On a 1965 house I just need to scrape and repaint one windowsill inside and about a 3x4 foot spot of peeling on the exterior.

Yes, the EPA RRP Rule applies. There is no de minimis exception for interior or exterior work on pre-1978 housing.

The triggers you hit:

• Interior: Disturbing >6 ft² per room. A standard windowsill (stool + apron) is typically 3–4 ft², but scraping the sash, stops, parting beads, and casing almost always pushes the total disturbed area over 6 ft².
• Exterior: Disturbing >20 ft². Your 3×4 ft spot = 12 ft². While this is under the 20 ft² exterior threshold, the combined project (interior + exterior) is considered one "renovation." Since the interior portion triggers the rule, the entire job falls under RRP.

What this means for you (if you are a paid contractor):

1. Firm Certification: Your company must be EPA-certified ($300/5 yrs).
2. Certified Renovator: You (or a supervisor on-site) must have completed the 8-hr RRP initial course (4-hr refresher every 5 yrs).
3. Work Practices: 40 CFR 745.85 — Containment (poly, signs), prohibited practices (open-flame burning, power sanding without HEPA), cleanup verification (cleaning verification card or clearance testing).
4. Records: Retain paperwork for 3 years (pre-renovation education pamphlet receipt, training certs, checklist, photos).

If you are the homeowner doing it yourself: RRP does not apply (owner-occupant exemption, 40 CFR 745.82(a)). However, lead-safe practices are still strongly advised — especially with kids/pregnant occupants. Use wet scraping, HEPA vac, poly containment, and PPE.

Bottom line: If you’re charging for this work, you must follow full RRP protocol. 40 CFR 745 Subpart E.

No, the EPA’s Renovation, Repair and Painting (RRP) Rule does not apply to your project.

The RRP Rule (40 CFR Part 745, Subpart E) applies only when:

• Work disturbs more than 6 square feet of painted surface per room on the interior, or
• More than 20 square feet on the exterior, or
• Work involves window replacement or demolition of painted surfaces.

Your interior windowsill scrape is likely far under 6 sq ft (a typical sill is <2 sq ft). The exterior spot is 3x4 ft = 12 sq ft, which is under the 20 sq ft exterior threshold.

Therefore, RRP certification, containment, and cleanup requirements do not apply.

However — critical caveat: If the house was built before 1978 (yours is 1965), assume lead-based paint is present unless tested otherwise. Even if RRP doesn’t trigger, you must still:

• Use lead-safe work practices: wet scraping, HEPA vacuuming, no dry sanding or power sanding without HEPA containment.
• Wear an N95 or better respirator, gloves, and disposable coveralls.
• Clean up thoroughly with HEPA vacuum and wet wiping.
• Dispose of debris as hazardous waste if lead is confirmed (check local rules).

Recommendation: Buy a $10–$20 EPA-recognized lead test kit (like 3M LeadCheck) to test the sill and exterior spot. If negative, you can proceed with standard precautions. If positive, follow lead-safe practices — even if RRP doesn’t require it, it’s the right and safe thing to do.

You’re doing a small job — stay safe, test first, and work clean. No license needed for this scope, but don’t cut corners on lead safety.