Jenkins Academy of Applied Technology

LEAD-001-EPA — Learner reference

Lead — OSHA and EPA Residential Requirements · v1.0.0 · October 22, 2026

Course developed by Todd Jerome Jenkins, MS, CSP.

Understand federal EPA residential lead requirements: RRP applicability, certification boundaries, occupant notices, containment, cleaning, current dust criteria, records and sale/rental disclosures. Twelve audible lessons; allow about 50–65 minutes.

Requirements-awareness course only. This is not EPA-accredited renovator initial/refresher training and awards no EPA firm or individual certification. Actual accredited training, certified-renovator job instruction, qualified testing and jurisdiction-specific implementation remain required.

1. Identify covered residential work

By the end: Determine whether RRP applies and which program administers it.

EPA’s Renovation, Repair and Painting rule, or RRP, protects occupants and the public from lead-based paint dust created by renovation. It generally applies to renovation performed for compensation in target housing and child-occupied facilities built before 1978. Contractors, sole proprietors, rental-property maintenance operations and other covered firms must evaluate their work before advertising or starting it.

Target housing generally means pre-1978 housing, with defined exceptions for housing for elderly people or people with disabilities and zero-bedroom dwellings unless a child under six resides or is expected to reside there. Do not use an outdated blanket zero-bedroom exemption. Absence of a child in an ordinary pre-1978 house does not create an owner opt-out.

A child-occupied facility is a pre-1978 building or portion regularly visited by the same child under six on at least two days in a week, for at least three hours each day, six hours per week and sixty hours per year. It can be in a public or commercial building. Evaluate the defined child-used common areas and adjacent exterior surfaces; not every commercial building is automatically covered.

Determine whether EPA or an EPA-authorized state or Tribal program administers the work location. Certification and additional requirements must be checked for that jurisdiction. HUD-assisted housing and state or local rules may add protection beyond federal RRP. Record the actual address, building age, use, work and program before deciding an exception applies.

This is requirements-awareness training, not an EPA-accredited initial or refresher course. It does not certify a renovator, dust-sampling technician, inspector, risk assessor, abatement worker or firm. OSHA worker protection remains a separate obligation; the companion OSHA Lead tracks address it.

Basis: 40 CFR Part 745, Subpart E; 745.103

2. Evaluate testing and minor-repair exceptions

By the end: Apply component evidence and disturbance limits without creating false exemptions.

RRP does not require paint testing before every renovation. Without valid documentation that affected components are free of lead-based paint, apply the rule where otherwise covered. A homeowner’s unverified statement or a consumer test performed by an unqualified person is not the required determination.

A certified inspector or risk assessor can make the specified written determination. A certified renovator can use an EPA-recognized test kit according to its instructions, or collect paint-chip samples for an EPA-recognized laboratory. Testing must address the affected components, with the rule’s limited integrated-component provisions. Keep the exact locations, method and results.

For this determination, lead-based paint is at least 1.0 milligram per square centimeter or 0.5 percent by weight. These are material criteria, not an OSHA exposure exemption. Paint below this definition can still create an occupational lead hazard. A paint result also does not establish dust clearance or certify the entire property lead-free.

Minor repair and maintenance can be excluded when disturbance is six square feet or less per room indoors, or twenty square feet or less outdoors, and no prohibited or restricted practice, window replacement or demolition of painted surfaces is involved. Count the entire removed painted component area, not just the cut line. Nonemergency jobs in the same room within thirty days are one job for this calculation.

Window replacement and demolition of painted surfaces do not qualify for the minor-repair exception merely because the disturbed area is small. Do not split a job into several invoices to evade the threshold. If scope expands or new components are affected, stop and reevaluate coverage, testing, notices and controls.

Basis: 40 CFR 745.82–745.83

3. Verify firm and renovator qualifications

By the end: Distinguish accredited certification from supplemental awareness.

Covered firms need current certification from EPA or the applicable authorized program. A firm cannot advertise, offer or perform covered renovation without it. A sole proprietor may need both firm certification and individual renovator certification; one does not replace the other. Verify certificates and expiration dates before accepting regulated work.

Assign a certified renovator to every covered renovation. Other workers must either be certified renovators or receive documented on-the-job instruction from a certified renovator on the lead-safe practices used for their assigned tasks. This Academy course can support knowledge, but it does not replace that job-specific instruction or accredited certification.

EPA initial renovator certification training is eight hours and includes two hours of hands-on learning through an accredited provider. The accredited course certificate is the individual’s credential. This twelve-lesson awareness course is not that training, regardless of quiz score or time spent. Use EPA’s accredited-provider locator for the required course.

Under EPA’s program, renovator refresher training must occur before certification expires. A hands-on refresher supports five-year certification; a refresher without hands-on training supports three years and must be followed next time by a hands-on refresher. Expired certification generally requires retaking the initial course. Check the actual certificate and jurisdiction rather than assuming every credential lasts five years.

The certified renovator must be physically present when warning signs are posted, containment is established and work-area cleaning is performed. They regularly direct other workers, remain available on-site or by telephone throughout renovation, and personally perform required cleaning verification. Copies of the initial and most recent refresher certificates must be available with them at the worksite.

Basis: 40 CFR 745.81, 745.89–745.90

4. Provide the right pre-renovation information

By the end: Use Renovate Right and document delivery to the appropriate people.

For covered dwelling-unit work, provide the current EPA Renovate Right pamphlet to the owner no more than sixty days before renovation begins. Obtain written acknowledgment or the specified certificate of mailing at least seven days before work. The delivery record should identify the property, recipient, date and method.

If the owner does not occupy the unit, also provide the pamphlet to an adult occupant. Obtain acknowledgment, or use the specified written certification of delivery when an adult acknowledgment cannot be obtained, or the mailing route. The refusal/unavailability record needs the required details and signature; it is not permission to skip delivery to the owner.

For common-area work in multiunit target housing, provide the owner information and notify affected units using the permitted written-notice or posted-information process. Explain the work location, nature, dates and how to obtain the pamphlet and compliance records without cost. Prepare a signed, dated statement of notification steps. Update written notices before work expands beyond the original notified scope.

For a child-occupied facility, notify the owner and, if different, its adult representative. Also provide the required information to parents and guardians through the permitted delivery or posted-information route, and document those steps. The rule has specific recipient and acknowledgment requirements; telling the building manager alone may be insufficient.

Renovate Right serves renovation education. Protect Your Family From Lead In Your Home serves sale/rental disclosure. They are not interchangeable obligations. Plan delivery early so a scheduled start does not pressure the firm to ignore the required notice or mailing interval.

Basis: 40 CFR 745.84

5. Contain interior renovation dust

By the end: Recognize the required interior setup and protect emergency egress.

Before work, post warning signs defining the work area and warning occupants and others to remain outside. Use the occupants’ primary language to the extent practicable. Keep signs in place and readable until the required cleaning verification is complete. Explain safe alternate routes rather than allowing occupants through contaminated work.

Remove furniture, rugs, window coverings and other objects from the area, or cover them with impermeable material and seal seams and edges. Close and cover ducts opening into the work area. Close windows and doors; cover doors with impermeable barriers, including a suitable entry arrangement that permits passage while containing dust.

Cover floors, including installed carpet, with taped-down plastic or another impermeable material at least six feet beyond the perimeter of surfaces being renovated, or farther if needed to contain dust. With a properly sealed floor-to-ceiling vertical containment system, floor protection may stop at that barrier. The distance is a minimum conditional setup, not permission to let dust travel beyond it.

Maintain containment throughout the work. Inspect for torn sheeting, lifted tape, open ducts and changing access needs. Before personnel, tools or waste-container exteriors leave, remove dust and debris so contamination is not carried into occupied spaces. A respirator on the worker does not protect an uncontained household.

Containment must not interfere with occupant or worker emergency egress. Coordinate other fire, electrical, access and worker-protection requirements. If the barrier fails or work expands, stop affected work and have the certified renovator restore and verify the setup before continuing.

Basis: 40 CFR 745.85(a)(1)–(2)

6. Contain exterior work and protect neighbors

By the end: Apply exterior distances and additional containment where needed.

Exterior renovation requires containment that prevents dust and debris from leaving the work area. Weather, height, adjacent property, occupied entrances and the method affect the setup. A standard distance alone does not prove containment is adequate for the actual work.

Close doors and windows within twenty feet of the renovation. For multistory buildings, include those within twenty feet on the same floor and those on floors below within the same horizontal distance. Doors in the work area that remain in use need a barrier that permits passage while containing dust and debris.

Cover the ground with disposable impermeable material extending ten feet beyond the surfaces being renovated, or far enough to collect falling debris, whichever is greater, unless the property line prevents ten feet. Ground containment may end at a vertical barrier. Secure the system and verify that falling or windblown material stays contained.

If affected surfaces are within ten feet of the property line, erect vertical containment or equivalent extra precautions so neighboring buildings and properties are not contaminated. Additional vertical containment may also be needed in other conditions. A narrow yard does not authorize dumping chips onto the neighboring property.

Inspect the setup during work and after weather or task changes. Stop affected activity if dust or debris escapes, restore effective containment and address contamination under the certified renovator’s direction. Keep pedestrians, residents and pets out of the work area and preserve safe entry and emergency routes.

Basis: 40 CFR 745.85(a)(2)(ii)

7. Avoid prohibited methods and manage waste

By the end: Recognize method restrictions and contained waste handling.

Open-flame burning or torching of painted surfaces is prohibited during covered RRP renovation. Do not assume that OSHA respiratory protection makes it allowable. All applicable rules must be met; permission under one program is not permission under another.

High-speed machines that remove paint or coatings, such as sanders, grinders, power planers, needle guns and abrasive blasters, need shrouds or containment systems and a HEPA vacuum attachment that collects dust at generation. Operate them so no visible dust or release of air occurs outside the shroud or containment system. A nearby vacuum hose is not automatically an adequate attachment.

Heat guns on painted surfaces may operate only below 1,100 degrees Fahrenheit. The rule is not “1,100 or less.” Verify actual equipment settings and use suitable low-dust methods under the certified renovator’s direction. Required worker exposure controls still apply even to a method permitted by RRP.

Contain waste before it leaves the work area for storage or disposal. Cover any waste chute. At the end of each workday and at project completion, store collected waste under containment, in an enclosure or behind a barrier preventing dust release and access. During transport, contain waste so dust and debris cannot escape.

Verify applicable waste-disposal and wastewater requirements with the jurisdiction and receiving facility. RRP containment is not a universal determination that every waste stream is nonhazardous or accepted at every landfill. Keep container exteriors clean, use the approved route and preserve actual disposal documentation required for the work.

Basis: 40 CFR 745.85(a)(3)–(4)

8. Complete cleaning and certified verification

By the end: Distinguish cleaning, visual inspection and cleaning verification.

After renovation, clean until no dust, debris or residue remains. Collect chips and debris without dispersing them and seal them in heavy-duty bags. Mist protective sheeting, fold dirty sides inward and seal it for disposal. Keep sheeting separating contaminated and clean rooms in place until other cleaning and sheeting removal is complete.

For interiors, clean objects and surfaces in the work area and within two feet of it, working from high to low. HEPA-vacuum or damp-wipe walls, thoroughly HEPA-vacuum remaining surfaces and objects, and use a beater bar for carpets and rugs. Damp-wipe noncarpeted, nonupholstered surfaces and mop hard floors with separate wash/rinse water or the specified wet-mopping system.

The certified renovator performs a visual inspection. Remaining dust, debris or residue requires recleaning and another inspection. Interior verification then uses the prescribed damp disposable cloths and EPA cleaning-verification card on windowsills, uncarpeted floors and countertops. Floors and countertops greater than forty square feet are divided into roughly equal sections each less than forty square feet, each with a new cloth.

If the cloth does not match the card, reclean and repeat the prescribed wet-cloth procedure. If the repeat still fails, wait one hour or until completely dry, whichever is longer, then use the required dry disposable cloth procedure. The renovator must follow the complete sequence in 745.85(b), including the windowsill details. This awareness description is not a substitute for accredited hands-on instruction or actual verification.

Exterior completion uses the certified renovator’s visual inspection of surfaces in and below the work area, including windowsills and ground, with removal and reinspection if residue remains. Remove warning signs only after the applicable verification passes. A customer saying it looks clean is not the required certified-renovator determination.

Basis: 40 CFR 745.85(a)(5), (b)

9. Distinguish verification from dust clearance

By the end: Apply current dust criteria only to the appropriate evaluation.

RRP cleaning verification is not a laboratory dust-clearance test. The cloth/card procedure does not produce a numeric dust-lead result or declare a home lead-free. OSHA personal air sampling is a third, different measurement. Keep the method, units and purpose clear in every record and customer statement.

RRP permits dust clearance in place of cleaning verification when the contract or another applicable law requires sampling by a certified inspector, risk assessor or dust-sampling technician, and requires recleaning until results are below the applicable action levels or other applicable jurisdictional standard. Sending an unqualified worker’s sample to a lab does not establish this alternative.

In EPA-administered jurisdictions, the revised dust-lead standards had a January 12, 2026 compliance date for the relevant standards and reporting provisions. Dust-lead reportable levels for floors and interior windowsills are any reportable level analyzed by an EPA-recognized laboratory. The dust-lead action levels are 5 µg/ft² for floors, 40 µg/ft² for interior windowsills and 100 µg/ft² for window troughs. Applicable post-abatement results must be below the action levels to clear them.

Do not reuse the older 10/100/400 clearance numbers as the current federal EPA baseline. Verify the administering state or Tribal program and any HUD or local requirements for the actual job. The reportable-level and action-level concepts serve different purposes: a reportable result does not automatically mean the same abatement decision as a result at or above an action level.

Certified professionals must select the appropriate sampling protocol, laboratory, interpretation, recleaning and reporting. EPA does not recommend abatement based solely on dust loading that is reportable but below the action levels; recommended cleaning practices and other hazard findings still matter. This course does not authorize dust sampling, risk assessment or abatement decisions.

Basis: 40 CFR 745.85(c); 745.65; 745.227(e)(8); EPA 2024 final rule

10. Keep project records and close the job

By the end: Document actual compliance and provide timely completion information.

Retain RRP records needed to demonstrate compliance for three years after renovation completion, and make them available to EPA on request. Longer obligations under other rules still apply. The three-year rule does not replace OSHA exposure or medical-record requirements or a longer authorized-program requirement.

Keep any inspector/risk-assessor determination, test-kit or paint-chip information, pre-renovation acknowledgments and notification certifications. Record the assigned renovator, relevant certificates and on-the-job worker instruction. Identify the actual components and work; a generic form prechecked before the task is not evidence that it happened.

Document warning signs, containment, restricted practices, waste containment, cleaning and the certified renovator’s verification. Include the required verification details, such as the wet and dry cloths used and results. If an emergency exemption was used, record the nature of the emergency and the specific requirements not followed to respond to it.

Provide the required compliance information to the owner and, when different, the adult occupant or facility representative when the final invoice is delivered or within thirty days after completion, whichever comes first. Common-area occupants receive the prescribed posted information or access instructions. If qualifying dust clearance replaced verification, provide the required sampling report on that same earlier deadline.

Close the job only after actual completion requirements and corrective actions are resolved. Store records so they can be retrieved by property, date and project. Use plain descriptions of what was verified; do not label the building lead-free or the work independently certified merely because this Academy course was completed.

Basis: 40 CFR 745.86

11. Understand residential sale and rental disclosure

By the end: Distinguish transaction disclosures from renovation notices.

The lead-based paint disclosure rule applies to most pre-1978 housing sales and rentals. Before the buyer signs a contract or renter signs a lease, provide the required pamphlet, known lead-based paint and hazard information, available records and reports, and the lead warning and acknowledgment language. Do not wait until move-in or closing to begin the disclosure.

Use Protect Your Family From Lead In Your Home for this transaction requirement. Disclose known locations and conditions, available evaluations and relevant building-wide common-area or other-unit records. A renovator’s Renovate Right delivery does not automatically satisfy the seller or landlord’s separate transaction obligations.

Homebuyers receive a ten-day opportunity for a lead inspection or risk assessment. The parties may agree in writing to a different period, or the buyer may waive the opportunity. This opportunity is not a universal requirement that every seller test the property. The disclosure rule itself does not require landlords to perform a requested inspection.

Keep signed disclosures for three years after the sale is completed or the lease begins. Use the required contract language and signatures, and satisfy applicable electronic-consent and access rules if delivering electronically. A text message saying “old house, possible lead” is not the full disclosure package.

Defined exceptions require careful review, including certain short leases without renewal, foreclosure sales and qualifying housing categories. Do not assume zero-bedroom housing or housing for older or disabled residents is exempt when a child under six lives or is expected to live there. Use the current rule and appropriate transaction forms for the actual property; this course does not replace legal review of a transaction.

Basis: 40 CFR Part 745, Subpart F; EPA disclosure guidance

12. Recognize abatement, emergencies and other requirements

By the end: Route work to the correct qualified program before starting.

Lead abatement is specialized work designed to permanently eliminate lead-based paint hazards. Renovation usually changes or repairs a building for another purpose and may include interim controls. Similar tools do not make the programs interchangeable. Inspection, risk assessment and abatement require their own applicable individual and firm certifications and work practices; RRP certification alone does not authorize those roles.

An emergency renovation results from a sudden, unexpected event that, if not immediately addressed, threatens safety, public health, equipment or property with significant damage. It is not simply a late schedule or a demanding customer. The pre-renovation information exception and the limited work-practice/certification exceptions must be applied only as the rule allows and documented.

For emergency renovations other than interim controls, certain signs, containment, waste, training and certification provisions are excepted only to the extent necessary to respond to the emergency. Required cleaning, certified-renovator cleaning verification and specified records remain. Interim controls responding to a child’s elevated blood lead have a narrower exception; do not assume all emergency categories waive the same duties.

HUD’s Lead Safe Housing Rule can add requirements for federally assisted or owned housing, including evaluation, worker qualifications, occupant protection and clearance depending on the assistance and work. Authorized state and Tribal lead programs and local rules may also differ. Determine these before choosing the contract, crew and completion method; ordinary federal RRP compliance alone is not a universal housing-compliance certificate.

Finally, EPA residential paint requirements do not replace OSHA worker exposure protection or other environmental obligations. Drinking-water lead, soil management and waste regulation have separate requirements outside this paint-focused course. Use the actual task, jurisdiction and qualified professionals to resolve those needs. Complete employer and certified-renovator instruction before work; never treat an awareness score as permission to take a regulated role.

Basis: 40 CFR 745.82(b); Part 745 Subparts L and Q; 24 CFR Part 35

Sources

Federal OSHA and EPA sources reviewed October 22, 2026. Confirm the actual work, jurisdiction and applicable additional requirements. Agency guidance supports planning; it is distinguished from mandatory standard text.