Does my contractor need EPA lead certification?
Toshikatsu Oga / September 27, 2026If your house was built before 1978, usually yes. Under the EPA's Renovation, Repair and Painting Rule, a firm paid to do work that disturbs painted surfaces in a home, childcare facility or preschool built before 1978 must be EPA certified (or certified by a state that runs its own program) and must assign a certified renovator to the job (EPA, Lead Renovation, Repair and Painting Program; 40 CFR 745.89). The exception is minor repair and maintenance: 6 square feet or less of painted surface per interior room, or 20 square feet or less outside, and window replacement and demolition are never minor (40 CFR 745.83). Exterior painting, window replacement, siding and any job that scrapes or cuts painted trim on a pre-1978 house is inside the rule, and the certification number belongs on the quote.
What the rule requires
- A certified firm. Firms that perform renovations for compensation must apply to EPA for certification, and must ensure a certified renovator is assigned to each renovation (40 CFR 745.89). Some states run their own programs in place of EPA's.
- The pamphlet. Before starting, the firm must give the owner the lead hazard information pamphlet, no more than 60 days before the work begins, and get a written acknowledgment that you received it (40 CFR 745.84). If you were never handed a pamphlet on a pre-1978 house, the firm has already missed a step.
- Work practices. Containment of the work area, no open-flame burning or high-speed sanding without HEPA capture, cleaning to a standard, and a certified renovator on site for the key steps. The details are in the rule; what you can check from the driveway is plastic sheeting, a sealed work area and a HEPA vacuum.
When it does not apply
Housing built in 1978 or later is outside the rule. On a pre-1978 house, work that stays under the minor repair thresholds (6 square feet per interior room, 20 square feet exterior) is outside it, unless it is window replacement or demolition of painted surfaces (40 CFR 745.83). And a renovation is exempt where a certified inspector or risk assessor has made a written determination that the components affected are free of lead-based paint (40 CFR 745.82). A contractor's own opinion that "there's no lead in that paint" is not that determination; a test by a certified inspector is.
A reroof that does not disturb painted trim is usually outside the rule; a reroof that replaces painted fascia or soffit on a 1960s house is not. Ask the contractor which it is, and ask how they know.
Why it shows up on quotes, and why it matters for price
Lead-safe work costs more. Containment, cleaning, a certified renovator and the paperwork add hours, and a certified firm will price them; an uncertified firm that skips them will be cheaper and will leave lead dust in a house where children live. That is one of the reasons two quotes for the same exterior repaint can be far apart, and it is a legitimate reason as long as the quote says so. Our reports ask, on every pre-1978 house, whether the firm's certification number is on the quote, and put the question in the letter if it is not; the hearing before a report asks the year the house was built for exactly this purpose.
What to do
- Find the year the house was built. The county appraisal record has it.
- If before 1978 and the work will disturb painted surfaces, ask for the firm's EPA (or state) certification number and check it in the EPA locator (EPA, find a certified firm).
- Ask for the pamphlet and sign the acknowledgment; keep a copy.
- If the contractor says the paint is lead-free, ask for the inspector's written determination.
- Expect the quote to carry lines for containment and cleanup, and compare quotes on that basis rather than on the total alone. How to line quotes up is in writing a scope of work before you get quotes.
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Questions
Does the EPA lead rule apply to my house?
If it was built before 1978 and the work disturbs more than 6 square feet of painted surface per interior room or 20 square feet outside, or replaces windows or demolishes painted surfaces, yes. Houses built in 1978 or later are outside the rule.
How do I check whether a contractor is EPA lead certified?
Ask for the firm's certification number and look it up in the EPA's certified firm locator. Some states run their own programs in place of EPA's.
Does the contractor have to give me a lead pamphlet?
Yes. Under 40 CFR 745.84 the firm must give the owner the lead hazard information pamphlet no more than 60 days before starting and obtain a written acknowledgment.
Can my contractor just tell me the paint has no lead?
A contractor's opinion is not the exemption. The rule exempts a renovation only where a certified inspector or risk assessor has made a written determination that the affected components are free of lead-based paint.
Sources
Every figure above links to the public record it comes from. The wage, import, margin and markup figures are the ones our reports use, published as USCCDB v1.0 under CC BY 4.0. Statutes and city pages are quoted as published on September 27, 2026; check the source for changes.
- U.S. Environmental Protection Agency, Lead Renovation, Repair and Painting Program
- 40 CFR Part 745, Subpart E, Residential Property Renovation (Sections 745.82, 745.83, 745.84, 745.89)
- U.S. Environmental Protection Agency, Locate Certified Renovation and Lead Dust Sampling Technician Firms
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