Yes, almost certainly, if you are paid to disturb painted surfaces in a home, school, or day care built before 1978. The EPA's Renovation, Repair and Painting (RRP) Rule requires your firm to be lead-safe certified and to have a trained certified renovator on the job, and it applies to remodelers, painters, window installers, plumbers, electricians, and anyone else who breaks the paint film. This is the single most commonly violated environmental rule among small contractors, ignorance is not a defense, and the penalty runs into five figures per violation per day. The rule is federal EPA in 2026 under 40 CFR Part 745, though about 20 states run their own authorized version.
What the RRP rule covers
The rule reaches any firm, including a sole proprietor, paid to do work that disturbs painted surfaces in:
- Residential housing built before 1978, and
- Child-occupied facilities (day cares, preschools, K-12 schools) in pre-1978 buildings.
"Disturbs painted surfaces" is broad. It means sanding, scraping, grinding, cutting, drilling, removing windows or doors, demolition, or any similar activity that breaks the paint film. Lead paint was banned for residential use in 1978, so a building's age is your first question. If it went up before 1978, assume lead until a test says otherwise.
The thresholds that trigger full compliance
The rule has a small "minor repair and maintenance" carve-out, but it is smaller than most people think. Full compliance kicks in above:
- More than 6 square feet of interior painted surface per room, or
- More than 20 square feet of exterior painted surface.
And two things trigger the full rule no matter how small the area: any window replacement, and any use of a prohibited practice (open-flame burning, torching, or high-speed dry sanding or grinding). These figures are the federal de-minimis thresholds in 2026, from 40 CFR 745.83.
You are exempt when the housing was built in 1978 or later, when the surfaces have been tested and confirmed lead-free by an EPA-recognized test kit or certified inspector, when a homeowner does their own work in their own home, or for genuine minor touch-ups below the thresholds above.
The two-layer certification
RRP has two separate certifications, and you need both.
- Firm certification. Every firm doing covered work, including sole proprietors, must be EPA lead-safe certified before advertising or performing any RRP work. You apply to the EPA (or your authorized state agency), the fee is typically $300, and it is valid for five years. Let it lapse and the lapse is itself a separate violation.
- Certified renovator. At least one individual on every job must hold the certified renovator credential. That means an 8-hour EPA-accredited training course with a hands-on component and a final exam. It is valid for five years. Renewal has a wrinkle: an online refresher renews you for 3 years, an in-person hands-on refresher renews you for 5 years, and if you let it lapse entirely you have to retake the full 8-hour course.
Any non-certified workers on the same job must be trained on the job by the certified renovator, and that training has to be documented in writing.
The lead-safe work practices
Certification is not just a card. On every covered job the certified renovator has to oversee a defined set of practices.
Before work begins:
- Give the owner or occupant the EPA "Renovate Right" pamphlet and get a signed, dated acknowledgment. The signature must be no more than 60 days before work starts.
- Post warning signs at the entrance to the work area.
- Test the paint or assume lead is present. If you assume, the full practices apply automatically.
During the work, contain it: cover or remove objects with sealed plastic, seal HVAC duct openings, close and cover windows and doors, keep occupants and pets out, and no eating, drinking, or smoking in the area. On exterior jobs, extend plastic sheeting to catch debris at ground level.
Never use a prohibited practice: no open-flame burning or torching of lead paint, no high-speed dry sanding or grinding without a HEPA vacuum attached, and no dry sweeping of lead dust.
Cleanup, verification, and records
The cleanup has a required order: collect all chips and debris and seal them, roll up the plastic dirty-side-in and dispose of it as lead waste, HEPA vacuum every surface from ceiling to floor, damp-wipe hard surfaces and mop floors with clean water, HEPA vacuum again, and clean two feet beyond the contained area.
Then the certified renovator does cleaning verification: a visual check for any dust or debris, then a wipe of floors, countertops, and windowsills with a disposable cloth compared against the EPA cleaning verification card. If the cloth is darker than the card, you reclean and repeat. Only after it passes can the signs come down and the area reopen.
Keep your records, the signed pamphlet acknowledgment, test results or the presumed-lead decision, training and certification records, and the cleaning verification, for three years after the job. Failing to keep records is on its own an enforceable violation.
What it costs to get it wrong
The RRP penalty is a TSCA civil penalty of $49,772 per violation, per day in 2026, and it is charged per violation. Criminal "knowing" violations add up to $50,000 a day plus a year in prison, and "knowing endangerment" can reach $1 million and 15 years for an organization. Home Depot paid a $20.75 million RRP settlement, and EPA has fined groups of small contractors in single enforcement sweeps. This is not a rule that only gets enforced against big companies.
Here is how the per-violation math bites. A window company replaces 10 windows in a 1965 house with no firm certification and no certified renovator on site. Each window is a separate violation. At $49,772 per violation, that one-day job carries potential liability over $497,000, on top of the health risk to the family living there.
Common questions
What year makes a house "pre-1978" for lead paint rules?
The RRP rule applies to housing built before 1978, because lead paint was banned for residential use that year. If the building went up in 1978 or later it is outside the rule. For anything older, assume lead paint is present and that the rule applies, unless the surfaces have been tested and confirmed lead-free by an EPA-recognized test kit or a certified inspector.
How much painted surface can I disturb before RRP kicks in?
More than 6 square feet of interior painted surface per room, or more than 20 square feet outside, triggers full RRP compliance, and any window replacement triggers it regardless of size. These federal de-minimis thresholds are current for 2026 under 40 CFR 745.83. Prohibited practices like torching or high-speed dry sanding also trigger the full rule at any size. Genuine minor touch-ups below the thresholds are exempt. Verify at epa.gov.
What does it cost to get RRP certified?
The EPA firm certification fee is typically $300 and lasts five years, and the certified renovator's 8-hour training course is a separate cost, usually a few hundred dollars per person, also good for five years. In the roughly 20 states that run their own authorized RRP program you apply to and pay the state instead of the EPA, so check Working in Your State before you send money to the EPA.
What is the fine for doing RRP work without certification?
The federal TSCA civil penalty is $49,772 per violation, per day, in 2026, and it is charged per violation, so a single job can stack into six figures. Criminal knowing violations add up to $50,000 a day plus jail. Because each unit of work, like each window, can count as a separate violation, a one-day job can carry hundreds of thousands in exposure. Verify current penalty figures at epa.gov.
Do I still need RRP if the homeowner says the paint is fine?
Yes. A homeowner's opinion is not a lead test, and the rule presumes lead is present in pre-1978 housing unless you have a valid negative test from an EPA-recognized kit or certified inspector. You cannot judge lead paint by eye or by the owner's say-so. Either test it and keep the result, or assume lead is present and follow the full lead-safe practices.
The honest bit
- The RRP thresholds (6 and 20 square feet, window replacement always), the firm and renovator certification structure, and the $49,772-per-violation-per-day penalty are federal EPA facts current for 2026 under 40 CFR Part 745 and TSCA. The 2025 penalty level remains in force for 2026 because no inflation adjustment was issued. Verify current figures at epa.gov/lead.
- About 20 states run their own EPA-authorized RRP program with state-run certification. In those states you apply to the state, not the EPA, and the state's rules govern. Which state, and whether it has its own program, is in Working in Your State.
- This is general guidance, not legal or environmental-compliance advice. Lead poisons children at very low levels and rides home on your clothes, so the practices are worth doing right every time. For a specific job, confirm your certification status and your state's program before you break the paint.
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