Lead Safe Renovation, Repair, and Painting

Renovations that disturb lead paint can poison family members, visitors, and neighbors. To keep properties safe from lead hazards, Rhode Island's Renovation, Repair, and Painting Rule requires contractors, painters, and other workers doing renovation, repair, or painting on pre-1978 homes or child care facilities (including day cares, preschools, and elementary schools) to work for licensed Lead Renovation Firms.

Regulated People and Activities

Rhode Island's RRP Rule applies to contractors, landlords, property managers, homeowners, and anyone else who disturbs painted surfaces on pre-1978 homes or child care facilities. This includes general contractors as well as special trade contractors, such as painters, plumbers, carpenters, and electricians.

In general, the RRP Rule applies to any renovation, repair, or painting that disturbs six square feet or more of paint per room on the interior or 20 square feet or more of paint on the exterior of a pre-1978 house or child care facility. Examples of regulated activities include window replacement, remodeling, repair/maintenance, electrical work, plumbing, painting, carpentry, and interior demolition. Not all projects are regulated by the Renovation, Repair, and Painting Rule.

In addition, the RRP Rule applies to window replacement and interim controls designed to reduce exposure to lead hazards (lead hazard control).  A clearance inspection by a licensed Lead Inspector, which includes interior dust wipe sampling, is required to obtain an inspection report documenting the lead hazard control and a lead certificate.

Rhode Island Rule

In 2010, Rhode Island was granted delegation of authority by the Environmental Protection Agency to administer its own Renovation, Repair, and Painting program.

  • Rhode Island's regulations differ from the federal Renovation, Repair, and Painting Rule in a few key ways:
    • Parents with children younger than six years of age must use a licensed Lead Renovation Firm.
    • The Lead Renovation Firm must submit a Start Work Notification to the Department of Health at least seven days before beginning work that includes window replacement, interior mechanical paint removal, interior demolition, or work intended to correct lead hazards (lead hazard control).
    • A certified Lead Renovator must always be on site
    • When the lead hazard control work is complete, a clearance inspection by a Rhode Island licensed Lead Inspector is required. The clearance inspection must include dust wipe samples analyzed by an approved laboratory. Once acceptable dust levels are achieved, the inspector can issue a Partial Lead Safe Certificate.
  • Exemptions
    • Housing built after 1978 and any housing with a Certification of Lead-Free Status or Full Lead-Safe Certificate issued  by a Rhode Island licensed Lead Inspector is generally exempt from Rhode Island's Renovation, Repair, and Painting Rule.
    • Other exemptions include housing for elderly or disabled persons, studio apartments, and dormitories. These buildings are regulated if a child younger than six years old resides there, or is expected to reside there, for more than two weeks per year.

Requirements

Training

Contractors, painters, and other workers must complete an eight-hour Lead Renovator training course certified by the Department of HealthFind

Licensing

Once training is complete, an individual is a certified Lead Renovator. All   certified Lead Renovators must work for licensed Lead Renovation Firms. Firms must renew their licenses every five years after completing a four-hour refresher course. Renovators who take an online review training will be certified for three years, and renovators who take an in-person review course with hands-on training will be certified for five years. On-line training is allowed for every other recertification.  more information on training

Start Work & Pre-Renovation Notification

The firm must deliver a copy of the Rhode Island version of the Renovate Right pamphlet to property owners and tenants no more than 60 days and no less than seven days before work begins. The firm must fill out the Pre-Renovation Education form at the back of the pamphlet, have it signed, and keep it for a minimum of three years. At least seven calendar days before beginning a job, the firm must submit a Start Work Notification to the Department of Health for work that includes window replacement, interior mechanical paint removal, interior demolition, or lead hazard control activities.

Lead-Safe Work Practices

While work is being performed, certified Lead Renovators  and their workers must:

  • Contain the work area to prevent dust and debris from escaping.
  • Refrain from using work methods that generate large amounts of lead-contaminated dust. Dry sweeping, using heat guns at temperatures above 1100°F, open flame burning, and using flammable or methylene chloride paint strippers are prohibited.

When work is complete, Lead Renovators and their workers must:

  • Clean dust and debris using a HEPA vacuum and wet mops.
  • Perform the EPA Cleaning Verification Procedure https://www.epa.gov/compliance/inspection-manual-lead-renovation-repair-and-painting-rule or have a licensed Lead Inspector conduct a clearance inspection.
  • Remove containment barriers upon notification that the dust wipes passed clearance or the cleaning verification was done.
  • Provide the owner with the completed Renovation Recordkeeping Checklist.