Last reviewed October 31, 2026.
The siding rep finishes measuring, sits down at your dining table, and before a single price comes up slides a thin EPA booklet across with a form to sign. On a house built before 1978, that form kicks off a federal rule that shapes the whole job, from who is allowed on the ladder to what gets swept off the lawn at the end of each day.
Which houses and jobs the rule reaches
It is the EPA’s Renovation, Repair and Painting rule, and it lives in Subpart E of 40 CFR Part 745. Section 745.82 aims it at all renovations done for compensation in target housing and child-occupied facilities.
Section 745.103 defines target housing as housing built before 1978. Housing for the elderly or people with disabilities and 0-bedroom units are left out, unless a child under 6 lives there or is expected to.
Section 745.83 casts a wide net for renovation. Removing or repairing painted surfaces counts. So does removing building components such as windows, and surface prep like sanding and scraping. Pulling old windows, stripping painted clapboard and scraping trim before a paint job all qualify.
New York is not on EPA’s list of states authorized to run their own version of the program, as of the agency’s program page updated June 17, 2026. On Long Island, the EPA runs it directly.
Nassau adds a step of its own. Rule 18 of the county Consumer Affairs home improvement regulations requires at least one owner or principal of a firm doing siding, window, roofing or painting work to hand in an EPA lead RRP course certificate with the license file. Our Nassau license guide walks through the rest of that application.
The booklet you sign before work starts
The booklet is Renovate Right. Section 745.83 gives its full name: Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools. EPA’s page for it dates it to September 2011.
Section 745.84 sets the timing. The firm must hand it to the owner no more than 60 days before work begins, then get either your written acknowledgment or a certificate of mailing obtained at least 7 days before the job. If you rent the house out, an adult living in the unit must get a copy as well.
Your signature confirms only that the pamphlet reached you.
When a small exterior patch is exempt
Section 745.83 carves out minor repair and maintenance. Outside, that means disturbing 20 square feet or less of painted surface, with none of the banned methods listed below. Inside, the cap is 6 square feet per room.
Take painted pieces off and the whole removed area counts as disturbed. Jobs in the same room within 30 days are treated as one job.
Window replacement and demolition of painted surfaces never qualify, at any size. Replacing even one window on a covered house falls under the rule. Swapping a few damaged clapboards on a siding repair call may not.
There is a second way out. Under section 745.82, the rule does not apply if a certified inspector or risk assessor has determined in writing that the affected parts are lead-free. The same goes if a certified renovator tested them with an EPA-recognized kit, or sent paint chips to an EPA-recognized lab, and found no lead at the regulated levels. Ask to see that result in writing.
Containment and banned tools on the outside of the house
Section 745.85 sets the work practices. Signs marking the work area go up before anything else.
For exterior work, the firm must close doors and windows within 20 feet of the work and cover the ground with plastic or similar material reaching 10 feet past the surfaces being worked on. Within 10 feet of the property line, it must put up vertical containment or take equivalent precautions, which matters on tight lots.
On painted surfaces, three practices are restricted:
- Open-flame burning or torching is prohibited.
- High-speed sanders, grinders and similar machines are allowed only with a shroud or containment system and a HEPA vacuum attachment.
- Heat guns may run only below 1,100 degrees Fahrenheit.
Waste has to stay contained at the end of each workday. Old siding left loose on the driveway overnight is a sign the crew is not following the rule.
Cleanup checks and the records you receive
When the work wraps, section 745.85 has the crew collect chips and debris into heavy-duty bags, mist the plastic and fold it dirty side in. For exterior jobs, a certified renovator then inspects surfaces in and below the work area, windowsills and the ground included, and repeats the cleaning until nothing is left. Only then do the signs come down.
Section 745.90 puts the certified renovator on site while signs go up, containment is set and cleanup happens, and within phone reach the rest of the time.
Under section 745.86, the firm keeps its records for 3 years. It also owes the owner information on how it complied, at the final invoice or within 30 days of finishing, whichever comes first.
Sudden damage gets some leeway. Section 745.82 treats unplanned work done in response to a sudden, unexpected event that creates a safety hazard or threatens significant property damage as an emergency renovation. The pamphlet step drops away, and signs, containment and waste handling relax only as far as the emergency requires. Cleaning, cleaning verification and recordkeeping still apply.
Looking up a firm’s EPA certification
Section 745.83 defines a firm to include sole proprietors, so the one-person outfit needs certification too. EPA’s consumer page points homeowners to its lead-safe certified firm locator. Look the company up there before you sign.
For questions the locator does not answer, EPA runs the National Lead Information Center at 1-800-424-LEAD, staffed Monday to Friday from 8 a.m. to 6 p.m. Eastern, except federal holidays. Section 745.89 says EPA certifies firms for no more than 5 years before recertification, so check the date, not just the name.
Lead is not the only old-house material worth checking before a tear-off. Our asbestos shingles guide covers New York’s separate rules for asbestos siding, and the window replacement page and siding page cover the rest of the job.
If you do the work yourself
EPA’s program page says the rule generally does not apply to homeowners doing projects in their own pre-1978 homes. That changes if you rent out all or part of the home, run a child care center in it, or buy and renovate homes to sell for profit. EPA still recommends lead-safe practices for do-it-yourselfers.
