🛠️ Renovation, Repair, and Painting (RRP) Rule & Contractor Guidance

If you plan to disturb painted surfaces in a home built before 1978, it's critical to ensure the work is performed by a contractor certified under the EPA’s Renovation, Repair, and Painting (RRP) Rule.

The RRP Rule requires that anyone conducting renovation, repair, or painting activities that may disturb lead-based paint in residential properties, child-occupied facilities, or schools must be trained and certified in lead-safe work practices.

✅ Why Use an RRP-Certified Contractor?

• Health Protection: Certified contractors follow lead-safe practices that minimize the release of hazardous lead dust during work.
• Legal Compliance: Federal law requires RRP certification for most renovation or repair work that disturbs painted surfaces in pre-1978 homes.
• Proper Containment: Certified professionals are trained to isolate work areas, use appropriate personal protective equipment (PPE), and conduct proper cleanup.
• Documentation: RRP contractors provide required notices and maintain compliance records for regulatory purposes.

🧾 Common Projects That May Require RRP Practices:

• Window replacement or repair
• Door installation
• Sanding, scraping, or grinding painted surfaces
• Demolition of walls, trim, or ceilings
• HVAC, plumbing, or electrical work disturbing painted components

🔍 How to Find an RRP-Certified Firm:

You can search the EPA’s database of certified renovation firms at:
www.epa.gov/lead/rrp
Or call the National Lead Information Center at 1-800-424-LEAD (5323)

Recommendation: Always ask for the contractor’s RRP certificate and ensure that lead-safe practices are followed before work begins. Even minor repairs can release dangerous amounts of lead dust if not handled correctly.

Encapsulation is a method of controlling lead-based paint hazards by applying a specially formulated, durable coating over the existing painted surface. This coating acts as a seal, preventing lead dust or chips from being released into the environment. Encapsulation is typically used on surfaces that are in good condition and are not subject to frequent wear or disturbance.

⚠️ Important: Regular paint is not considered an encapsulant. Encapsulants are specific products designed, tested, and approved for lead hazard control.

✅ Advantages of Encapsulation:

• Minimally invasive: Application usually generates little to no dust.
• Cost-effective: Often less expensive than other abatement methods.
• Fast: Can typically be completed more quickly than removal or replacement.

⚠️ Disadvantages and Considerations:

• Not a permanent solution: The lead-based paint remains underneath and can still pose a risk if disturbed.
• Surface prep is critical: Failure is more likely if the surface is not properly cleaned or repaired beforehand.
• Not suitable for all surfaces: Encapsulants may fail on deteriorated, chalky, or uneven materials.
• Ongoing maintenance is required: Surfaces must be routinely inspected for signs of damage, peeling, or failure.
• Can complicate future renovations: Any disturbance of encapsulated areas may require full lead-safe work practices.

🚫 Surfaces Where Encapsulation Should Not Be Used:

Encapsulation is not recommended on “friction” or high-profile surfaces that experience repeated movement or contact, such as:

• Window jambs, sashes, glides, or parting beads
• Door jambs and stops that experience contact
• Stair treads, floors, and thresholds

These surfaces are prone to wear and may compromise the integrity of the encapsulant, increasing the risk of lead exposure.

Enclosure is a method of lead hazard control in which the lead-painted surface is covered with a durable, non-lead material to prevent exposure. This technique seals the lead-based paint beneath a physical barrier, such as drywall, paneling, aluminum, or vinyl cladding, without disturbing the original paint surface.

✅ Advantages of Enclosure:

• Quick and effective: Provides an immediate barrier between occupants and lead-based paint.
• Less dust: Generates minimal lead dust during installation compared to removal methods.
• Cost-effective: Typically less expensive than full removal or component replacement.

⚠️ Disadvantages and Considerations:

• Lead is still present underneath: If the enclosure is damaged or removed in the future, exposure risk returns.
• Proper installation is critical: Gaps, breaks, or poor sealing can allow dust to escape or render the enclosure ineffective.
• Not suitable for deteriorated surfaces: The underlying paint must be intact and stable before enclosure is applied.
• May complicate future renovations: Enclosed areas must be treated as lead-containing during any future work.

🛠️ Common Materials Used for Enclosure:

• Gypsum board (drywall)
• Aluminum or vinyl siding (for exteriors)
• Wood paneling or composite sheeting
• Prefinished panel systems

Note: Enclosure is best suited for large flat surfaces such as walls and ceilings. It is generally not recommended for components like windows or friction surfaces where wear and movement occur.

Replacement involves the complete removal and substitution of building components that contain lead-based paint. Rather than treating or covering the painted surface, the component itself — such as a window, door, trim, or cabinet — is fully removed and replaced with a new, lead-free item.

This method is considered a permanent abatement strategy, as it completely eliminates the source of lead.

✅ Advantages of Replacement:

• Permanent removal of lead hazards – Eliminates the painted surface entirely, reducing long-term risk.
• No need for monitoring or future maintenance – Unlike encapsulation or enclosure, no ongoing inspection is required.
• Improves energy efficiency and performance – New windows, doors, and building materials often enhance home function.

⚠️ Disadvantages and Considerations:

• Higher upfront cost – Replacement typically requires skilled labor and material purchase, making it one of the most expensive abatement methods.
• May require permits or code compliance updates – Especially when replacing windows, doors, or exterior finishes.
• Lead dust exposure during removal – Old components can still release hazardous dust during demolition and must be handled with lead-safe work practices.

🔧 Commonly Replaced Components:

• Windows and window sashes
• Doors and door trim
• Baseboards and crown molding
• Kitchen cabinets or built-ins
• Stair treads and risers
• Exterior siding or soffit panels

Note: Replacement should always be performed by qualified personnel using EPA RRP-compliant methods, especially during demolition and disposal of lead-containing components.

Clearance testing is performed after lead hazard control or renovation activities to ensure that lead dust levels have been reduced to safe levels before the space is reoccupied. It is a critical step in verifying the effectiveness of cleanup procedures following any work that disturbed lead-based paint.

Clearance is typically required after:

• Lead abatement projects
• Certain EPA RRP projects in regulated settings (e.g., child-occupied facilities, HUD housing)
• Local or state-mandated work
• Voluntary hazard control efforts (e.g., home renovations involving LBP)

🔍 What Clearance Testing Involves:

• A visual inspection of the work area to ensure there is no visible dust, paint chips, or debris
• Dust wipe sampling of floors, windowsills, and troughs using standardized procedures
• Laboratory analysis of the samples to determine if lead dust levels are below EPA/HUD action thresholds
• A written report detailing findings and certifying clearance if results meet acceptable limits

✅ Why Clearance Matters:

• Confirms that the home is safe for reoccupancy
• Provides peace of mind for homeowners, tenants, and property managers
• Documents compliance with federal, state, or local regulations
• Prevents unnecessary liability for contractors or landlords

Important: Clearance testing should be performed by a certified lead risk assessor or inspector, who is independent of the company performing the renovation or abatement.

Even when lead-based paint is intact and undisturbed, ongoing monitoring is essential to ensure it does not become a hazard over time. Environmental conditions, daily use, and aging materials can cause paint to deteriorate, especially in older homes.

Homeowners and property managers should inspect painted surfaces regularly — at least every 6 months — and immediately after any event that might damage painted components (e.g., leaks, repairs, tenant turnover).

🧾 What to Look For:

• Chipping, peeling, or flaking paint
• Friction damage on windows, doors, stairs, or floors
• Water stains or moisture around painted areas (especially ceilings, trim, and baseboards)
• Dust or paint debris collecting on floors, windowsills, or other surfaces
• Evidence of prior encapsulant failure (bubbling, separation, cracking)

🛠️ Maintenance Tips:

• Clean surfaces regularly with wet methods (damp cloths and HEPA vacuums) to control lead dust
• Use mild detergent, not abrasive cleaners, on painted surfaces
• Avoid dry sweeping, sanding, or scraping painted areas unless proper containment and lead-safe work practices are used
• Address any signs of deterioration immediately using EPA-compliant repair methods
• Document all repairs and inspections to show responsible lead hazard management, especially for rental properties

Tip: Landlords and property owners should consider incorporating lead paint checks into their regular maintenance or tenant turnover process.

Lead dust is one of the most common sources of lead exposure in homes — especially for children. It can accumulate on floors, windowsills, and other surfaces even when paint appears intact. Routine cleaning using lead-safe techniques helps reduce the risk of exposure.

✅ Safe Cleaning Methods:

• Wet Wipe Surfaces:
  Clean hard surfaces (floors, baseboards, windowsills) using disposable cloths, warm water, and a mild detergent. Avoid dry dusting.
• Use a HEPA Vacuum:
  Vacuum carpets, rugs, and hard surfaces using a HEPA-filter vacuum designed to trap fine lead particles. Standard vacuums are not effective and may spread dust.
• Mop Floors Regularly:
  Use two buckets — one for soapy water, one for rinsing — and replace water frequently. Avoid sponge mops that can push dust into corners.
• Focus on High-Risk Areas:
  Clean window troughs, entryways, stair treads, and play areas frequently, as these areas tend to collect dust and debris.
• Dispose of Waste Properly:
  Wash or discard cloths and gloves after use. Do not shake dust rags or vacuum bags inside the home.

🚫 What to Avoid:

• Dry sweeping or vacuuming with standard equipment
• Power sanding or grinding painted surfaces without proper containment
• Using bleach or abrasive cleaners (they don’t remove lead effectively)

Tip: Homes with small children should be cleaned using lead-safe methods weekly, especially if they crawl on floors or place objects in their mouths.

Lead exposure can cause serious health problems, especially in children under 6 years old, pregnant individuals, and developing fetuses. Even low levels of lead can affect brain development and cause lifelong learning, behavioral, and physical issues.

⚠️ Health Effects of Lead Exposure:

In Children:

• Learning and developmental delays
• Lower IQ and attention problems
• Speech and language delays
• Behavioral issues (hyperactivity, impulsiveness)
• Poor coordination or slowed growth

In Adults:

• High blood pressure
• Memory or concentration problems
• Reproductive issues
• Nerve disorders or joint/muscle pain

🧪 Blood Lead Testing:

If lead-based paint is present in the home — or if a child has been exposed to dust or debris from renovation or deterioration — a simple blood test can screen for lead exposure. Testing is especially recommended for:

• Children under 6 living in or visiting older homes
• Families who have recently done renovations
• Tenants in pre-1978 rental properties with suspected lead hazards

📍 Where to Get Tested:

• Contact your pediatrician or family doctor
• Reach out to the New Mexico Department of Health Lead Program:
  https://www.nmhealth.org/about/erd/eheb/lead/
• Call the CDC Lead Information Line: 1-800-CDC-INFO (1-800-232-4636)

Tip: Blood lead testing is typically covered by health insurance and may be offered free of charge through public health clinics.