Lead RRP work practice standards study guide
40 CFR 745.85 sets the work practice standards for renovations covered by the federal residential property renovation rules (40 CFR Part 745 Subpart E). It says renovations must be performed by certified firms using certified renovators, and this guide sets out what the federal rule text states on occupant protection and warning signs, containing the work area (with separate duties for interior and exterior renovations), prohibited and restricted practices, waste handling, cleaning the work area, the optional dust clearance testing alternative in 745.85(c) and activities after cleaning verification in 745.85(d). Many duties differ between interior and exterior work, and emergency renovations have limited exemptions. The cleaning verification procedure in 745.85(b) has its own guide. Your State or Tribe may run its own authorized program, so check its rules too. goraedu is not a training provider; every point links to the regulation and quotes its exact words.
Who does the work and warning signs
Renovations must be performed by certified firms using certified renovators, as directed in 745.89.
“Renovations must be performed by certified firms using certified renovators as directed in § 745.89.”
745.85(a) points to 745.89(d) for the responsibilities of certified firms and to 745.90(b) for the responsibilities of certified renovators.
“The responsibilities of certified firms are set forth in § 745.89(d) and the responsibilities of certified renovators are set forth in § 745.90(b).”
A renovator is an individual who either performs or directs workers who perform renovations; a certified renovator has successfully completed a renovator course accredited by EPA or an EPA-authorized State or Tribal program.
“Renovator means an individual who either performs or directs workers who perform renovations. A certified renovator is a renovator who has successfully completed a renovator course accredited by EPA or an EPA-authorized State or Tribal program.”
Firms must post signs that clearly define the work area and warn occupants and other persons not involved in the renovation to stay outside the work area.
“Firms must post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area.”
To the extent practicable, the signs must be in the primary language of the occupants.
“To the extent practicable, these signs must be in the primary language of the occupants.”
The signs must be posted before the renovation begins and must stay in place and readable until both the renovation and the post-renovation cleaning verification have been completed.
“These signs must be posted before beginning the renovation and must remain in place and readable until the renovation and the post-renovation cleaning verification have been completed.”
If warning signs have been posted in accordance with 24 CFR 35.1345(b)(2) or 29 CFR 1926.62(m), 745.85 does not require additional signs.
“If warning signs have been posted in accordance with 24 CFR 35.1345(b)(2) or 29 CFR 1926.62(m), additional signs are not required by this section.”
Emergency renovations other than interim controls are exempt from the warning sign, containment, waste handling, training and certification requirements of 745.85, 745.89 and 745.90, but only to the extent necessary to respond to the emergency.
“Emergency renovations other than interim controls are also exempt from the warning sign, containment, waste handling, training, and certification requirements in §§ 745.85, 745.89, and 745.90 to the extent necessary to respond to the emergency.”
Not covered here
Which renovations are covered (745.82(a)), the full emergency renovation definition and the firm and renovator duties in 745.89(d) and 745.90(b) are not set out here. We only write what an official source states, so study these parts with your certifying program's materials.
Containing the work area
Before the renovation begins, the firm must isolate the work area so that no dust or debris leaves it while the renovation is being performed.
“Before beginning the renovation, the firm must isolate the work area so that no dust or debris leaves the work area while the renovation is being performed.”
The firm must maintain the integrity of the containment: plastic or other impermeable materials must not be torn or displaced, and the firm must take any other steps necessary so that no dust or debris leaves the work area.
“the firm must maintain the integrity of the containment by ensuring that any plastic or other impermeable materials are not torn or displaced, and taking any other steps necessary to ensure that no dust or debris leaves the work area while the renovation is being performed.”
The firm must install containment so that it does not interfere with occupant and worker egress in an emergency.
“The firm must also ensure that containment is installed in such a manner that it does not interfere with occupant and worker egress in an emergency.”
The work area is defined as the area the certified renovator establishes to contain the dust and debris generated by a renovation.
“Work area means the area that the certified renovator establishes to contain the dust and debris generated by a renovation.”
Vertical containment is a vertical barrier of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area.
“Vertical containment means a vertical barrier consisting of plastic sheeting or other impermeable material over scaffolding or a rigid frame, or an equivalent system of containing the work area.”
Vertical containment is required for some exterior renovations, but it may be used on any renovation.
“Vertical containment is required for some exterior renovations but it may be used on any renovation.”
Interior containment
For interior renovations, the firm must remove all objects from the work area, including furniture, rugs and window coverings, or cover them with plastic sheeting or other impermeable material with all seams and edges taped or otherwise sealed (one of the two options).
“Remove all objects from the work area, including furniture, rugs, and window coverings, or cover them with plastic sheeting or other impermeable material with all seams and edges taped or otherwise sealed.”
The firm must close and cover all ducts opening in the work area with taped-down plastic sheeting or other impermeable material.
“Close and cover all ducts opening in the work area with taped-down plastic sheeting or other impermeable material.”
The firm must close windows and doors in the work area, and doors must be covered with plastic sheeting or other impermeable material.
“Close windows and doors in the work area. Doors must be covered with plastic sheeting or other impermeable material.”
Doors used as an entrance to the work area must be covered in a way that lets workers pass through while confining dust and debris to the work area.
“Doors used as an entrance to the work area must be covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area.”
The floor surface, including installed carpet, must be covered with taped-down plastic sheeting or other impermeable material 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater.
“Cover the floor surface, including installed carpet, with taped-down plastic sheeting or other impermeable material in the work area 6 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater.”
Interior floor containment may stop at the edge of the vertical barrier when a vertical containment system of impermeable barriers extends from floor to ceiling and is tightly sealed at the joints with the floor, ceiling and walls.
“Floor containment measures may stop at the edge of the vertical barrier when using a vertical containment system consisting of impermeable barriers that extend from the floor to the ceiling and are tightly sealed at joints with the floor, ceiling and walls.”
The firm must use precautions so that all personnel, tools and other items, including the exteriors of waste containers, are free of dust and debris before leaving the work area.
“Use precautions to ensure that all personnel, tools, and other items, including the exteriors of containers of waste, are free of dust and debris before leaving the work area.”
Exterior containment
For exterior renovations, the firm must close all doors and windows within 20 feet of the renovation.
“Exterior renovations. The firm must: (A) Close all doors and windows within 20 feet of the renovation.”
On multi-story buildings, the firm must close all doors and windows within 20 feet of the renovation on the same floor, and all doors and windows on all floors below that are the same horizontal distance from the renovation.
“On multi-story buildings, close all doors and windows within 20 feet of the renovation on the same floor as the renovation, and close all doors and windows on all floors below that are the same horizontal distance from the renovation.”
Doors within the work area that will be used during the job must be covered with plastic sheeting or other impermeable material so workers can pass through while dust and debris stay confined to the work area.
“Ensure that doors within the work area that will be used while the job is being performed are covered with plastic sheeting or other impermeable material in a manner that allows workers to pass through while confining dust and debris to the work area.”
The ground must be covered with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of ground covering.
“Cover the ground with plastic sheeting or other disposable impermeable material extending 10 feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance to collect falling paint debris, whichever is greater, unless the property line prevents 10 feet of such ground covering.”
Exterior ground containment may stop at the edge of the vertical barrier when a vertical containment system is used.
“Ground containment measures may stop at the edge of the vertical barrier when using a vertical containment system.”
If the renovation will affect surfaces within 10 feet of the property line, the firm must erect vertical containment or equivalent extra precautions so that dust and debris do not contaminate adjacent buildings or migrate to adjacent properties.
“If the renovation will affect surfaces within 10 feet of the property line, the renovation firm must erect vertical containment or equivalent extra precautions in containing the work area to ensure that dust and debris from the renovation does not contaminate adjacent buildings or migrate to adjacent properties.”
Vertical containment or equivalent extra precautions may also be necessary in other situations to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties.
“Vertical containment or equivalent extra precautions in containing the work area may also be necessary in other situations in order to prevent contamination of other buildings, other areas of the property, or adjacent buildings or properties.”
Prohibited and restricted practices
Open-flame burning or torching of painted surfaces is prohibited during a renovation.
“Open-flame burning or torching of painted surfaces is prohibited.”
Machines that remove paint or other coatings through high-speed operation (sanding, grinding, power planing, needle gun, abrasive blasting or sandblasting) are prohibited on painted surfaces unless they have shrouds or containment systems and a HEPA vacuum attachment that collects dust and debris at the point of generation.
“The use of machines designed to remove paint or other surface coatings through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting, is prohibited on painted surfaces unless such machines have shrouds or containment systems and are equipped with a HEPA vacuum attachment to collect dust and debris at the point of generation.”
Such machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system.
“Machines must be operated so that no visible dust or release of air occurs outside the shroud or containment system.”
A heat gun may be operated on painted surfaces only at temperatures below 1,100 degrees Fahrenheit.
“Operating a heat gun on painted surfaces is permitted only at temperatures below 1,100 degrees Fahrenheit.”
A HEPA vacuum is a vacuum cleaner designed with a HEPA filter as the last filtration stage; a HEPA filter can capture particulates of 0.3 microns with 99.97% efficiency.
“HEPA vacuum means a vacuum cleaner which has been designed with a high-efficiency particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particulates of 0.3 microns with 99.97% efficiency.”
A HEPA vacuum must be designed so that all air drawn in is expelled through the HEPA filter with none leaking past it, and it must be operated and maintained according to the manufacturer's instructions.
“The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the HEPA filter with none of the air leaking past it. HEPA vacuums must be operated and maintained in accordance with the manufacturer's instructions.”
Minor repair and maintenance activities are defined as activities, including minor heating, ventilation or air conditioning work, electrical work and plumbing, that disrupt 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities, where none of the work practices prohibited or restricted by 745.85(a)(3) are used and where the work does not involve window replacement or demolition of painted surface areas.
“Minor repair and maintenance activities are activities, including minor heating, ventilation or air conditioning work, electrical work, and plumbing, that disrupt 6 square feet or less of painted surface per room for interior activities or 20 square feet or less of painted surface for exterior activities where none of the work practices prohibited or restricted by § 745.85(a)(3) are used and where the work does not involve window replacement or demolition of painted surface areas.”
Waste from renovations
Waste from renovation activities must be contained to prevent releases of dust and debris before it is removed from the work area for storage or disposal.
“Waste from renovation activities must be contained to prevent releases of dust and debris before the waste is removed from the work area for storage or disposal.”
If a chute is used to remove waste from the work area, it must be covered.
“If a chute is used to remove waste from the work area, it must be covered.”
At the end of each work day and at the end of the renovation, collected waste must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris (one of the options).
“At the conclusion of each work day and at the conclusion of the renovation, waste that has been collected from renovation activities must be stored under containment, in an enclosure, or behind a barrier that prevents release of dust and debris out of the work area and prevents access to dust and debris.”
When the firm transports renovation waste, it must contain the waste to prevent release of dust and debris.
“When the firm transports waste from renovation activities, the firm must contain the waste to prevent release of dust and debris.”
One of the cleaning steps for interior and exterior renovations in 745.85(a)(5)(i)(B) is to dispose of the sheeting as waste.
“Dispose of the sheeting as waste.”
Cleaning the work area
After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains.
“After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains.”
For both interior and exterior renovations, the firm must collect all paint chips and debris and, without dispersing any of it, seal it in a heavy-duty bag.
“Interior and exterior renovations. The firm must: (A) Collect all paint chips and debris and, without dispersing any of it, seal this material in a heavy-duty bag.”
The firm must remove the protective sheeting: mist it before folding, fold the dirty side inward, and either tape it shut to seal or seal it in heavy-duty bags.
“Remove the protective sheeting. Mist the sheeting before folding it, fold the dirty side inward, and either tape shut to seal or seal in heavy-duty bags.”
Sheeting used to isolate contaminated rooms from non-contaminated rooms must remain in place until after the cleaning and removal of other sheeting.
“Sheeting used to isolate contaminated rooms from non-contaminated rooms must remain in place until after the cleaning and removal of other sheeting.”
For interior renovations, the firm must also clean all objects and surfaces in the work area and within 2 feet of the work area, cleaning from higher to lower.
“Additional cleaning for interior renovations. The firm must clean all objects and surfaces in the work area and within 2 feet of the work area in the following manner, cleaning from higher to lower:”
As part of the additional cleaning for interior renovations in 745.85(a)(5)(ii), walls are cleaned starting at the ceiling and working down to the floor, by either HEPA vacuuming or wiping with a damp cloth (one of the options).
“Clean walls starting at the ceiling and working down to the floor by either vacuuming with a HEPA vacuum or wiping with a damp cloth.”
For interior renovations (745.85(a)(5)(ii)(B)), all remaining surfaces and objects in the work area, including furniture and fixtures, must be thoroughly vacuumed with a HEPA vacuum, which must have a beater bar when vacuuming carpets and rugs.
“Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum. The HEPA vacuum must be equipped with a beater bar when vacuuming carpets and rugs.”
For interior renovations (745.85(a)(5)(ii)(C)), all remaining surfaces and objects in the work area except carpeted or upholstered surfaces must be wiped with a damp cloth, and uncarpeted floors mopped thoroughly with a method that keeps wash water separate from rinse water (such as the 2-bucket method) or with a wet mopping system.
“Wipe all remaining surfaces and objects in the work area, except for carpeted or upholstered surfaces, with a damp cloth. Mop uncarpeted floors thoroughly, using a mopping method that keeps the wash water separate from the rinse water, such as the 2-bucket mopping method, or using a wet mopping system.”
Emergency renovations are not exempt from the cleaning requirements of 745.85(a)(5), which must be performed by certified renovators or individuals trained in accordance with 745.90(b)(2).
“Emergency renovations are not exempt from the cleaning requirements of § 745.85(a)(5), which must be performed by certified renovators or individuals trained in accordance with § 745.90(b)(2)”
Not covered here
The post-renovation cleaning verification procedure in 745.85(b) (visual inspection, cloth comparison with the cleaning verification card) is covered in its own study guide. We only write what an official source states, so study these parts with your certifying program's materials.
Dust clearance testing and later activities
Under the optional dust clearance testing in 745.85(c), cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation, or another Federal, State, Territorial, Tribal or local law or regulation, requires the firm to perform dust clearance sampling at the conclusion of the renovation, together with the two further requirements below.
“Cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another Federal, State, Territorial, Tribal, or local law or regulation requires: (1) The renovation firm to perform dust clearance sampling at the conclusion of a renovation covered by this subpart.”
Under that option, the dust clearance samples must be required to be collected by a certified inspector, risk assessor or dust sampling technician.
“The dust clearance samples are required to be collected by a certified inspector, risk assessor or dust sampling technician.”
Under that option, the firm must be required to re-clean the work area until dust sample results are below the dust-lead action levels in 745.227(e)(8) or any applicable State, Territorial, Tribal or local standard.
“The renovation firm is required to re-clean the work area until the dust sample results are below the dust-lead action levels in § 745.227(e)(8) or any applicable State, Territorial, Tribal, or local standard.”
Under 745.85(d), activities that do not disturb paint, such as applying paint to walls that have already been prepared, are not regulated by Subpart E if they are conducted after post-renovation cleaning verification has been performed.
“Activities that do not disturb paint, such as applying paint to walls that have already been prepared, are not regulated by this subpart if they are conducted after post-renovation cleaning verification has been performed.”
Not covered here
The dust sampling and action-level procedures in 745.227(e)(8) (Subpart L) are not set out here. We only write what an official source states, so study these parts with your certifying program's materials.
Sources
- eCFR: 40 CFR 745.85, Work practice standards (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.83, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.82, Applicability (as of Nov 4, 2026)Checked November 6, 2026
Other EPA Lead RRP study guides: Scope and definitions, Firm and renovator certification and training, Pre-renovation information and recordkeeping, Cleaning verification and dust clearance, Lead hazard standards and abatement basics