Most of the housing stock we work in was built before 1978. Bungalows, Georgians, greystones, two-flats, ranches and split-levels across the south and southwest suburbs — the great majority of them predate the residential lead paint ban.
That means a federal rule governs how work gets done in your house. It affects how the job site looks, how long cleanup takes, and which contractors are legally allowed to do the work at all. It’s worth understanding as a homeowner, because it’s also one of the clearest ways to tell a professional operation from a cheap bid.
What the rule actually is
The EPA’s Renovation, Repair and Painting rule — everyone calls it RRP — has been in force since April 2010. It applies to anyone who is paid to perform work that disturbs painted surfaces in housing built before 1978, or in child-occupied facilities like daycares and preschools.
The firm doing the work must be EPA-certified. At least one certified renovator, trained through an accredited course, must be assigned to the job, and other workers must be trained on lead-safe practices. Certification runs five years.
There’s a minimum threshold. The rule kicks in when work disturbs more than six square feet of interior painted surface per room, or more than twenty square feet on the exterior. Window replacement and demolition of painted surfaces are covered regardless of area.
Six square feet is a small area. A kitchen demo passes it in the first ten minutes.
One thing worth knowing: the rule generally doesn’t apply to homeowners doing work in their own home. That’s a legal distinction, not a safety one — the dust behaves identically either way.
Why it exists
Lead-based paint isn’t dangerous sitting intact on a wall. It becomes dangerous when it’s sanded, scraped, cut, or demolished, because that produces fine lead dust that settles across the whole house and doesn’t clean up with a broom and a shop vac.
Lead exposure causes permanent neurological damage in young children at levels that produce no visible symptoms. That is the entire reason for the containment and cleanup requirements — the dust, not the paint.
This is also why the rule matters more in a lived-in remodel than an empty one. If your family is staying in the house while the kitchen is out of commission, the dust boundary between the work zone and where your kids sleep is doing real work.
What compliance looks like on your job
If you’ve hired a compliant contractor for a pre-1978 home, you should see all of the following:
- A pamphlet, before work starts. The EPA requires that you receive a lead hazard information pamphlet and acknowledge it before renovation begins. If nobody has given you one, that’s your first signal.
- Testing, or an assumption. A certified renovator can test the surfaces being disturbed with an EPA-recognised kit. If they don’t test, they must assume lead is present and follow full practices — which is often the simpler choice.
- Containment. Plastic sheeting over floors and surfaces, doorways sealed, HVAC registers covered so dust isn’t distributed through the ductwork, and signage at the work area.
- Prohibited practices avoided. No open-flame burning, no high-temperature heat guns, no power sanding or grinding without HEPA attachment, no dry scraping beyond limited areas.
- HEPA cleanup and verification. HEPA vacuuming and wet wiping, followed by a defined cleaning verification procedure before the containment comes down.
- Records. The firm must retain documentation of compliance for three years.
What this means for you in practical terms: a lead-safe job site looks more contained and takes longer to clean up at the end of each phase than one that isn’t following the rules. That’s the point.
The enforcement side
Penalties under this rule are substantial — federal civil penalties run into tens of thousands of dollars per violation, per day, adjusted annually for inflation, and they can stack across separate requirements on a single job. The EPA has brought enforcement actions against national retailers and their contractor networks, not just small operators.
For a homeowner, the exposure is different but real. A contractor who isn’t certified may not have insurance that responds to a lead claim — general liability policies commonly exclude pollution, including lead. If lead dust becomes an issue in your home after an uncertified renovation, the question of who pays gets complicated quickly.
What to ask before you sign
- Is your firm EPA lead-safe certified, and can I see the certificate?
- Who is the certified renovator assigned to my job?
- Will you test the surfaces you’re disturbing, or assume lead is present?
- How will you contain the work area, and what happens to my HVAC system during the work?
- What does your cleanup and verification process look like at the end?
A contractor working properly in older homes will answer these without hesitation. A contractor who reacts as though the questions are unusual is telling you something.
How this affects an older Chicago-area remodel
Two situations come up constantly in our work.
Opening a wall. Any structural change in a pre-1978 house means cutting through painted plaster or drywall, well past the six-square-foot threshold. We cover the wider set of surprises in opening a wall in older Chicago homes.
Bathroom demolition. Old bathrooms are full of painted plaster, painted trim and painted window casings, and the room is small enough that containment is straightforward but the dust concentration is high. See behind the walls of older Chicago bathrooms.
Painting work in older homes falls under the same rule when surfaces are being prepped by sanding or scraping — it isn’t only demolition that counts. That’s part of how we approach interior painting in older housing.
The short version
If your home was built before 1978 and someone is being paid to disturb painted surfaces in it, federal rules apply to how that work is done. Those rules exist to keep lead dust out of the rest of your house, and they add time and process to a job for a reason worth accepting.
When you’re comparing bids on an older home, the cheapest one is sometimes cheaper because it isn’t doing this. That’s worth knowing before you choose. Read more about how we work, or request a quote.