Vermont Lead Poisoning Prevention Law: Renovation, Repair, Painting and Maintenance

Vermont Lead Poisoning Prevention Law: Renovation, Repair, Painting and Maintenance

logo that says act now be lead safe for you, your family, and your clientsLead is a toxic metal that was used in house paint until 1978. It is estimated that the majority of Vermont housing was built before 1978. Lead-based paint becomes a hazard when it is disturbed and turns into dust. If lead-based paint is not handled properly, lead dust can be breathed in or swallowed by workers, other people and children and cause lead poisoning. Learn more about the health effects of lead.

Because lead is toxic, there are regulations that require workers to be trained and licensed to use lead-safe work practices when they disturb painted surfaces in pre-1978 buildings. Since 2010, the U.S. Environmental Protection Agency (EPA) has governed the Renovation, Repair and Painting (RRP) regulations.

As of October 1, Vermont has taken over the federal regulations, which are now called the Renovation, Repair, Painting and Maintenance (RRPM) regulations. The Health Department now oversees compliance with these regulations and licenses individuals and entities that perform renovation, repair, painting and maintenance work. For the most part, the new RRPM regulations are the same as the federal RRP regulations. However, there are some ways that the RRPM regulations are more restrictive. 

See the Vermont Regulations for Lead Control for more details. 

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What type of work falls under the 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. 

How do I become Lead-Safe RRPM licensed?

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

Initial Training

  1. Take an 8-hour Initial RRP training by searching on the EPA’s website or the Zack Academy website for an initial "renovator” course. Make sure it is an “initial” course. You can check neighboring states for conveniently located courses. For example, you can take the course in New York, New Hampshire or Massachusetts and then apply for a Lead-Safe RRPM license in Vermont. This training certificate is good for 5 years.
  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.

Refresher Training

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

  1. Take an accredited 4-hour RRP Refresher training in-person every 5 years by searching on the EPA’s website or the Zack Academy website for a refresher "renovator” course. Make sure it is a “refresher” course. 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.
  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. 

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 licenses

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

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Which educational materials do I need to provide?

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

Below you will find information related to how work needs to be performed based on the type of housing or facility.

Rental Housing

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 both the RRPM Supervisor and RRPM Firm licenses if you are doing work on your own rental housing property.

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. 

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

Owner-Occupied Housing

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

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 RRP training by searching on the EPA’s website or the Zack Academy website for a "renovator” course. If this is the first time you are taking this course, look for an “initial” course. Be sure to check neighboring states for conveniently located courses. For example, you can take the course in New York, New Hampshire or Massachusetts and then apply for a UCCO Certification in Vermont. 
  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.
  3. Apply for the Uncompensated Child Care Operator Certification. This certification must be renewed every year and is free. 

Refresher Training

To maintain your Uncompensated Child Care Operator certification – and before your previous RRP training certificate expires – you need to:

  1. Take an accredited 4-hour RRP Refresher training in-person every 5 years by searching on the EPA’s website or the Zack Academy website for a "renovator” course. Make sure it is a “refresher” course. 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.
  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. 
  3. Apply for the Uncompensated Child Care Operator Certification. This certification must be renewed every year and is free. 

apply for the ucco certificate

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

can't find an rrp training? let us know

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

For Homeowners and Renters: What to ask, what to look for, and how to report a concern

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.

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 received RRPM educational materials from the contractor before the work begins.

Workers are required to give you (the homeowner, tenant or child care operator) a copy of:

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.