The regulations that impact projects involving lead-related renovation inside California can be confusing.  This page will discuss the EPA RRP rule as well as the San Diego specific lead-based paint ordinance.  Lead-related renovation applies to all pre-1979 construction where no testing has been performed to identify lead-based paint coated components.  If testing is performed the renovator can identify which components are coated with lead-based paint and which are not.  Lead-related renovation may be performed by renovation contractors, handymen, painters, property management employees and property owners.

The Lead-Safe Certified Guide to Renovate Right (epa.gov)

California Lead Related Construction Regulations:

Environmental Protection Agency (EPA) - Responsible of the Renovation, Repair and Painting (RRP) Rule which requires training and certification for anyone working for compensation in pre-1978 residential structures, day care centers and schools where known or assumed lead-based paint is impacted.  www.epa.gov/getleadsafe/

California Department of Public Health (CDPH) -  Created Title 17 which includes lead testing and abatement provisions in residential and public structures in California.  A number of important definitions are contained in Title 17 including Abatement, Clearance Inspection, Containment, Lead-Based Paint, Lead Contaminated Dust and Soil, Lead Hazard and Lead Hazard Evaluation.  Title 17 establishes that lead testing be performed using XRF methods or paint chip sample collection and analysis.  Lead Test Kits are not Accepted.  It also establishes testing in California be performed by a State certified Lead Inspector/Risk Assessor if the testing is related to a project involving compensation. www.cdph.ca.gov/programs/CLPPB/Documents/Title17.pdf

Department of Housing and Urban Development (HUD) - Created the HUD Guidelines, Title X,  which contains protocols for lead testing and abatement.  Specific protocols in the HUD Guidelines are required by  both Title 17 and by the City of San Diego Lead Ordinance.  http://portal.hud.gov/hudportal/HUD?src=/program_offices/healthy_homes/enforcement/regulations 

City of San Diego - Lead Hazard Prevention and Control Ordinance, this ordinance supercedes the EPA's RRP rule and is more expansive in it's scope.  This ordinance applies to everyone that disturbs paint on pre-1979 structures of any kind, whether there is compensation involved or not.  Additionally this ordinance applies to demolition projects, whereas the RRP rule does not.  Depending on the scope of the renovation activity the City of San Diego ordinance requires clearance dust/soil sampling by a DPH certified Lead Inspector or Clearance Technician.  This ordinance also specifies that renovators conducting work on pre-1979 construction "self-certify" clearances for any paint that contains lead greater than 1,000 ppm or 0.5 mg/centimeter squared, this is half of the threshold for lead-based paint identified by both the City of San Diego and the EPA's HUD regulations.  http://www.sandiego.gov/environmental-services/pdf/ep/081017leadord.pdf

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