Lead-Based Paint Renovation Rule

The Lead-Based Paint Renovation Rule, effective April 22, 2010, is an EPA rule affecting construction contractors, residential landlords, property managers and others who perform “renovations” for compensation in housing that may contain lead-based paint – that is, built before 1978.  The term “renovation” includes most repair, remodeling and maintenance activities that disturb painted surfaces. 

BEFORE STARTING A RENOVATION:  Within 60 days prior to commencing the renovation, renovators must give to the owner or occupant of the dwelling the EPA pamphlet entitled, “Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools.”

This pamphlet is found can be found online at: http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf. 

The renovator must obtain written acknowledgment that the owner or occupant has received the pamphlet.

CERTIFICATION AND TRAINING:  Beginning April 22, 2010, firms doing “renovations” in pre-1978 homes will need to be certified.  The Rule specifies the requirements of renovators to become certified.

 RENOVATION:  The requirements of the Rule apply to renovations performed for compensation within and on the exteriors of “target housing” units, including renovations in the common areas that are routinely used by children under age six. 

 Renovations include the removal, modification or repair of painted surfaces or painted components; including the sanding or scraping of doors, window frames, walls, ceilings, etc.  However, this does not include minor repair and maintenance activities as defined by the Rule.

For example, if the renovation job will require the disturbance of more than 6 square feet of paint per room in the interior, or more than 20 square feet of paint in the exterior in pre-1978 housing, then the person doing the renovation is a “renovator” for the purposes of this Rule.

COVERED PROPERTIES:  The Lead Renovation Rule applies to “target housing” which any housing constructed before 1978, except: 

(1)  housing for the elderly or persons with disabilities (unless any child under age six resides or is expected to reside in the housing).  The Rule defines what is meant by housing wherein a child under six years of age resides.

(2)  Any zero-bedroom dwelling;

(3)  Work that is performed for free;

(4)  Work performed by do-it-yourselfers in their own homes;

(5)  Work that is performed during an emergency;

(6)  Housing that has been already been determined to be lead free by a Certified Risk Assessor, Lead Inspector, or Certified Renovator;

(7)  Minor repairs that disturb 6 square feet or less of paint per room in the interior, or 20 square feet or less of paint in the exterior.

For further information see the CAR Legal Memo:  Federal Lead-Based Paint Renovation Rule” at:



http://www.car.org/legal/legal-questions-answers/2010-qa/fed-lead-paint-renovation/?redirectFrom=login