A homeowner scrapes and repaints the windows of the pre-1978 house she owns and lives in, doing all the work herself. Under the federal RRP rule, she is
- not covered, because the work is not done for compensation
- covered, because the house was built before 1978
- covered, unless she first tests the paint for lead
- not covered, but only if no children under 6 live in the home
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A. not covered, because the work is not done for compensation
The rule applies to renovations performed for compensation. An owner working on her own owner-occupied home is not being paid, so she is outside the rule, although lead-safe practices are still strongly advised. The age of the house alone does not trigger the rule.
Reference: 40 CFR 745.82
Which statement best describes a renovation as the RRP rule uses the term?
- Any work that requires a building permit in a building built before 1978
- Work intended to permanently remove lead-based paint hazards
- Any repair that costs more than a set dollar amount
- Modifying an existing structure in a way that disturbs painted surfaces
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D. Modifying an existing structure in a way that disturbs painted surfaces
A renovation is the modification of an existing structure, or part of one, that disturbs painted surfaces. Work designed to permanently eliminate lead hazards is abatement, which is regulated separately and is excluded from the definition.
Reference: 40 CFR 745.83 (definitions)
Under federal rules, paint is lead-based paint when it contains lead at or above
- 0.1 mg/cm2 or 0.05 percent by weight
- 0.5 mg/cm2 or 1.0 percent by weight
- 1.0 mg/cm2 or 0.5 percent by weight
- 5.0 mg/cm2 or 0.5 percent by weight
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C. 1.0 mg/cm2 or 0.5 percent by weight
The federal definition is 1.0 milligram per square centimeter or 0.5 percent by weight. The choice that swaps the two numbers is the classic trap.
Reference: 40 CFR 745.83; 40 CFR 745.103