B. Federal Lead-Based Paint Enforcement Bench Book - National ...

The RRP Rule does not modify TSCA’s Lead Hazard Standard, the Disclosure Rule, the Lead Safe Housing
Rule, 290 or RCRA Section 7003. 291
The final RRP Rule was published as only amendments to the pre-existing regulations. Pending
publication of the updated Code of Federal Regulations, the National Center for Healthy Housing
produced an unofficial version of the full, revised regulations.
www.centerforhealthyhousing.org/html/eparule.htm.
EPA attempted to “harmonize” the RRP Rule with the pre-existing requirements of the PRE Rule. 292 The
RRP Rule, however, both amends the PRE rule and adds significantly to it (making the PRE Rule a
component of the new rule). For example, the RRP Rule:
• Applies PRE (and other requirements) to renovations in COFs, as well as in target housing;
• Imposes work practice standards for renovations;
• Creates two new disciplines, renovators and DST, and requires certification for each;
• Requires certification for renovation firms;
• Provides new PRE options for renovations in common areas; and
• Adds new notification and recordkeeping requirements.
§ 745.320, § 745.324, § 745.326, § 745.327, § 745.339. See also section III.D, above.
290 Some of HUD’s interim controls are regulated under the RRP Rule as renovations. In most cases, the HUD regulations are
comparable to or more stringent than the RRP Rule. The RRP Rule, however, does not require dust clearance testing, which
may be required by HUD after interim control activities. 73 Fed. Reg. 21692, 21753, supra note 160. The RRP Rule allows
clearance testing in lieu of post-renovation cleaning verification provided the testing comports with RRP Rule requirements.
40 C.F.R. § 745.85(c). See section III.F.4-5, below.
291 The RRP Rule does not affect the disposal of waste from renovation projects, which is regulated as solid waste under
RCRA. 73 Fed. Reg. 21692, 21753, supra note 160. See also, Part I.B of this book, Resource Conservation and Recovery Act –
Waste from Residential Lead-Based Paint Renovations and Abatements.
292 73 Fed. Reg. 21692, 21753, supra note 160.
38 FEDERAL LEAD-SAFE PAINT ENFORCEMENT BENCHBOOK