You have a bid in hand for the 1962 ranch or the 1940s bungalow, the number looks reasonable, and you are ready to sign. Before you do: a federal rule governs that job whether or not anyone brings it up. The EPA’s Renovation, Repair and Painting rule — the RRP rule, at 40 CFR Part 745, Subpart E — tells your contractor what to do, and gives you a short list of things you are entitled to see.
What the rule is and who it binds
The RRP rule applies to renovations performed for compensation in target housing and child-occupied facilities. “Target housing” means housing built before 1978, with narrow exceptions for housing for the elderly or people with disabilities and for zero-bedroom dwellings, unless a child under six lives there or is expected to.
The word carrying the weight is “compensation.” The rule binds anyone paid to disturb painted surfaces — contractors, painters, plumbers, electricians, HVAC technicians, window installers, handymen, and landlords working in their own rentals. A one-person operation is a firm here. There is no small-outfit exemption.
“Renovation” means any modification of an existing structure that disturbs painted surfaces, which is broader than most homeowners expect: cutting an access hole for a duct run, pulling a tub surround, replacing a window, taking down a wall.
And it is not only houses. Child-occupied facilities are covered — a pre-1978 building visited regularly by the same child under six on at least two days in a week, at least three hours per visit, six hours per week, and 60 hours per year. Home daycares, church nurseries, and preschools in older buildings fall inside the rule.
Two certifications to ask for before you sign
Firm certification
The company must hold an EPA Lead-Safe Certified Firm certification, valid for no more than five years from approval. Texas has not taken over this program, so EPA administers RRP directly across the metroplex. Verify it yourself: EPA publishes a searchable database of certified firms, and the National Lead Information Center at 1-800-424-LEAD will check for you.
Certified renovator
Separately, an individual certified renovator must be assigned to your job — certified for five years when refresher training includes hands-on work, three years when it does not. They must be present when warning signs go up, when containment is established, and when the work area is cleaned, reachable on site or by phone while work is underway, and carrying their course certificates at the site.
So the question is not “are you certified.” It is: who is the certified renovator on my job, and may I see the card.
The pamphlet, and the signature they need from you
The firm must give you EPA’s pamphlet, the Lead-Safe Certified Guide to Renovate Right, no more than 60 days before the renovation starts. Then they must obtain your written acknowledgment of receipt, or a certificate of mailing dated at least seven days before work begins. In a rental it is owed to the owner and an adult occupant; in a child-occupied facility, to the owner and a facility representative, with parents and guardians notified separately.
That signature is the clearest tell you get. A contractor who never mentions the pamphlet is either unaware of the rule or skipping it.
What lead-safe work actually looks like
- Containment. Inside: furnishings removed or covered, ducts closed, windows and doors closed, doors covered with plastic, and taped-down plastic sheeting extending at least six feet beyond the work area. Outside: all doors and windows within 20 feet closed, and ground covering extending at least 10 feet beyond the perimeter.
- Prohibited practices. Open-flame burning or torching of painted surfaces is prohibited outright. High-speed paint removal — sanding, grinding, power planing, needle gun, abrasive blasting — is prohibited unless the machine has a shroud or containment system with a HEPA vacuum attachment collecting dust at the point of generation. A heat gun may only run below 1,100 degrees Fahrenheit. A torch or an uncontained grinder on a pre-1978 exterior means the job has already gone wrong.
- Cleaning verification. Afterward the certified renovator wipes windowsills, uncarpeted floors, and countertops with a wet disposable cloth and compares it to EPA’s cleaning verification card. Surfaces over 40 square feet are split into sections under 40 square feet, each wiped with a fresh cloth. A cloth darker than the card means reclean and rewipe; if it still fails, the crew waits one hour or until the surface is completely dry, whichever is longer, then finishes with a dry-cloth wipe.
The firm must keep these records for three years and give you documentation of compliance within 30 days of finishing. Ask for it.
“It’s a small job” — the minor repair threshold
This is the exemption most often stretched. Minor repair and maintenance activities, including small HVAC, electrical, and plumbing work, fall outside the rule when they disturb six square feet or less of painted surface per room inside, or 20 square feet or less outside.
Three limits matter. Window replacement is never minor repair, regardless of size. Demolition of painted surfaces is never minor repair. And jobs done in the same room within the same 30 days count as one job — five square feet on Monday and five more there two weeks later is a ten-square-foot job. Using a prohibited practice also disqualifies work from the exemption no matter how small the area.
So sometimes it genuinely is a small job, and often the phrase is doing work it should not. If your project involves demolition of painted components, you are past the threshold before the first swing.
Doing the work yourself
The rule does not reach a homeowner working on their own home, because there is no compensation. That exemption is real, and narrower than it sounds. It ends the moment the property is a rental, the moment you run a childcare business there, or the moment you renovate to flip for profit, and it never covers anyone you pay to help you.
It is a legal exemption, not a physical one: sanding old paint in your own hallway makes the same dust. And one option is gone for everyone. Homeowners could once sign an opt-out waiving lead-safe practices when no young child or pregnant woman lived in the home; EPA revoked that provision effective July 6, 2010.
If a contractor ignored the rule
You have real recourse. EPA enforces RRP under the Toxic Substances Control Act, and the maximum civil penalty is $49,772 per violation, per day for penalties assessed on or after January 8, 2025. Reports go to EPA — the National Lead Information Center at 1-800-424-LEAD takes them, and EPA Region 6 in Dallas covers Texas.
Practically: photograph what you saw with dates, stop the work rather than let dust spread, and get the house assessed. What matters to you is not only whether the contractor was wrong but whether your home now holds a hazard. Lead testing, with samples analyzed by accredited laboratories, tells you where you stand.
Why this matters most in some houses
Lead exposure harms young children’s developing brains, and no level of lead in a child’s blood is considered safe. That is why the rule exists, and why the stakes rise with children under six or a pregnant occupant in the home. It is not a reason to fear an older house — intact, undisturbed paint is generally not the problem. Careless renovation dust is.
If your bid covers work that will disturb a meaningful amount of old paint, the honest options are a properly certified renovation or professional lead paint removal beforehand. Homes of this era often carry more than one legacy material, so pair that with asbestos testing for popcorn ceilings, floor tile, and pipe insulation. Our home environmental risk checker shows which questions apply to your build year.
Hiring well in Dallas-Fort Worth
Superior Environmental Services is a licensed and insured environmental remediation company based in Plano, serving Dallas, Tarrant, Collin, and Denton counties with certified technicians. We answer 24/7/365 and can have someone on site within 24 hours. Costs for lead paint abatement vary widely with the size of the area, the substrate, and whether components are stripped or replaced — small single-room scopes sit at the low end of a wide range, while whole-house exteriors run considerably higher. You will have the full scope and cost in writing before anything begins.
Call (469) 283-5227 and bring the contractor’s bid. Often the most useful thing we do in that first conversation is tell you which questions to take back to them.
