Lead-Related Renovation Regulations
California Occupational Safety and Health Administration (Cal/OSHA) - Responsible for CCR Title 8 Section
1532.1 which contains safety provisions that protect employees in construction that may be occupationally
exposed to lead.
1532.1 which contains safety provisions that protect employees in construction that may be occupationally
exposed to lead.
This page discusses regulations that impact projects involving lead-related renovation*
inside California, and then specifically in the City of San Diego. A handy one page
guide is provided that considers both the EPA RRP Rule and the City of San Diego
Lead Ordinance when performing lead-related renovation inside the City. It steps
through primary requirements and at what point each is triggered.
inside California, and then specifically in the City of San Diego. A handy one page
guide is provided that considers both the EPA RRP Rule and the City of San Diego
Lead Ordinance when performing lead-related renovation inside the City. It steps
through primary requirements and at what point each is triggered.
*On this site the term "lead-related renovation" refers to projects that impact pre-1979
paint where the paint has not been tested in advance and shown to have lead below
threshold levels. Lead-related renovation may be performed by renovation contractors,
handymen, painters, property management employees, and property owners.
paint where the paint has not been tested in advance and shown to have lead below
threshold levels. Lead-related renovation may be performed by renovation contractors,
handymen, painters, property management employees, and property owners.
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Regulations That Apply In All of California
Environmental Protection Agency (EPA) - Created 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. The EPA website with
complete information on this regulation is located here.
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. The EPA website with
complete information on this regulation is located here.
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 equipment or by paint chip sample analysis in California. Lead test kits are not accepted. It also
establishes testing in California be performed by a State certified lead inspector/assessor if the testing is
related to a project involving compensation.
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 equipment or by paint chip sample analysis in California. Lead test kits are not accepted. It also
establishes testing in California be performed by a State certified lead inspector/assessor if the testing is
related to a project involving compensation.
Department of Housing and Urban Development (HUD) - Created the HUD Guidelines which contain 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.
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.
Department of Toxic Substance Control (DTSC) - Responsible for "Title 22" regulations which concern
management of hazardous waste including lead waste.
management of hazardous waste including lead waste.
Additional Requirements if Inside the City of San Diego
The City of San Diego Lead Hazard Control Ordinance has a broader application
than the EPA RRP Rule because it applies to everyone that disturbs paint on
pre-1979 structures of any kind regardless to whether compensation is involved.
Additionally, the San Diego lead ordinance applies to complete demolition of
structures whereas the EPA RRP Rule does not. It requires a clearance
inspection by a certified lead inspector/assessor for most projects that impact
known or assumed lead-based paint. The full text of the City of San Diego
Lead Ordinance is located here.
than the EPA RRP Rule because it applies to everyone that disturbs paint on
pre-1979 structures of any kind regardless to whether compensation is involved.
Additionally, the San Diego lead ordinance applies to complete demolition of
structures whereas the EPA RRP Rule does not. It requires a clearance
inspection by a certified lead inspector/assessor for most projects that impact
known or assumed lead-based paint. The full text of the City of San Diego
Lead Ordinance is located here.
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