My firm has been hired to replace windows in a home built before 1978. The existing windows are mil-finish (i.e.: not painted) aluminum. We plan to use the "insert" method of replacement where we remove the existing sash and attach the new window's frames inside the old frames. Because we will not disturb a painted surface (our work remains inside the mil finished aluminum), is this activity subject to the RRP ruling?
No. The activity described above does not disturb a painted surface. Therefore, the requirements of the RRP Rule do not apply.