EPA's Renovation, Repair, and Painting Rule

The EPA Renovation, Repair, and Painting (RRP) Rule is the most important federal lead regulation since the HUD Lead-Safe Housing Rule a decade ago. It has the potential to ensure the widespread use of lead-safe work practices in homes and child-occupied facilities and may be extended to public and commercial buildings in the future.

Congress adopted the Residential Lead-Based Paint Hazard Reduction Act in 1992. It amended the Toxic Substances Control Act to add a Title IV on Lead Exposure Reduction. Section 402(c)(3) of TSCA (15 U.S.C. 2682(c)(3) required that EPA adopts regulations on or before October 28, 1996 for renovation or remodeling activities in target housing, public buildings constructed before 1978, and commercial buildings that create lead-based paint hazards.
   
On April 22, 2008, EPA published the Renovation, Repair, and Painting (RRP) Rule to fulfill this mandate. Since then, EPA has amendmed the rule two times: The first was a technical amendment that did not change the substance of the rule, and the other established fees for training providers and renovation firms. 
 
Shortly after the rule was filed, several parties challenged the rule in the federal court of appeals. On August 23, 2009, the public interest petitioners reached a settlement with EPA. EPA agreed to propose a series of four rulemakings to address the concerns and to make final decisions on the proposed changes according to a specific schedule covering six years. The industry petitioner withdrew the petition voluntarily in October, 2009. On September 7, 2012, the public interest petitioners and EPA revised the settlement agreement to combine the rulemakings on the interiors and exteriors of public and commercial buildings.

In August 2009, several public interest groups petitioned EPA to revise its regulatory definitions of lead-based paint and lead-based paint hazards.  EPA accepted the petition on October 22, 2009 effectively committing it to additional rulemaking.

For the latest word on EPA's rulemakings, go to www.epa.gov/lead/pubs/regulation.htm. Sometimes EPA's rulemakings are difficult to track.

Tracking the Rulemaking

Archived Comments on EPA's RRP Policy

Comment addressing the issue of clearance testing requirements (submitted August 6, 2010) [PDF]

Letter to EPA from the NCHH and NAHB Regarding Implementation of the Lead Renovation Remodeling and Painting Rule (submitted March 12, 2010) [PDF]

Letter to EPA to add the Renovation, Repair, and Painting rule to EPA's list of Candidate National Enforcement and Compliance Assurance Priorites (submitted January 15, 2010) [PDF]

National Health and Housing Groups Urge EPA to Issue Long Overdue Regulation to Protect Children from Lead Poisoning - Call on EPA to Ensure Safe Renovations 

In a letter to administrator Stephen Johnson, national organizations call upon EPA to immediately finalize the Lead Renovation, Remodeling, and Repainting Rule. [PDF]

NCHH and the Alliance for Healthy Homes submit comments on two new studies related to the Lead Renovation, Remodeling, and Repainting Rule.  [PDF]

The first comment, addressing the issue of clearance (submitted March 16, 2006) [PDF]  

The second comment, addressing the issue of dangerous work practices (submitted March 24, 2006) [PDF]

The third comment, addressing the issue of clearance for carpets (submitted March 31, 2006) [PDF] 

The fourth comment, addressing EPA's Economic Analysis (submitted April 24, 2006) [PDF]

The fifth comment, addressing EPA's Lead Renovation, Repair, and Painting Program (submitted July 5, 2007)

Frequently-asked questions regarding the EPA requirements for safe renovation, remodeling, and painting in pre-1978 housing and child-occupied facilities [PDF]

Proposed legislative actions to address shortcomings in EPA's Renovation, Repair, and Painting Regulation [PDF]

EPA's Lead Renovation, Repair, and Painting Program (EPA–HQ–OPPT–2005–0049; FRL–8355–7; RIN 2070–AC83) Final Rule [PDF]