Official State of Rhode Island website

State of Rhode Island Department of Health

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 (RRP) Rule requires contractors, painters, and other workers to do renovation, repair, or painting on pre-1978 homes or childcare facilities (including daycares, preschools, and elementary schools) to work for licensed Lead Renovation Firms. 

What is RRP?

The purpose of an RRP project is to perform renovations, repairs, painting, and related construction work for reasons other than correcting environmental lead hazards. These projects may disturb lead paint but do not aim to fix lead hazards or remove lead paint. For example, window or door replacement, cabinet replacement, demolition work, or plumbing work that requires cutting a hole in the wall are considered RRP work. 
Rhode Island's RRP Rule applies to 

  • Contractors
  • Landlords
  • Property managers
  • Homeowners,
  • General contractors
  • Special trade contractors (ex: painters, plumbers, carpenters, and electricians)

 
And anyone else who disturbs painted surfaces in pre-1978 homes or childcare facilities.  

In general, the RRP Rule applies to any renovation, repair, or painting that disturbs 6 square feet or more of paint per room on the interior or 20 square feet or more of paint on the exterior, involves window removal/replacement, interior mechanical paint removal, interior demolition activities and interim controls designed to reduce exposure to lead hazards (lead hazard control). A licensed Lead Inspector's clearance inspection, including interior dust wipe sampling, is required to obtain an inspection report documenting the lead hazard control and a lead certificate. 

The Renovation, Repair, and Painting Rule does not regulate all projects.  
The RRP Rule does not cover the following projects.

  • Disturbing painted surfaces that do not contain lead-based paint
  • Spot removal or minor repair and maintenance activities that disturb less than 6 square feet (6 ft2) of lead-based paint per interior room,
  • Spot removal or minor repair and maintenance activities that disturb less than 20 square feet (20 ft2) of exterior lead-based paint

For specific requirements for different types of work, please refer to the Rhode Island Regulations.  

Rhode Island Rule

In 2010, the Environmental Protection Agency granted Rhode Island authority 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 6 must use a licensed Lead Renovation Firm.
  • The Lead Renovation Firm must submit a Start Work Notification to the Department of Health at least 7 days before beginning work, including 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 6 resides there or is expected to reside there for more than 2 weeks per year.

Requirements

Training

Contractors, painters, and other workers who wish to be certified in RRP must complete an 8-hour Lead Renovator training course approved by the Department of Health.

The 8-hour Initial Lead Renovator (RRP) training providers are here.

Licensing

Once training is complete, an individual is a certified Lead Renovator. All certified Lead Renovators must work for licensed Lead Renovation Firms. Anyone who completes the Lead Renovator certification can apply to be a Lead Renovation Firm by filling out the application and paying the $100 licensing fee. The license is suitable for 5 years. 

Firms must renew their licenses every five years after completing a four-hour refresher course. Renovators who take 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 5 years. 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 7 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 at least 3 years. At least 7 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 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… 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.

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