Frequent Questions

Minor Repair and Maintenance Activities

As a floor covering installer I use an undercut saw to remove a small amount of wood at the bottom of baseboards and door casings. I am only disturbing the paint in the 1/8 inch cut of the blade. How do I calculate the area of the paint that is affected for purposes of the minor repair and maintenance provision?
Does drilling holes in window frames to install window treatments such as shades and shutters qualify as minor repair and maintenance?
Does the minor maintenance exception mean that if I drill 1-inch holes in a painted surface to blow insulation into an enclosed wall cavity, I could drill 864 holes in the interior or 2880 holes on the exterior before I had to comply with the RRP Rule? Or does it mean that the work is covered by the RRP Rule once I insulate more than 6 square feet of interior wall area (basically 1 hole) or more than 20 square feet of exterior wall area?
How is window repair or maintenance, as distinct from removal, treated under the RRP Rule? Would the rule apply to a job that replaced parts or components of a window, such as broken or failed glass, hardware, or balance systems, where some components might be painted, but the frame of the window would remain?
If a renovator disrupts 20 square feet or less of painted surface per side on several sides of the exterior of one property, does the RRP Rule apply?
If a renovator disrupts 6 square feet or less of painted surface per room in several rooms inside one property, does the RRP Rule apply?
If a renovator removes less than 6 square feet of crown molding, is that considered demolition? Does it matter whether the molding will be discarded, replaced with new molding, or reinstalled?
If an electrician or plumber, working in a different room from the contained renovation project, needs to drill or cut a hole six square feet or less in size to chase a wire or pipe, does the RRP rule apply to that work?
If I am insulating a multi-family building, does the standard for interiors of 6 square feet or less of disrupted painted surface, or the standard for exteriors of 20 square feet or less of disrupted painted surface apply to the whole building or can it be applied to each separate unit?
If I use a hammer to make a hole is a wall that is two feet on each side, does the RRP Rule apply?
Is replacing a pane of glass or fixing a broken window balancer a renovation covered by the RRP Rule?
My company installs new or replacement seamless gutters. We install the gutters using self-tapping 3/16" to ¼" screws and the cumulative size of the total number of holes is only a couple of square inches. If the job does not involve sanding, scraping, repainting, repair, replacement or reconditioning of the fascia surface, is it covered by the RRP Rule?
My firm installs carpets. Sometimes there is no need to remove an existing carpet before installing the new carpet, but sometimes there is. How do I know when I need to comply with the RRP Rule?
My firm removes and replaces garage doors. The garage doors are typically made up of multiple panels, each of which has an exterior painted surface area of less than 20 square feet. Aggregated, the exterior painted surface area of all the panels exceeds 20 square feet. If we disturb the paint on just one of the door panels, is that activity subject to the RRP Rule?
Please provide guidance on how the Agency will interpret the term “minor repair and maintenance activities.” Is the replacement of a window measuring less than 6 square feet considered minor repair and maintenance? If I use a torch to burn off less than 20 square feet of paint on exterior fixtures, is that considered minor repair and maintenance? What does EPA mean by demolition? How is the size of the disrupted surface calculated? If I sand 5 square feet of paint on one wall on one day, and 5 square feet on a different wall in the same room on the next day, are both projects considered minor repair and maintenance?
When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity? Do I calculate the amount of painted surface disrupted using the standard for interior renovations (6 square feet or less in the room where the door is located) or for exterior renovations (20 square feet or less)?

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