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

4-1. Important Terms
The RRP Rule introduces new regulatory terms, and substantively modifies existing ones. “Renovation” and
“child-occupied facility” are seminal terms. (Other terms are discussed below in the context within which
they appear in the rule.)
“Renovation”
“Renovation” means “modification of any existing structure, or portion thereof, that results in the
disturbance of painted surfaces” unless part of an abatement. 293
The RRP Rule and PRE Rule cover a “virtually identical” universe of activities, 294 except for a change in the
exclusion for “minor” activities (explained below). To clarify the broad reach of the new rule, 295 however,
EPA has provided a more extensive illustration of covered projects. See Fig. 10: Comparison: Definition of
“Renovation.” Therefore, the term “renovation” explicitly includes:
• Removal, modification, and repair of painted surfaces or components 296 (e.g., modification of painted
doors; and dust-generating surface preparation, such as sanding and scraping);
• Removal of “building components,” such as walls, ceilings, plumbing, windows;
• Window repair;
• Surface restoration;
• Weatherization projects (e.g., cutting holes to blow-in insulation or access attics; planing thresholds for
weather-stripping);
• Renovation to convert a building (or part thereof) into target housing or a COF; and
• “Interim controls that disturb painted surfaces.” 297
“Interim controls” are “measures designed to temporarily reduce human exposure or likely
exposure” to LBP hazards, including “specialized cleaning, repairs, maintenance, painting,
temporary containment, ongoing monitoring” of LBP hazards or potential hazards, and “resident
education programs.” 298
“Renovation” excludes “minor repair and maintenance activities” 299 (sometimes called the “de minimis
exception”).
“Minor” activities mean those which:
• Disrupt a painted surface of six square feet or less (