Lead rule checker
Does the EPA lead rule apply to this job? Six questions, a straight answer, and what to do about it.
People get this wrong in both directions
One manager assumes every old building is covered and pays for containment and certification on jobs that never needed it. Another assumes it doesn’t apply and finds out from a fine. The rule itself is short — two area thresholds, two things that trigger regardless of area, three exemptions, and four answers to “who has to be certified”. It is a decision, so this is a decision tool rather than an article.
The two traps
Full window replacement and demolition are carved out of the exception. The square-footage thresholds belong to the minor repair and maintenance exception, and replacing a whole window is one of the things expressly excluded from it — so the rule applies in pre-1978 housing however small the area. Window troughs and friction surfaces are exactly where lead dust concentrates.
Repairing a window is not replacing it. Sash replacement, glass replacement and balancer work are ordinary jobs measured against the same thresholds as anything else. Treating a glass repair as an automatic trigger sends somebody to buy a certification they do not need, which is its own wrong answer — so the tool asks which of the two you are doing.
The measurement is the whole project, over 30 days. 6 square feet inside a room is about a two-by-three-foot patch, and the threshold is measured per room across a 30-day window — so doing the job over four afternoons does not make it four small jobs. If the scope grows mid-job, the answer can change — which is worth re-checking before the extra work starts rather than after.
Working on your own rental doesn’t exempt you
This is the one that surprises people. An owner-occupant renovating their own home is outside the rule. A landlord doing the same work on a unit they rent out is not — they need firm and renovator certification. Hire an outside contractor instead and the obligation moves to them, but you should ask to see the firm certificate rather than take a logo on a business card for it.
Where it meets the other tools
The PM checklist already flags buildings built before 1978; this is the tool that flag points at. A unit turn almost always means repainting, which is where this question comes up most often in multifamily. Before dispatching a work order to an outside contractor on an old building, this is the check — and their certification sits alongside their insurance on the COI register.
If lead work does go ahead and somebody is hurt doing it, the OSHA 300 log is a separate question with separate rules.
A self-check against the federal Renovation, Repair and Painting rule (40 CFR Part 745, Subpart E), reviewed August 2026. CompliMaint is not EPA, issues nothing, and makes no determination — this records your own answers to the rule’s questions. Not legal advice and not a substitute for the rule. Several states run their own authorized lead programs which can be stricter than the federal floor, so check yours. Confirm current requirements and any firm’s certification status at epa.gov. Everything runs on your device.
Questions people ask
- What size job triggers the EPA lead rule?
- Disturbing more than 6 square feet of interior surface in any one room, or more than 20 square feet of exterior surface, triggers the rule in pre-1978 target housing. Full window replacement and demolition of painted surfaces are excluded from the minor repair and maintenance exception, so they are covered regardless of area — repairing a window (sash, glass, a balancer) is not, and is measured against the thresholds like any other job. The measurement is per room across a 30-day window, so splitting work across several days does not put it under the threshold.
- Do I need to be certified to work on my own rental property?
- Yes. A landlord doing renovation work personally on a pre-1978 rental needs both firm certification and renovator certification. If an employee does the work, the landlord's business needs firm certification and the employee needs renovator certification. If you hire an outside contractor, you do not need certification yourself, but the firm must be an EPA Lead-Safe Certified Firm using a certified renovator. An owner-occupant working on their own home is outside the rule.
- What is target housing?
- Housing built before 1978, with three exclusions: zero-bedroom dwellings such as studios, dormitories and hotel rooms; housing for the elderly or people with disabilities, but only while no child under six lives there; and housing certified free of lead-based paint by a certified inspector or risk assessor. Child-occupied facilities such as daycares are covered alongside housing.
- What must a renovator do once the lead rule applies?
- Give the Renovate Right pamphlet to the owner and occupants before work starts and keep proof; assign a certified renovator to the job; contain the work area with signs, sheeting and closed vents; avoid prohibited practices such as open-flame burning, uncontrolled power sanding or grinding, and heat guns above 1,100 degrees Fahrenheit; clean with HEPA vacuum and wet methods and then perform cleaning verification; and keep the records for three years after completion.