--- title: "RRP Question: Does Removing Aluminum Siding Fall Under the RRP Rule?" description: RRP Questions and answers. Does anyone know if the factory paint on aluminum siding has lead in it? image: https://www.shawnmccadden.com/hs-fs/file-15726816-jpg/images/aluminum_siding_drilling_holes-wr.jpg --- [![Shawn McCadden](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1539748069.jpg)](https://www.shawnmccadden.com/) # Welcome to RRPedia Your Interactive Resource for EPA RRP Information ## ![RRPedia logo](https://www.shawnmccadden.com/hs-fs/file-1549005086-jpg/images/RRPedia_Logosmall_-wr-1.jpg)Looking for accurate information about the EPA RRP rule? RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule.  ## Please read *[RRPedia Use and Contribution Information](https://www.shawnmccadden.com/using-and-contributing-to-rrpedia-/) *before using or contributing to RRPedia.   --- # You Can Browse For RRP Topics By Using The Tags List To The Right ## [RRP Question: Does Removing Aluminum Siding Fall Under the RRP Rule?](https://www.shawnmccadden.com/rrpedia/bid/79171/RRP-Question-Does-Removing-Aluminum-Siding-Fall-Under-the-RRP-Rule) Posted by [Shawn McCadden](https://www.shawnmccadden.com/rrpedia/author/shawn-mccadden) on Thu, Jun 21, 2012 @ 05:00 AM - [Tweet](https://twitter.com/share) ## **RRP Question:  Does Removing Aluminum Siding Fall Under the RRP Rule?**   ### **Question:** ![disturbing aluminum siding under the RRP Rule](https://www.shawnmccadden.com/hs-fs/file-15726816-jpg/images/aluminum_siding_drilling_holes-wr.jpg?width=248&height=165&name=aluminum_siding_drilling_holes-wr.jpg)   ***"Theoretically, aluminum siding came with paint on it…..and most was installed before 1978.  Does anyone know if the factory paint on aluminum siding has lead in it?  Intuitively, one would pull it off without concern for lead, but I have a client who has asked specifically."*** Gregory A. Antonioli, GCP, President [Out of the Woods Construction and Cabinetry](http://www.outofthewoodsconstruction.com/)   ### **Shawn’s Answer: ** Greg: ![working on aluminum siding uder the rrp rule](https://www.shawnmccadden.com/hs-fs/file-16140983-jpg/images/working_on_aluminum_siding-wr.jpg?width=217&height=325&name=working_on_aluminum_siding-wr.jpg)The rule includes all painted or coated surfaces.  So yes, the siding must be assumed to have lead until tested otherwise. Note: My opinion as expressed above is based on the fact that the painted surface is being “disturbed”. Here is an [interesting conversation about this topic on the JLC forum](http://forums.jlconline.com/forums/archive/index.php/t-52539.html). Aluminum siding during that era was manufactured by many different companies so it would not be wise to assume they all used the same paint or coating.  Even if you test a product on one house and find it lead free, under the RRP Rule you must assume that same product might have lead if installed on any other building. Here is one that might seem crazy.  Along the same vein, even if you built an addition or deck at a home after 1977, and you know all the products you used were purchased and installed after 1977, if returning to work on the addition or deck you must still assume the addition or deck may contain lead.  The only way around this is to test it to prove the absence of lead under the rule. Something often missed or overlooked is if the original siding under the aluminum siding contains lead.   If you have to remove that siding too or even just disturb more than 20 square feet of the old siding when removing the aluminum siding, then the RRP Rule will apply.   ### **[Here is what the EPA says at their RRP FAQ area](http://toxics.supportportal.com/ics/support/KBAnswer.asp?questionID=32207&hitOffset=242+113+112+48+47+22+13+12+5+4&docID=537) about removing aluminum siding:** ** ** ### **Question: ** I am removing aluminum siding from a pre-1978 home. The aluminum siding was nailed over the top of painted wood siding that tested positive for lead. The underlying painted surface is greater than twenty-square feet. Must I comply with the Rule when removing the aluminum siding? ### **EPA Answer: ** ![EPA logo](https://www.shawnmccadden.com/hs-fs/file-15753787-jpg/images/epa_logo-wr.jpg?width=102&height=102&name=epa_logo-wr.jpg)The work practices for exterior projects are based on a performance standard – if the activity disturbs a painted surface (generally, by creating paint chips or dust) in excess of 20 square feet, the work area must be contained so that dust or debris does not leave the work area while the renovation is being performed. In this case, if the removal of the aluminum siding results in the disturbance of paint in excess of 20 square feet, then the RRP Rule applies. However, if the removal activity could be performed in such a way that does not disturb 20 square feet of painted surface, then the RRP Rule would not apply. EPA recognizes that this may be difficult to determine in advance of the renovation activity. However, the renovator is the person with the expertise and experience to make this determination on a case-by-case basis. In such a situation, a renovator should consider how factors like the condition of the underlying paint or the chosen method of removal may increase or decrease the likelihood for a disturbance of paint. If there is still uncertainty, **EPA recommends that renovators err on the side of caution and be prepared to contain any dust and debris.**   Topics: [RRP Questions](https://www.shawnmccadden.com/rrpedia/topic/rrp-questions), [Sales Considerations](https://www.shawnmccadden.com/rrpedia/topic/sales-considerations), [EPA RRP for Dummies](https://www.shawnmccadden.com/rrpedia/topic/epa-rrp-for-dummies) [![cs-ye-234x16](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1553381212.gif)](http://www.copyscape.com/duplicate-content/) ### Subscribe to RRPedia by Email and get notified about new postings as soon as they happen! ### Are You Documenting Yor Crew's Compliance With The RRP Rule?  [![download free RRP checklist](https://no-cache.hubspot.com/cta/default/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e.png)](https://cta-redirect.hubspot.com/cta/redirect/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e) ### Still Using a Yellow Pad for Your Estimating? 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[Worker Training (15)](https://www.shawnmccadden.com/rrpedia/topic/worker-training) ### I just wanted to say thank you for your efforts to keep us informed.  *"Thank you again for the hundreth time for keeping a vigil on this business nightmare. Your site is one of the best resources we have to stay on level ground"*  **Christian Peter**   *"I am quite impressed with all the confusion out there at Shawn McCadden’s clear and concise voice that continues to help contractors and those involved in this industry truly understand the rule. His efforts should be applauded."*  **Christopher Wagner, LBPFiles**   *"RRPedia is an accurate and contractor friendly interpretation of the very complex and confusing EPA RRP rule"* * * *"Thanks for taking the time to write the blog.  It's about the only place one can go to get some serious info on this dreadful subject"*   *"I would like to begin by thanking Shawn for all of his postings and education that he has been sharing with the remodeling industry. He has personally been extremely helpful in guiding me through various interpretations of the RRP rule, his advice and knowledge are priceless."* **Michael A. Mahoney*** * ### Suggest or Contribute a RRPedia Topic ### Want a Simple Summary of the EPA RRP? #### Shawn McCadden has created an EPA RRP Summary for Remodelers. *"Hi Shawn, **Nice RRP write up on the website.   I've already forwarded a link to it to a number of local builder types."*   #### [Click here to go to the summary.](https://www.shawnmccadden.com/epa-rrp-summary-for-remodelers-by-shawn-mccadden/)  You can also download it if you want your own copy. ### Add this widget to your Web page, blog, or social networking site. A widget is a CDC.gov application that displays the featured content directly on your web page. Click the buttons to see the next tip to prevent lead poisoning.