Renovation, Repair, Painting & Maintenance (RRPM) Regulations

The RRPM regulations apply to all pre-1978 housing (rented or owner-occupied) and child-occupied facilities, and to anyone who is a painter, carpenter, plumber, electrician, weatherization or window replacement contractor, landlord, property manager, or anyone else who disturbs painted surfaces in pre-1978 housing and child-occupied facilities. 

Lead-Safe RRPM licenses are required for work done for compensation that will disturb more than:

• 1 square foot per interior room
• 20 square feet per exterior surface 

For rental housing and child care facilities, Lead-Safe RRPM licenses are required for work that will disturb more than:

• 1 square foot per interior room
• 1 square foot per exterior surface

Lead-Safe RRPM Licenses

These Lead-Safe RRPM licenses are required: 

• Lead-Safe RRPM Supervisor license – this license is for an individual who supervises the work onsite.
• Lead-Safe RRPM Firm license – this license is for the company.

If you are a sole proprietor, you need both the Lead-Safe RRPM Supervisor and the RRPM Firm licenses. 

If you are a company with multiple employees, the company only needs one Lead-Safe RRPM Firm license, but each worksite must have a licensed onsite Lead-Safe RRPM supervisor. The onsite supervisor can train other workers to perform RRPM work. However, the supervisor must remain on the job site at all times to supervise the work.  

Window replacement or demolition of painted surface areas are considered RRPM activities, no matter how small the job. 

Training is required before you can apply for the Lead-Safe RRPM licenses.

Initial Training

1. Take an 8-hour Initial RRP training. Look for the initial "lead renovator” course. Make sure it is an “initial” course. This training certificate is good for 5 years. The refresher training needs to be taken before your initial training certificate expires, or you will need to take the initial course again. Find a training
2. Take the 2-hour online Vermont Inspection, Repair and Cleaning (IRC) Practices training and review What Workers Need to Know About Vermont’s RRPM Regulations. You will be tested on the content of this information sheet when you take the online IRC Practices training test. This training certificate is good for 5 years. Go to the online training

Refresher Training

To maintain your Lead-Safe RRPM license – and before your previous RRP training certificate expires – you need to:

1. Take a 4-hour RRP Refresher training. Look for the refresher “lead renovator” course. Make sure it is a “refresher” course. This training certificate is good for 5 years. The refresher training needs to be taken again before your training certificate expires, or you will need to take the initial course again. There is also an online option for the RRP refresher training. However, this training certificate is valid for only 3 years and your next RRP refresher training will need to be taken in person. Find a training
2. Take the 2-hour online Vermont Inspection, Repair and Cleaning (IRC) Practices training every 5 years. You will need to review What Workers Need to Know About Vermont’s RRPM Regulations. You will be tested on the content of this information sheet when you take the online IRC Practices training test. Go to the online training

Please note that if you let your RRP training certificate expire, you will need to take the Initial RRP training course again.

Apply for RRPM Licenses

RRPM supervisors must work under a Lead-Safe RRPM Firm license.

• The application fee for a Lead-Safe RRPM Firm license is $300. It must be renewed every 5 years.
• The application fee for a Lead-Safe RRPM Supervisor license is $50. It must be renewed every year.
• The appeal process for a licensing decision can be found in the Statement of Procedural Rights.

Apply for the Lead-Safe RRPM Licenses

The RRPM firm is required to provide homeowners, tenants or child care providers with the following educational materials within 60 days before starting work: 

1. EPA’s Lead-Safe Certified Guide to Renovate Right
2. What Homeowners, Renters and Child Care Providers Need to Know About Vermont’s Renovation, Repair, Painting and Maintenance (RRPM) Regulations

For rental housing, Lead-Safe RRPM licenses are required for work that will disturb more than:

• 1 square foot per interior room
• 1 square foot per exterior surface

If you are a landlord or property management company, this means that you must have the Lead-Safe RRPM Firm – Landlord license if you are performing work on your own rental property and are not supervising other workers. If you are supervising other workers or are performing work on properties you don't own, then you need both the Lead-Safe RRPM Supervisor and RRPM Firm licenses.

If you are a renter, make sure the work being done on your home is following the law by reading what to ask, what to look for, and how to report a concern before the work starts. 

How to Become Lead-Safe RRPM – Landlord Licensed 

Initial Steps

1. Take an 8-hour Initial RRP training. Look for the initial "lead renovator” course. Make sure it is an “initial” course. This training certificate is good for 5 years. The refresher training needs to be taken before your initial training certificate expires, or you will need to take the initial course again. Find a training
2. Take the 2-hour online Vermont Inspection, Repair and Cleaning (IRC) Practices training and review What Workers Need to Know About Vermont’s RRPM Regulations. You will be tested on the content of this information sheet when you take the online IRC Practices training test. This training certificate is good for 5 years. Go to the online training
3. Apply for the Lead-Safe RRPM Firm – Landlord. This license must be renewed every 5 years and costs $300.

Please note that if you let your RRP training certificate expire, you will need to take the Initial RRP training course again.

Apply for the Lead-Safe RRPM Firm – Landlord License

Refresher Training

To maintain your UCCO certification – and before your previous RRP training certificate expires – you need to:

1. Take an accredited 4-hour RRP Refresher training. Look for the refresher “lead renovator” course. Make sure it is a “refresher” course. This training certificate is good for 5 years. The refresher training needs to be taken again before your training certificate expires, or you will need to take the initial course again. There is also an online option for the RRP refresher training. However, this training certificate is valid for only 3 years and your next RRP refresher training will need to be taken in person. Find a training
2. Take the 2-hour online Vermont Inspection, Repair and Cleaning (IRC) Practices training every 5 years. You will need to review What Workers Need to Know About Vermont’s RRPM Regulations. You will be tested on the content of this information sheet when you take the online IRC Practices training test. Go to the online training
3. Apply for the Lead-Safe RRPM Firm – Landlord. This license must be renewed every 5 years and costs $300.

Please note that if you let your RRP training certificate expire, you will need to take the Initial RRP training course again.

Apply for the Lead-Safe RRPM Firm – Landlord License

The Vermont Lead Poisoning Prevention Law requires that landlords or property management companies of pre-1978 rental housing must also perform Inspection, Repair and Cleaning (IRC) Practices and submit a compliance statement each year. Learn more about IRC Practices

If you are paying someone to work on your home, Lead-Safe RRPM licenses are required for work that will disturb more than:

• 1 square foot per interior room
• 20 square feet per exterior surface

For your safety, you may choose to have the worker use lead-safe work practices even if the area they disturb is smaller than these requirements. 

To make sure the company and/or the workers you hire are following the law, read what to ask, what to look for, and how to report a concern before the work starts. 

You may work on your own home without these Lead-Safe RRPM licenses. However, you may want to take the 8-hour Initial RRP training to learn lead-safe work practices.

Child-occupied facilities include child care facilities, preschools and kindergarten classrooms (see the full definition of a child-occupied facility). Only the portion of the building (inside or outside) that the children routinely use must meet the RRPM regulations. 

In child-occupied facilities, Lead-Safe RRPM licenses are required for work that will disturb more than:

• 1 square foot per interior room
• 20 square foot per exterior surface

Child Care Facilities

In child care facilities, Lead-Safe RRPM licenses or an Uncompensated Child Care Operator (UCCO) certification is required for work that will disturb more than:

• 1 square foot per interior room
• 1 square foot per exterior surface

If you are a child care provider, you may apply for a UCCO Certification if you will be working on your own child care. This certification is free. You do not need a Lead-Safe RRPM Firm or Supervisor license with this certification. Certified Uncompensated Child Care Providers cannot perform RRPM work for hire and cannot train or supervise other workers. 

How to Become UCCO Certified 

Initial Steps

1. Take an 8-hour Initial RRP training. Look for the initial "lead renovator” course. Make sure it is an “initial” course. This training certificate is good for 5 years. The refresher training needs to be taken before your initial training certificate expires, or you will need to take the initial course again. Find a training
2. Take the 2-hour online Vermont Inspection, Repair and Cleaning (IRC) Practices training and review What Workers Need to Know About Vermont’s RRPM Regulations. You will be tested on the content of this information sheet when you take the online IRC Practices training test. This training certificate is good for 5 years. Go to the online training
3. Apply for the Uncompensated Child Care Operator Certification. This certification must be renewed every year and is free.

Please note that if you let your RRP training certificate expire, you will need to take the Initial RRP training course again.

Apply for the UCCO Certificate

Refresher Training

To maintain your UCCO certification – and before your previous RRP training certificate expires – you need to:

1. Take an accredited 4-hour RRP Refresher training. Look for the refresher “lead renovator” course. Make sure it is a “refresher” course. This training certificate is good for 5 years. The refresher training needs to be taken again before your training certificate expires, or you will need to take the initial course again. There is also an online option for the RRP refresher training. However, this training certificate is valid for only 3 years and your next RRP refresher training will need to be taken in person. Find a training
2. Take the 2-hour online Vermont Inspection, Repair and Cleaning (IRC) Practices training every 5 years. You will need to review What Workers Need to Know About Vermont’s RRPM Regulations. You will be tested on the content of this information sheet when you take the online IRC Practices training test. Go to the online training
3. Apply for the Uncompensated Child Care Operator Certification. This certification must be renewed every year and is free. 

Please note that if you let your RRP training certificate expire, you will need to take the Initial RRP training course again.

Apply for the UCCO Certificate

The Vermont Lead Poisoning Prevention Law requires that child care providers must also perform Inspection, Repair and Cleaning (IRC) Practices on pre-1978 child care facilities and submit a compliance statement each year. Learn more about IRC Practices

If someone is working on your home, follow these steps to make sure they are performing the work properly.

Step 1: Confirm the worker and company is Lead-Safe RRPM licensed before you sign a contract.

• Ask to see a copy of both the Lead-Safe RRPM Supervisor and RRPM Firm licenses.
• Look up the RRPM Firm and Supervisor licenses to verify they are current. 

In the contract, you might want to specify that the worker(s) have the correct Lead-Safe RRPM licenses and will use lead-safe work practices. 

Step 2: Make sure you receive RRPM educational materials from the contractor before the work begins.

Within 60 days before starting work, workers are required to give you (the homeowner, tenant or child care operator) a copy of these educational materials:

• Lead-Safe Certified Guide to Renovate Right
• What Homeowners, Renters and Child Care Providers Need to Know About Vermont’s Renovation, Repair, Painting and Maintenance (RRPM) Regulations

Step 3: Observe the work activities to make sure the workers are following lead-safe work practices.

Workers are required to use lead-safe work practices to make sure lead dust and debris are contained. Some work practices generate so much lead dust that they are not allowed under federal and state regulations.

Workers must follow these lead-safe work practices:

• Use plastic sheets to contain the work areas by:
  • Covering the floors and any furniture that cannot be moved and secure the plastic with tape.
  • Sealing off doors and heating and cooling system vents.
  • For exterior work, covering the ground. In some cases, there may need to be extra precautions to contain the work area (for example, putting up vertical containment).
• Put up warning signs that alert others to potential lead hazards.
• Clean up and secure the work area daily.
• Clean up all work areas when the work is complete and before taking down the plastic sheets.
  • Exterior work areas must be properly cleared of visible paint chips and debris. Interior work areas must be deep cleaned by first using a HEPA vacuum on all surfaces followed by wet wiping and wet mopping with detergent and rinse water.
  • When the final cleaning is done, there should be no dust, paint chips, or debris in the work area.  
  • The supervisor must perform a cleaning verification procedure to ensure the cleaning was done properly. If the work area has been adequately cleaned, a clean wet disposable cloth (like a Swiffer) should not pick up any signs of dirt when run along the walls, windowsills, or floors of the work area. 

These work practices are prohibited: 

• Open flame burning or torching
• Dry scraping or sanding
• Using power tools (sanding, grinding, planing, needle gunning, or abrasive blasting or sandblasting), unless the worker has received a permit or other written authorization from the Asbestos and Lead Regulatory Program
• Using a heat gun at temperatures greater than 1100°F
• Hydro-blasting or high-pressure washing
• Chemical stripping

If you see workers using any of these prohibited work practices, please immediately fill out this online form.

Step 4: Contact the Asbestos and Lead Regulatory Program if you see something that does not seem right.

If you are concerned the work is not meeting the lead-safe work practices listed above, contact the worker or company to ask them to correct the issue(s). If you still have concerns or cannot get the cooperation of the worker or company, or if you see workers using any of the prohibited work practices, immediately fill out this online form. 

It is helpful to complete the form as soon as you notice a concern so that we can respond in time. You can take pictures and upload them through the online form. You do not need to be the person who hired the workers to contact us. Anyone can notify us of any concerns they see related to unsafe work practices.