Does the RRP Rule apply to federal employees performing work on federal facilities?
Yes. Federal agencies and their employees must comply with all Federal, State, interstate, and local requirements, both substantive and procedural, respecting lead-based paint in the same manner and to the same extent as any non-governmental entity. In addition, the RRP Rule requires all renovations performed after April 22, 2010, to be performed by a certified firm. The definition of "firm" includes federal agencies. Therefore, if the employees of a federal agency are performing renovations, the agency must be a certified firm and must follow the RRP Rule when performing the renovation.