Lead paint and small repairs in older homes: what the EPA requires of a handyman
Updated · KeystoneProGuide editorial team
Does a handyman need lead certification?
In a home built before 1978, often yes. The Environmental Protection Agency's Renovation, Repair and Painting rule requires anyone paid to do work that disturbs painted surfaces in pre-1978 housing to be certified, and that includes every firm, even a sole proprietor. The EPA names carpenters, painters, plumbers and electricians among the trades it covers, and lists carpentry, painting preparation, repair and maintenance among the covered activities. Firms cannot advertise or do covered work without firm certification.
Pennsylvania does not run its own version of the program, so the federal rule applies here as written.
Why does the rule exist?
Because lead dust is easy to make and hard to see. The EPA says about three-quarters of U.S. homes built before 1978 still contain some lead-based paint, and that any renovation, repair or painting project in such a home can easily create dangerous lead dust. Children can live safely with lead paint that is in good condition and kept clean; the hazard comes when it is disturbed or worn, especially on surfaces that rub, such as doors and window sills.
What is the small-job exemption?
The rule does not cover minor repair and maintenance that disturbs six square feet or less of paint per room inside, or 20 square feet or less on the exterior. Three conditions come with it: the job must not be window replacement, it must not demolish painted surfaces, and it must not use a practice the rule prohibits. Those limits apply regardless of size.
The EPA's own answers to contractors explain how the limits are counted, which matters for a handyman's list of small jobs:
- Per room, over 30 days. The six-square-foot limit applies to each room and includes all work done in that room in any 30-day period. Three small jobs in one room in the same month are added together.
- One total outside. The 20 square feet outside is for the whole exterior, not per side.
- Whole components count. When a painted part is cut or removed, the area counted is the surface of the part. Trimming a 1-inch strip off a 36-inch door disturbs 36 square inches, whatever the width of the saw blade.
- Demolition is never minor. Knocking a hole in a wall with a hammer is demolition, even if the hole is only about two feet on each side, so the exemption does not apply. Cutting the same hole out cleanly, without destroying the piece removed, is not demolition.
What about windows?
Replacing a window is covered at any size. Repairs are measured. The EPA says replacing a pane of glass or fixing a broken window balancer is not window replacement, but is covered unless it stays within the six-square-foot limit, and it notes that old glazing putty is painted and must come out to change a pane. Drilling holes in a window frame to hang shades or shutters is minor maintenance as long as the room stays under the limit within 30 days.
Does the paint have to be tested?
No, but untested paint is treated as lead paint. The EPA says testing is not required, but that unless there is documentation the paint is not lead-based, the rule applies. A certified renovator can test specific components with an EPA-recognized kit; certified inspectors and risk assessors can test the whole home.
Which homes and jobs are outside the rule?
Homes built in 1978 or later; housing for elderly or disabled people, and studio-type dwellings, unless a child under six lives or is expected to live there; and components a certified professional has declared lead-free. Ceramic tile glaze is not a painted surface, so disturbing it is not covered. The rule also does not apply to unpaid work by friends, relatives or volunteers, though the EPA warns that such work can still create hazardous dust. Vacant homes are not exempt.
Can you do the work yourself?
Usually the rule does not apply to owners working on their own home, unless they rent part of it out, run a child care center there or renovate homes to sell. The EPA still recommends hiring a lead-safe certified contractor, and its do-it-yourself guidance sets out what to do if you go ahead: contain the area with plastic sheeting, turn off forced-air heating and cooling and cover the vents, wear a disposable N-100 respirator, coveralls, eye protection and gloves, mist surfaces before sanding, scraping or drilling, use a HEPA vacuum, and clean the area again before anyone returns. Its list of dust-reducing tools includes a low-temperature heat gun, under 1,100 degrees Fahrenheit.
What do local health departments add?
Delaware County, where the average home was built in 1956, says all repairs that disrupt paint in pre-1978 homes should be done by a lead-certified contractor, and suggests covering loose or chipping paint with heavy tape, paneling, contact paper or furniture until then. A child with a blood-lead level of 3.5 micrograms per deciliter or higher qualifies the home for a free lead inspection under a statewide program.
Montgomery County's Lead Hazard Control Program, for pre-1978 homes with a young child or a pregnant woman and incomes under its limits, sends a certified inspector and a certified abatement contractor to repair hazards at no cost to the owner. Philadelphia has the oldest housing of the five counties: about four in ten homes were first built in 1939 or earlier.
What should you ask?
"Is your firm EPA lead-safe certified, and will this job stay under the small-job limit?" If not, ask how they will contain and clean up. The EPA keeps a search tool for certified firms and takes reports of violations through the National Lead Information Center, 1-800-424-5323. More questions are in what to ask before you hire, and the Delaware County guide covers the county with the second-oldest housing of the five.
Sources
- Frequent Questions About Renovations Covered by the RRP Rule, U.S. Environmental Protection Agency
- Lead Hazard Control Program, Montgomery County
- 2020-2024 ACS 5-Year Narrative Profile: Philadelphia County, Pennsylvania, U.S. Census Bureau
- Lead Renovation, Repair and Painting Program, U.S. Environmental Protection Agency
- Renovation, Repair and Painting Program: Contractors, U.S. Environmental Protection Agency
- Lead-Safe Renovations for DIYers, U.S. Environmental Protection Agency
- Lead Free 1-2-3, Delaware County