Lead Safe Housing Rule and the Renovation, Repair and Painting Rule

HUD's specific requirements under the Lead Safe Housing Rule depend on the amount of Federal rehabilitation assistance the project is receiving. The Table below provides a comparison to EPA's Renovation, Repair and Painting Rule (RRP) and guidance on what steps must be taken to comply with the RPP.

Additional guidance is available for Renovators.


Stage of Job
Changes to LSHR Projects to Comply with RRP
Planning and Set-Up
Determination that lead-based paint (LBP) is present
EPA-recognized test kits cannot be used to say paint is not LBP. Only a certified LBP inspector or risk assessor may determine whether LBP is present.
Certified renovators use an EPA-recognized test kit to determine if RRP rule applies or not.
HUD does not certify renovators or firms. All workers and supervisors must complete a HUDapproved curriculum in lead safe work practices, except that non-certified renovation workers need only on-the-job training if they are supervised by a certified LBP abatement supervisor who is also a certified renovator.
EPA or EPA authorized States certify renovation firms and accredit training providers that certify renovators. Only the certified renovator is required to have classroom training. Workers must receive on-the-job training from the certified renovator.
Renovation firms must be certified. At least one certified renovator must be at the job or available when work is being done. (The certified renovator may be a certified LBP abatement supervisor who has completed the 4-hour RRP refresher course.)
HUD requires conformance with EPA regulations, including EPA's Pre- Renovation Education Rule. EPA had required renovators to hand out the EPA / HUD / CPSC Protect Your Family from Lead in Your Home (Lead Disclosure Rule) pamphlet.
Education Renovators must hand out the EPA / HUD Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools pamphlet. (This requirement went into effect on December 22, 2008.)
During the job
Treating LBP hazards
Depending on type and amount of HUD assistance, HUD requires that lead hazards be treated using "interim controls" or "ongoing lead-based paint maintenance."
EPA generally requires that renovations in target housing be performed using lead-safe work practices.
Prohibited Work Practices HUD prohibits 6 work practices. These include EPA's 3 prohibited work practices plus: heat guns that char paint, dry scraping or sanding farther than 1 ft. of electrical outlets, and use of a volatile stripper in poorly ventilated space. EPA prohibits 3 work practices (open flame burning or torching, heat guns above 1100 degrees F, machine removal without HEPA vacuum attachment). None.
Threshold minimum amounts of interior paint disturbance which trigger lead activities. HUD has a lower interior "de minimis" threshold (2 sq. ft. per room, or 10% of a small component type) than EPA for lead-safe work practices. HUD also uses this lower threshold for clearance and occupant notification. EPA's interior threshold (6 sq. ft. per room) for minor repair and maintenance activities is higher than HUD's de minimis threshold. None.
End of job Confirmatory Testing HUD requires a clearance examination done by an independent party instead of the certified renovator's cleaning verification procedure. EPA allows cleaning verification by the renovator or clearance examination. The cleaning verification does not involve sampling and laboratory analysis of the dust. None.
Notification to Occupants HUD requires the designated party to distribute notices to occupants within 15 days after lead hazard evaluation and control activities in their unit (and common areas, if applicable). EPA has no requirement to notify residents who are not the owners after the renovation. None.