Determine whether the EPA RRP (Renovation, Repair and Painting) rule or its full-demolition exemption applies to a pre-1978 residential project

Steps

1. Determine whether the scope of work is a COMPLETE demolition of the entire target-housing structure or child-occupied facility, versus a partial demolition performed as part of a renovation
2. If it is complete/total demolition of the entire property, confirm this falls outside RRP Rule (40 CFR 745 Subpart E) coverage — EPA guidance states demolition of an entire property is not a 'renovation' for RRP purposes
3. If any portion of the structure is being retained (i.e., partial demolition or deconstruction of parts of the building while other parts remain), treat it as a RENOVATION subject to RRP if it disturbs more than 6 square feet of interior or 20 square feet of exterior painted surface in target housing or a child-occupied facility
4. Note that the RRP minor-repair-and-maintenance exemption does NOT cover window replacement or demolition activities — do not apply that exemption to any demolition-adjacent scope of work
5. For deconstruction/salvage occurring as part of full-property demolition, confirm current EPA guidance on whether RRP applies to that salvage activity specifically (EPA has published FAQ guidance directly addressing deconstruction/reuse of materials from demolished structures) before assuming full exemption covers every activity on site