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.    

Question Number: 23002-15684

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