system is employed, floor covering may stop at the vertical barrier, providing it is impermeable, extends from floor to ceiling, and is tightly sealed at floors, ceilings, and walls.
5. Use precautions to ensure that all personnel, tools, and other items, including the exteriors of containers of waste, are free of dust and debris when leaving the work area.
6. After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains. The firm must: 
1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
2. Remove and dispose of protective sheeting as waste.
3. Clean all objects and surfaces in the work area and within two feet of the work area in the following manner: 
   • Clean walls starting at the ceiling and working down to the floor by either vacuuming with a HEPA vacuum or wiping with a damp cloth. 
   • Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum. 
   • Wipe all remaining surfaces and objects in the work area, except for carpeted or upholstered surfaces, with a damp cloth. Mop uncarpeted floors thoroughly using a mopping method that keeps the wash water separate from the rinse water, or using a wet mopping system.
7. Perform a Post-renovation Cleaning Verification of the interior work areas:
1. Certified renovator must perform a visual inspection. If dust, debris or residue are present, the area must be recleaned.
2. If the contract or other regulation requires a clearance testing, see the instructions in the Small Entity Compliance Guide to Renovate Right, Flow Chart 6. https://www.epa.gov/sites/production/files/2020-03/documents/small_entity_guide_9-23-11_w_new_cover.pdf
3. Certified renovator must wipe all uncarpeted floors, countertops, and windowsills within the work area with a wet disposable cleaning cloth.  Use a new disposable cleaning cloth for each section of 40 square feet.  Check and reclean any areas needing it—see instructions in the Small Entity Compliance Guide to Renovate Right, Flow Chart 7. https://www.epa.gov/sites/production/files/2020-03/documents/small_entity_guide_9-23-11_w_new_cover.pdf

For all exterior renovations, these additional steps must be followed.  (See the details in the Small Entity Compliance Guide to Renovate Right, Flow Chart 8. https://www.epa.gov/sites/production/files/2020-03/documents/small_entity_guide_9-23-11_w_new_cover.pdf)  The firm must:

1. Close all doors and windows within 20 feet of the renovation.
2. Ensure that doors within the work area that will be used while the job is being performed are covered with plastic sheeting in a manner that allows workers to pass through while confining dust and debris.
3. Cover the ground with plastic sheeting or other disposable impermeable material extending a minimum of 10 feet beyond the perimeter or a sufficient distance to collect falling paint debris, whichever is greater. If a property line prevents 10 feet of such ground covering, then erect vertical containment or equivalent extra precautions to prevent contamination of adjacent buildings and property.
4.  In situations such as where work areas are in close proximity to other buildings, windy conditions, etc., the renovation firm must take extra precautions in containing the work area, like vertical containment.
5. After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains. The firm must:
1. Collect all paint chips and debris, and seal it in a heavy-duty bag.
2. Remove and dispose of protective sheeting as waste.
3. Waste transported from renovation activities must be contained to prevent release of dust and debris.
6. A certified renovator must perform a visual inspection.  If dust, debris or residue are present, these must be eliminated and another visual inspection must be performed.  Once the area has been adequately cleaned; remove the warning signs.

Be sure to document your work practices and post-renovation cleaning and verification and retain these records for three years after the job has been completed.  See details of these requirements on the recordkeeping page.

You can find the regulatory language for the RRP Rule work practices requirements at 40CFR§745.85.

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