If you are paid to do work that disturbs paint in a house built before 1978, the Environmental Protection Agency's Renovation, Repair and Painting rule almost certainly applies to you. EPA's own summary is blunt: anyone paid to perform work that disturbs paint in housing and child-occupied facilities built before 1978 must be certified in lead-safe work practices, and that includes all firms, even sole proprietorships.
The reason is in the paint. EPA says approximately three-quarters of the homes in the United States built before 1978 still contain some lead-based paint. The rule itself goes further and tells you to assume it: lead-based paint is assumed to be present at renovations the rule covers (40 CFR 745.87(e)), unless the paint has been tested in one of the ways described below.
Which jobs it covers
The rule applies to renovations performed for compensation in pre-1978 housing and in child-occupied facilities such as day care centers and preschools (40 CFR 745.82(a) and 745.83). EPA's contractor page lists the work it has in mind: remodeling and repair or maintenance, electrical work, plumbing, painting preparation, carpentry and window replacement. Painting, window and remodeling work is the obvious fit, but an electrician or plumber cutting into a painted wall is inside it too.
EPA's contractor page and the rule list what is not covered:
Homeowners working on their own homes are generally outside the rule, EPA says, unless they rent all or part of the home, run a childcare center in it, or buy, renovate and sell homes for profit.
The minor repair threshold
Small jobs get a pass, within strict limits. Minor repair and maintenance means work that disrupts 6 square feet or less of painted surface per room inside, or 20 square feet or less outside, and only if none of the prohibited practices below are used and the job does not involve window replacement or demolition of painted surfaces (40 CFR 745.83). Two details catch people out. When you remove a painted component, the whole surface area removed counts. And jobs in the same room within 30 days count as one job, emergencies aside.
Some examples, framed as examples:
Two certifications: the firm and the renovator
The firm. A firm that performs renovations for compensation must apply to EPA for certification electronically and pay the fee; EPA approves, asks for more, or denies within 90 days, and an approved certificate expires no more than 5 years after approval (40 CFR 745.89(a)). The fee is $300 for initial certification and $300 to recertify every 5 years (40 CFR 745.92).
The renovator. A person becomes a certified renovator by completing an accredited course (40 CFR 745.90(a)(1)). The initial renovator course must last at least 8 training hours, with at least 2 hours hands-on, and a refresher at least 4 hours (40 CFR 745.225). The refresher is due within 5 years of the initial course; a refresher with hands-on training certifies you for 5 years, one without it for 3 (40 CFR 745.90(a)(4)). Miss the window and you take the initial course again.
Not every worker needs the course. The firm must make sure everyone doing renovation work is either a certified renovator or trained by one, that a certified renovator is assigned to every job, and that the work practices, the pamphlet and the records are all done (40 CFR 745.89(d)). The assigned renovator must be physically present while the warning signs go up, while containment is built and while the work area is cleaned, must regularly direct the others, must be reachable on site or by telephone the whole time work is under way, and must keep copies of their course certificates at the job (40 CFR 745.90(b)).
Before the job: the Renovate Right pamphlet
No more than 60 days before work starts in a home, the firm must give the owner EPA's pamphlet and either get a written acknowledgment that the owner received it or get a certificate of mailing at least 7 days before the work. If the owner does not live there, an adult occupant gets the pamphlet too (40 CFR 745.84(a)). EPA publishes the pamphlet, titled The Lead-Safe Certified Guide to Renovate Right, in English and Spanish; the current version was published in September 2011. The pamphlet step does not apply to emergency renovations, meaning unplanned work after a sudden event that threatens safety or significant property damage (40 CFR 745.82(b)).
On the job: containment, banned methods, cleaning
The work practices are in 40 CFR 745.85. Signs go up marking the work area. Inside, the firm removes or covers furniture and rugs, closes and covers ducts, closes windows and doors, and covers the floor with taped-down plastic at least 6 feet beyond the surfaces being worked. Outside, it closes doors and windows within 20 feet and covers the ground at least 10 feet out, where the property line allows.
Three practices are prohibited or restricted on painted surfaces: open-flame burning or torching is prohibited; high-speed sanding, grinding, power planing, needle guns and abrasive blasting are prohibited unless the machine has a shroud or containment and a HEPA vacuum attachment; and heat guns may be used only below 1,100 degrees Fahrenheit (40 CFR 745.85(a)(3)).
After an interior job, the certified renovator inspects visually, then wipes windowsills, uncarpeted floors and countertops with a damp disposable cloth and compares each cloth with EPA's cleaning verification card, re-cleaning and wiping again as the rule directs when a cloth comes out darker than the card (40 CFR 745.85(b)).
Records and penalties
Keep every record that shows compliance, such as signed pamphlet acknowledgments or certificates of mailing, any lead test results, and the renovator's documentation that the work practices and cleaning verification were done, for 3 years after the job is finished, and produce them if EPA asks (40 CFR 745.86(a)). Breaking the rule violates the Toxic Substances Control Act and can bring civil and criminal sanctions for each violation (40 CFR 745.87). Under the statute, each day a violation continues is a separate violation (15 U.S.C. 2615(a)(1)), and the inflation-adjusted civil penalty is up to $49,772 per violation for penalties assessed on or after January 8, 2025 (40 CFR 19.4).
Some states run their own program
EPA runs the program in most of the country, but it has authorized Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont and Wisconsin, plus one tribal program, to run their own. EPA firm and renovator certification counts only where no authorized program exists (40 CFR 745.89(a) and 745.90(a)). If you work in one of those states, or across a state line into one, get certified under that state's program.
How many homes near you it touches
The Census Bureau's American Community Survey counts homes by the decade they were built. Its 2024 one-year estimates put the United States at about 146.7 million housing units, of which 50.5 million were built before 1970 and another 20.1 million in the 1970s. The survey does not split the decade at 1978, so homes built in 1978 and 1979, which the rule does not cover, are mixed into that 1970s group.
To see your own market, look up table B25034, “Year Structure Built,” on data.census.gov and pick your county. For a painter, a window installer or a remodeler working in an older town, the answer is often that a large share of the jobs are RRP jobs, and the plastic, the HEPA vacuum, the cleaning time and the paperwork belong in the price, not in your margin. The painting, windows and doors and remodeling pages cover pricing for those trades.
General information, not legal or tax advice. Rules change and vary by state; check with the agency named above or a professional for your situation.