Lead paint and exterior work on older homes: what the EPA's renovation rule requires
Updated · KeystoneProGuide editorial team
Does the lead rule apply to exterior work?
Yes, and exterior remodeling is squarely inside it. The EPA's Renovation, Repair and Painting (RRP) Rule requires anyone paid to perform work that disturbs painted surfaces in a home built before 1978 to be certified, and their workers trained in lead-safe practices. Its list of covered activities names remodeling, repair, carpentry, painting preparation and window replacement. Replacing windows, pulling off old siding or trim, rebuilding a painted porch and stripping a door all disturb paint.
Pennsylvania does not run its own version of the program; the EPA lists the states it has authorized, and Pennsylvania is not among them. So the EPA administers the rule here, and its pages are the authority.
Why does it matter so much here?
Because the paint is old and common. The EPA says the federal government banned consumer use of lead-based paint in 1978, that homes built before then are more likely to have it, and that about three-quarters of U.S. homes built before 1978 still contain some. In Pennsylvania, the Census Bureau estimates that 25.0 percent of homes were first built in 1939 or earlier, and in Philadelphia 39.9 percent; the Census pages give no share for all homes built before 1978.
The EPA is specific about the risk. It says children can live safely in these homes as long as paint and surfaces are in good condition and kept clean; the danger comes when paint deteriorates or is disturbed. Worn paint on surfaces that rub, like doors and window sills, can produce chips and dust, and the EPA says renovation that creates even a small amount of lead dust is enough to poison a child.
Which jobs are exempt, and which never are?
The EPA's contractor page lists what the rule does not cover:
- housing built in 1978 or later;
- components declared lead-free by a certified inspector or risk assessor, or by a certified renovator using an EPA-recognized test kit or lab samples;
- minor repair and maintenance that disturbs 6 square feet or less of paint per room inside, or 20 square feet or less on the exterior.
The small-job exemption has two exceptions that matter for this trade: window replacement and demolition of painted surfaces are always covered, whatever the area. Replacing a single window in a house built before 1978 is covered work.
What must a certified firm do?
Before work starts, give you the EPA pamphlet Renovate Right and document that you received it. During the job, follow the EPA's lead-safe work practices: contain the work area so dust and debris cannot escape, avoid prohibited methods such as open-flame burning and power tools without HEPA exhaust control, and clean up thoroughly, followed by a verification procedure. The firm must keep copies of the certified renovator's course certificates on the job site, and keep records for each job for three years, including proof that you got the pamphlet and any test results.
ENERGY STAR repeats the point for window buyers: contractors replacing windows must use lead-safe practices, and must provide a brochure to homeowners before beginning a window, door or skylight replacement.
Do you have to test the paint?
No, but the rule then assumes the worst. The EPA says paint testing is not required, but unless there is documentation that the paint is not lead-based, the rule's requirements apply. If you or the contractor choose to test, it must be done by the right person on every surface the work will touch: EPA-recognized test kits by certified renovators, and X-ray fluorescence by certified inspectors or risk assessors. Paint chip samples can be taken by any of them.
Is this the same as lead abatement?
No. The EPA says abatement, which is designed to permanently remove lead hazards and often starts with an inspection or risk assessment, is a separate program with different certifications. A window or siding contractor works under the renovation rule. In Pennsylvania, the Department of Labor and Industry certifies lead removal contractors and workers.
What if you rent, or rent out?
If you are a tenant in a pre-1978 rental, the EPA says your landlord must comply with the rule when doing work that disturbs paint. If you are a landlord, the rule applies to you even when you do the work yourself, and it also applies to anyone who buys, renovates and sells homes for profit, or runs a child care center at home.
And if you do the work yourself in your own home?
The rule generally does not apply, but the EPA still recommends hiring a certified contractor. If you go ahead, it sets out do-it-yourself lead-safe practices: find out whether lead paint is present, set up safely, protect yourself, minimize dust, leave the area clean every day, control waste and clean once more. Its advice includes a disposable N-100 respirator, misting before sanding or cutting, and a HEPA vacuum.
What should you ask a contractor?
Ask for the firm's EPA certification and the name of the certified renovator on your job, ask when you will receive Renovate Right, ask how the work area will be contained outside, and ask what the cleaning verification will be. A contractor who says the rule does not apply to a pre-1978 window job, without a test result to show you, is wrong about the rule.
Where can you report a problem?
The EPA says suspected violations can be reported to the National Lead Information Center at 1-800-424-5323 or online. Before hiring, questions to ask covers the rest of the checks, and what Pennsylvania requires the state rules that sit alongside this federal one. Listed businesses are on the exterior remodeling directory page.
Sources
- Renovation, Repair and Painting (RRP) Program: Consumers, U.S. Environmental Protection Agency
- Lead Renovation, Repair and Painting Program, U.S. Environmental Protection Agency
- Renovation, Repair and Painting Program: Contractors, U.S. Environmental Protection Agency
- Renovation, Repair and Painting Program: Work Practices, U.S. Environmental Protection Agency
- Lead-Safe Renovations for DIYers, U.S. Environmental Protection Agency
- Residential Windows, Doors, & Skylights, ENERGY STAR (U.S. Environmental Protection Agency)
- Contractor Licensing, Pennsylvania Department of Labor and Industry
- 2020-2024 ACS 5-Year Narrative Profile: Pennsylvania, U.S. Census Bureau
- 2020-2024 ACS 5-Year Narrative Profile: Philadelphia County, Pennsylvania, U.S. Census Bureau