In an Older Home, Ask About Lead Before Anyone Sands

The age of the building is the first clue

Many renovation plans start with colors, finishes and a schedule. In an older home, one question should come before any of that: could the paint being disturbed contain lead?

The U.S. Environmental Protection Agency's Renovation, Repair and Painting Rule, often called the RRP Rule, focuses on housing and child-occupied facilities built before 1978. Sanding, cutting, scraping or demolishing painted surfaces in those buildings can create lead dust, even when the lead paint was applied decades ago and is now buried under newer coats.

Who the rule covers

According to EPA, in general anyone who is paid to perform work that disturbs paint in housing and child-occupied facilities built before 1978 must be certified, including sole proprietorships. EPA lists general contractors and trade contractors such as painters, plumbers, carpenters and electricians among the firms covered, along with rental property owners and managers.

The covered work is broad. EPA names remodeling, repair and maintenance, electrical work, plumbing, painting preparation, carpentry and window replacement as examples of activities that can disturb paint.

Small jobs and testing

The rule has limits. EPA's definition of minor repair and maintenance covers work that disturbs 6 square feet or less of painted surface per room inside, or 20 square feet or less outside. Window replacement and demolition of painted surfaces do not qualify for that exception, no matter the size, and jobs in the same room within 30 days count as one job.

Testing is not required by the rule, but EPA explains that unless there is documentation that the paint is not lead-based, the rule's requirements apply. When an owner chooses testing, it must be done by the appropriate certified professional on all surfaces the work will affect.

What changes on the job

When the rule applies, the work looks different from an ordinary paint or drywall job. The firm must give the owner, and adult occupants when the owner does not live there, EPA's Renovate Right pamphlet no more than 60 days before work begins. The work area must be marked with warning signs and contained so dust and debris stay inside it.

For interior work, the federal work practice standards call for steps such as removing or covering furniture, closing and covering ducts in the work area, and covering the floor with taped-down plastic sheeting at least 6 feet beyond the surfaces being renovated. These steps take time and materials, so they belong in the plan and the schedule from the start.

Commercial buildings are not automatically outside it

The housing part of the rule is about homes and apartments. But EPA's definition of a child-occupied facility, such as a day care center or preschool, includes spaces located inside public or commercial buildings. For hotel and restaurant owners, the takeaway is to mention any child care or similar use in or next to the work area so its status can be checked before work starts.

Questions to settle before demolition or prep

• When was the building, or the part being renovated, built?
• Is there documentation that the painted surfaces to be disturbed are not lead-based, or should testing by a certified professional come first?
• Will the work go beyond the minor repair limits, or include window replacement or demolition of painted surfaces?
• Who will live in or use the space during the work, and how will they be kept out of the work area?

Conclusion

Lead is not a reason to avoid improving an older home. It is a reason to ask the right question early, before sanding, cutting or demolition begins. Knowing the building's age, checking whether the paint has been tested and confirming that the work will follow the federal rules where they apply all help a renovation in Florida stay safe for the people who live with it.