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?
Replacing a pane of glass or fixing a broken window balancer is not a window replacement. However, this activity would be subject to the rule unless it meets the definition of minor repair and maintenance. To be considered minor repair and maintenance, the renovation must not disrupt more than six square feet of painted surfaces per room. Activities such as replacing a piece of glass in a window can disturb paint. The glazing that holds the pane in place in older windows is painted, and this glazing has to be removed for the pane to be replaced. Also keep in mind that when calculating the six square feet when a component is being removed, it's based on the surface area of the component.