A contractor is renovating a home built in 1965 and will disturb painted surfaces totaling 8 square feet. What lead-based paint requirement applies under Oregon regulations?
Correct Answer
C) Must follow RRP Rule requirements including certification
Oregon follows EPA RRP Rule requirements. Work disturbing more than 6 sq ft of painted surfaces in pre-1978 housing requires RRP certification and procedures.
Why This Is the Correct Answer
Under the EPA Renovation, Repair, and Painting (RRP) Rule, work that disturbs more than 6 square feet of painted surfaces in pre-1978 housing triggers RRP Rule requirements, including contractor certification and specific work practices. Since 8 square feet exceeds the 6 square foot threshold and the home was built in 1965 (before 1978), full RRP Rule compliance is required.
Why the Other Options Are Wrong
Option A: No special requirements since area is under 10 square feet
The claim that no special requirements apply because the area is under 10 square feet is incorrect. The RRP Rule threshold is 6 square feet for interior work, not 10. At 8 square feet, the threshold is already exceeded.
Option B: Must hire certified lead abatement contractor
Hiring a certified lead abatement contractor is not automatically required for renovation work. Lead abatement is a separate process for permanently removing lead hazards. RRP-certified renovators (not abatement contractors) handle renovation, repair, and painting work, and abatement is not required unless the scope involves permanent hazard elimination.
Option D: Must provide EPA lead pamphlet but no other requirements
Providing the EPA lead pamphlet alone is insufficient. While distributing the pamphlet is one RRP requirement, contractors must also be certified and follow specific work practice standards. Pamphlet distribution without certification and proper procedures does not satisfy the RRP Rule.
Memory Technique
Remember '6 is the fix' — once you disturb 6 or more square feet of painted surfaces in pre-1978 homes, the RRP Rule kicks in. Six square feet is roughly the size of a standard interior door panel.
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