Key takeaways
- Homes built before 1978 may have lead-based paint under newer coats. The hazard comes from dust and chips when old paint is disturbed.
- EPA's Renovation, Repair and Painting (RRP) rule covers paid work that disturbs more than 6 square feet per room inside or 20 square feet outside.
- The firm must be certified, and a certified renovator must be assigned to the job.
- Open-flame burning, high-temperature heat guns and power sanding without HEPA dust collection are not allowed on covered work.
- Ask for certificates, the Renovate Right pamphlet and a written scope that names the lead-safe steps.
Why 1978 is the line
The federal government banned lead-based paint for residential use in 1978. Houses built before then may still have it, usually buried under later coats, and the older the house the more likely it is. Denver has whole neighborhoods of bungalows, Victorians, Tudors and mid-century ranches that fall on the older side of that line.
Lead paint that is intact and covered is a much smaller hazard than lead paint that is chipping or being disturbed. Painting is exactly the kind of work that disturbs it: scraping, sanding and removing old coatings create fine dust that settles on floors, window sills and soil. Young children and pregnant women are at the greatest risk from that dust, which is why the rules focus on how the work is done.
What the RRP rule covers
The EPA Renovation, Repair and Painting rule has required lead-safe work practices since 2010. It applies to contractors, painters, property managers and landlords who are paid to work on housing or child-occupied facilities, such as daycares, built before 1978.
- Interior: work that disturbs more than 6 square feet of painted surface in a room.
- Exterior: work that disturbs more than 20 square feet of painted surface.
- Always covered: window replacement and demolition of painted surfaces, regardless of size.
Small jobs under those thresholds are treated as minor repair and maintenance, but the safest approach on an older house is still to work lead-safe.
Certified firm, certified renovator
Two certifications matter. The firm must be certified, either by EPA or by a state program EPA has authorized. And at least one certified renovator, someone who has completed an EPA-accredited training course, must be assigned to the job, direct the lead-safe steps and train the rest of the crew in them. Ask to see both certificates. A painter who does this work regularly will not mind.
What lead-safe work looks like
- Before work starts you receive EPA's Renovate Right pamphlet, which explains the hazard and the rule.
- The work area is contained. Inside, that means plastic sheeting on floors, doors closed or sealed and HVAC vents covered. Outside, sheeting runs out along the ground beneath the work, and nearby windows and doors stay closed.
- Some methods are prohibited on covered work: open-flame burning or torching, heat guns at 1100°F or higher, and power sanding, grinding, planing or blasting unless the tool has a shroud and HEPA vacuum attachment.
- Dust is kept down. Misting and wet scraping, HEPA vacuums rather than shop vacs, and debris bagged before it leaves the work area.
- Cleanup is verified. After interior work, surfaces are wiped and checked against EPA's cleaning verification card before the area is released.
- Records are kept by the firm for three years.
Testing before the work starts
There are three common paths. A firm can simply assume lead is present and work lead-safe throughout. A certified renovator can use an EPA-recognized test kit on the surfaces being disturbed. Or a certified lead inspector or risk assessor can take paint samples or use an XRF analyzer, which gives the most complete answer for the whole house.
How it shows up in an estimate
Lead-safe work takes more setup, slower preparation and a more careful cleanup, so on an older house it should be visible in the scope rather than hidden. A written estimate should say whether the house is being treated as containing lead, which surfaces are affected and how preparation and cleanup will be handled. Two bids that differ a lot on a pre-1978 exterior often differ exactly here.
If you are doing the work yourself
The RRP rule applies to people paid to do the work, not to homeowners working on the house they live in. The dust is just as hazardous either way. Skip dry sanding and dry scraping, avoid heat guns, keep children and pregnant family members away from the work area, contain dust with plastic sheeting and clean up with a HEPA vacuum and wet wiping.
Questions to ask any painter
- Is your firm lead-safe certified, and who is the certified renovator on my job?
- Are you assuming lead is present, or testing? Which surfaces?
- How will you contain dust inside and outside?
- Which removal methods will you use, and which will you avoid?
- How do you clean up and verify the cleanup?
- Will the lead-safe steps be written into the scope?
The bottom line
On a house built before 1978, how old paint comes off matters as much as how new paint goes on. Hire a certified firm, expect containment and careful cleanup, and make sure the estimate says so. If you are not sure when your house was built, the county assessor's record usually lists the year.
