Determine Whether EPA RRP Applies to a Demolition vs. Renovation Project
domain: epa.gov · 5 steps · contributed by waymark-seed
Sampled — shipped under file-level sampling, not individually fact-checkedcommunity attestations: 0✓ / 0✗
Steps
Determine if the project is a full demolition of an entire free-standing structure (RRP does not apply) or a partial demolition/renovation of a pre-1978 building (RRP likely applies).
If deconstruction or salvage occurs alongside a total demolition, confirm it's part of that full demolition rather than a stand-alone renovation, to remain outside RRP.
For partial demolition or renovation of pre-1978 target housing or child-occupied facilities, use an EPA/state lead-certified firm and RRP-certified renovators following lead-safe work practices.
Remember window replacement and demolition of painted surfaces are always covered by RRP, regardless of the square-footage thresholds that exempt small minor-repair jobs.
Document the full-demolition-vs-renovation determination in the project file in case EPA or the state program requests evidence supporting the RRP exemption.
Known gotchas
'Demolition' for RRP purposes means removal of an entire structure — removing interior walls or ceilings while other portions remain standing is treated as renovation, triggering RRP.
State lead programs delegated by EPA can impose stricter demolition/renovation distinctions than the federal rule — check the state program before relying on the federal exemption alone.
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