When replacing an old wood door and frame with a new steel entry door and frame, how do I determine whether the job qualifies as a minor repair and maintenance activity?  Do I calculate the amount of painted surface disrupted using the standard for interior renovations (six square feet or less in the room where the door is located) or for exterior renovations (20 square feet or less)?

Answer: If replacing the door and frame disrupts more than 6 square feet of interior painted surface in the room where the door is located, or more than 20 square feet on the exterior of the building, the job does not qualify as a minor repair and maintenance activity, and the Lead Renovation, Repair, and Painting (RRP) Rule applies. Calculate the area of painted surface disrupted based on the surface area of the component that is disrupted. In addition, to qualify as a minor repair and maintenance activity, the job must not use prohibited practices or involve window replacement or demolition of painted surfaces.  

Question Number: 23002-23857

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