EPA RRP Rule Explained: What Oklahoma Contractors Must Know
The Rule Every Contractor Knows About — And Many Still Ignore
If you're a contractor working on pre-1978 homes in Oklahoma, the EPA's Renovation, Repair, and Painting (RRP) Rule applies to you. Not sometimes. Not maybe. Not "well, nobody's checking." Every time you disturb painted surfaces beyond minimal thresholds in a home built before 1978.
The penalties for non-compliance can reach $48,762 per violation per day. That's not a typo, and it's not a theoretical maximum that never gets enforced. The EPA has been actively pursuing enforcement actions, and one improperly documented job can cost more than the entire renovation.
Here's the prediction error that gets contractors into trouble: they assume the rule exists to protect big-city homeowners in expensive historic homes. It doesn't. It exists because a contractor in Any Town, Oklahoma can create a lead dust contamination event that poisons a child just as effectively as a contractor in Manhattan. Lead doesn't care about your zip code or your project budget.
What It Is: The EPA RRP Rule requires certified renovators using lead-safe work practices for any renovation disturbing more than 6 square feet of interior painted surface or 20 square feet of exterior painted surface in pre-1978 housing. Oklahoma manages its own RRP program through ODEQ.
Who Must Comply (Hint: It's More People Than You Think)
The RRP Rule applies to any paid contractor performing work that disturbs paint in:
- Residential housing built before 1978
- Apartments and multi-family housing built before 1978
- Child-occupied facilities (schools, daycares — and yes, church nurseries count)
"Any paid contractor" is broader than general contractors. This includes:
- General contractors — the obvious ones
- Specialty trades — Plumbers, electricians, HVAC technicians, carpenters. If your plumber cuts into a wall to repair a pipe in a 1965 home, RRP applies
- Painters — Especially when prep work involves scraping or sanding. This is the trade that triggers RRP most frequently and understands it least
- Property managers — When supervising renovation work on pre-1978 rentals
- House flippers — Even if you think of yourself as a homeowner, if you're buying, renovating, and selling for profit, the EPA considers you a contractor
Homeowners working on their own primary residence are generally exempt — unless they rent out any portion of the home, operate a daycare, or buy/renovate/sell homes for profit. But here's the thing the exemption doesn't cover: it exempts you from the legal requirement. It doesn't exempt you from the lead dust you're creating. The physics of lead contamination don't check your tax status.
The Thresholds (They're Smaller Than You Think)
| Location | Threshold | Reality Check |
|---|---|---|
| Interior surfaces | More than 6 square feet per room | That's a 2×3 patch. Replacing a single window exceeds this |
| Exterior surfaces | More than 20 square feet total | About the size of a small closet door. One section of siding easily exceeds this |
| Windows | Always covered | Any window replacement or demolition triggers RRP regardless of area |
| Demolition | Always covered | Any demolition in a pre-1978 home triggers RRP |
That 6 square foot interior threshold is the one that catches people. Replacing a single window. Cutting a new doorway. Sanding prep for repainting one wall. Replacing a section of baseboard. Running new electrical. It doesn't take what most contractors would consider a "major job" to trigger RRP requirements.
Certification: What You Actually Need
Firm Certification
The contracting business itself must be certified as a firm. In Oklahoma, this means applying through the Oklahoma Department of Environmental Quality (ODEQ), not directly through the EPA. Oklahoma is an EPA-authorized state, which means the state runs its own program. Certification is typically valid for five years and involves documentation, not testing — though the documentation requirements are specific.
Individual Certified Renovator
At least one person on each job site must be a Certified Renovator who has completed an 8-hour EPA-approved training course. Think of this person like the charge nurse on a hospital floor — they don't have to do every task personally, but they're responsible for ensuring everything is done correctly. This person:
- Ensures lead-safe work practices are followed
- Trains other workers on the job
- Directs and supervises the work
- Performs or directs post-renovation cleaning
- Verifies cleaning was done properly (and documents it)
Oklahoma-Specific: Oklahoma manages its own RRP program through ODEQ. Contractors must apply for certification through the Oklahoma Department of Environmental Quality. If you got certified through the EPA directly, check with ODEQ to confirm your certification is recognized in-state.
Required Work Practices (The Ones People Skip)
Before Work Begins
- Provide the EPA's "Renovate Right" pamphlet to owners and tenants — in their language, not just English if applicable
- Post warning signs around the work area
- Contain the work area with plastic sheeting — on the floor and sealing off the room from the rest of the house
- Close windows and doors, seal HVAC vents — lead dust is so fine that your forced air system will distribute it to every room in the house if you don't
During Work
- Minimize dust creation
- No prohibited practices — This is where I see violations most often: open flame burning or torching of lead paint, power sanding without HEPA vacuum attachment, heat guns above 1100°F. These create lead fume and fine dust hazards that dramatically exceed normal renovation exposure
- Keep containment intact — if the plastic comes down during work, the containment has failed
After Work
- Clean the entire work area using HEPA-equipped vacuum and wet cleaning — standard shop vacs blow lead dust back into the air
- Verify cleaning with visual inspection or clearance testing
- Dispose of waste properly — lead-contaminated debris isn't regular construction waste
- Maintain records for at least 3 years — and I recommend longer, because lawsuits don't follow convenient timelines
The Penalties (Not Theoretical)
The EPA has intensified enforcement of the RRP Rule. Current civil penalties:
- Up to $48,762 per violation per day — and they stack. Each day of non-compliance is a separate violation. Each uncertified worker is a separate violation. Missing documentation is a separate violation
- Criminal penalties for knowing or willful violations — this is rare but it happens, especially when injured children are involved
One job with multiple violations can result in penalties exceeding the value of the entire renovation. I've heard contractors say "nobody's checking." The EPA's enforcement database says otherwise. And the homeowner who discovers their child's blood lead levels are elevated after your uncertified renovation has both standing and motivation to sue.
2025 Updates: Tighter Standards
In January 2025, the EPA tightened dust-lead hazard standards:
- Dust-lead hazard standards lowered to "any reportable level" — effectively, any detectable lead in dust is now a hazard
- Post-abatement clearance levels reduced significantly
These stricter standards mean more thorough cleaning and more stringent verification requirements. Enforcement of the new levels began January 12, 2026. If your RRP training predates these changes, you need a refresher.
How Testing Fits Into RRP Compliance
Here's where my work intersects with yours as a contractor. Testing plays two distinct roles in RRP compliance:
Pre-Renovation Paint Testing (Optional But Smart)
The RRP Rule doesn't actually require paint testing before work. You can assume lead is present and follow all RRP practices. But if you can document that lead-based paint is not present through proper testing, the RRP requirements don't apply. This is called "opting out."
For many jobs, the cost of testing is less than the cost of full RRP compliance. Testing can save you money — and save your client money — by confirming that lead-safe practices aren't needed on a particular project. Of course, if testing finds lead, you've just confirmed that RRP practices are definitely needed, which is also valuable information.
Post-Renovation Clearance Testing
After renovation, the Certified Renovator must verify cleaning through either visual inspection or dust wipe sampling. Clearance testing is the definitive proof that your cleanup was effective. With the 2025 tightened standards, clearance testing has become more important — and harder to pass.
I perform both pre-renovation lead testing (to determine if RRP applies) and post-renovation clearance testing (to verify the work area is safe). Both protect the contractor's liability as much as the homeowner's health.
For Oklahoma Homeowners Hiring Contractors
If you're hiring contractors for renovation work on your pre-1978 Oklahoma home, protecting yourself is straightforward:
- Ask if the contractor is EPA RRP-certified — Some will sidestep the question. An honest answer is a sign of a good contractor
- Ask to see the firm's certification — It's a document they should have readily available
- Expect to receive the "Renovate Right" pamphlet before work begins — if they don't provide it, they're either not certified or not following their own training
- Consider pre-renovation lead testing to know what you're dealing with before the first hammer swings
An uncertified contractor working on your pre-1978 home may be creating lead hazards — and they're definitely violating federal law. If your child later shows elevated blood lead levels, the fact that you hired an uncertified contractor who created lead dust contamination is going to be very relevant. Protect yourself by asking the questions before the project starts.
Need Pre-Renovation Lead Testing?
Testing confirms whether lead is present — which determines whether RRP practices are required. Know before you start.
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