Renovate Right - EPA Lead Paint Regulation
Note: Iowa has received approval from the EPA to administer this rule at the State level. See THIS ARTICLE for updated information specific to Iowa
Starting on April 22, 2010, every contractor who works on a house built before 1978 or any "child-occupied facility" where work will disturb lead based paint, must have successfully completed a certified renovator course delivered by an EPA-accredited trainer. In addition every firm involved in renovation in target housing must be registered with the EPA. This rule applies, with a few exceptions, to all renovations performed for compensation in target housing and child-occupied facilities. A home owner working on his or her specific owner-occupied housing unit is exempt from the rule, though it is of course strongly recommended that lead-safe work practices be followed.
In a nutshell - covered by the rule is any renovation where the work area will disturb either 1 square foot of painted surface. This includes, but is not limited to:
- Window replacement or repair
- Door replacement or repair
- Gutters
- Trim
- Cabinets
- Blown-in Insulation
- Siding/soffits
- Painting/stripping
- Plumbing, electrical, and HVAC (if walls are disturbed)
- Floor sanding
- Demolition
An owner may request that a certified contractor test hard surfaces (except drywall/plaster) for presence of lead based paint. There is not currently an EPA-recognized field test for lead based paint on drywall/plaster. The owner may contract with a certified risk assessor to do a more comprehensive report with an XRF machine or lab-test samples. In the case that the work area is determined negative for lead based paint, the contractor does not have to utilize lead-safe work practices.
Why is this a big deal? Several reasons - first the good:
- Most contractors have been doing things wrong for a long time. Many common construction practices create lead hazards for occupants, workers, and their families. This rule will help turn the tide and pretty much makes up for all of the "bad" and "ugly" below.
- There will be a lot of consumer education - home owners and tenants will have a greater ability to demand that contractors use lead safe work practices.
Now the bad:
- Becoming a Certified Renovator will cost contractors money and time. The training is 8 hours and firm certification may cost upwards of $300.
- The procedures for establishing a lead safe work environment are logical and necessary, but also time consuming and detail oriented.
- Contractors will assume more liability, and potential fines are steep.
- Contractors as a general rule are relatively resistant to changes and requirements such as this.
It is up to all of us in the residential renovation world to learn about the new requirements, demand that our contractors become certified, and of course, make sure that they follow the necessary lead safe work practices when they are working in our homes. Homeowners must advocate strongly for their own safety even if contractors argue against it.


Rule is more restrictive in Iowa
The EPA renovation rule is not as restrictive as Iowa's rule. Contractors need to be aware that disturbing more the 1 square foot of paint (either interior or exterior) cumulatively must be certified by the State of Iowa in lead safe work practices!
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