Lead Paint and Window Replacement: The EPA RRP Rule

If your home was built before 1978, replacing its windows falls under the Environmental Protection Agency's Renovation, Repair and Painting (RRP) rule. EPA says the rule covers "anyone paid to perform work that disturbs painted surfaces in homes, childcare facilities and preschools built before 1978," and adds that "This includes all firms, even sole proprietorships" (EPA RRP program) ¹. Under the rule, firms doing that work must be EPA- or state-approved, use trained renovators and follow specific work practices to prevent lead contamination (EPA RRP rules) ^{1 6}.

Window replacement gets no small-job exception. The rule exempts minor work that disturbs six square feet or less of paint per room inside, or 20 square feet or less outside, but EPA states: "Window replacement and demolition of painted surfaces are always covered regardless of square footage" (EPA RRP for contractors) ². In practice, that means a window job in a pre-1978 house starts with a pamphlet, runs inside a contained work area and ends with a specific cleanup.

Why old windows are a lead concern

EPA estimates that about three-quarters of the homes in the United States built before 1978 still contain some lead-based paint ¹. Windows are a common place to find it: sashes, stops, sills and exterior trim were painted and repainted for decades, and taking a window out means prying, cutting and scraping those parts. EPA's page for homeowners names "replacing windows" among the activities that can create lead dust and chips, and warns that even a small amount of lead dust from a home project can be enough to poison a child (EPA RRP for consumers) ⁵.

That is why the rule focuses on dust: how it is kept in the work area, which methods are off the table because they make too much of it, and how the area is checked before the plastic comes down.

The Renovate Right pamphlet

Before work starts, the firm has to give you EPA's lead hazard pamphlet, titled _Renovate Right_. EPA's work practices page says firms must distribute it "before starting renovation work" and document that they did (EPA RRP work practices) ³. The pamphlet itself spells out the same duty for homeowners and tenants, and says that when it is mailed instead of handed over, it must be mailed at least seven days before the renovation, with a certificate of mailing from the post office (Renovate Right) ⁴. The pamphlet includes a receipt for the owner to sign, confirming that it arrived before the work began ⁴.

The pamphlet is worth reading rather than just signing for. It explains how to prepare the house, what the crew should be doing, and how to check the result ⁴.

Lead-safe work practices, step by step

The rule sits in federal regulations at 40 CFR 745, Subpart E, and has been fully effective since April 22, 2010 (EPA RRP rules) ⁶. _Renovate Right_ describes the practices a contractor must follow in three steps ⁴:

1. Contain the work area. Warning signs go up, and plastic or other impermeable material and tape are used as needed to cover floors and furniture that cannot be moved and to seal doors and heating and cooling vents. For exterior work, the ground is covered and, in some cases, vertical containment is put up ⁴.
2. Avoid the dustiest methods. The pamphlet lists three methods whose use is prohibited: open-flame burning or torching; sanding, grinding, planing, needle gunning or blasting with power tools that lack a shroud and HEPA vacuum attachment; and heat guns above 1100°F (Renovate Right) ⁴. It mentions misting before scraping, scoring paint before separating parts, and prying parts apart instead of breaking them as ways to make less dust ⁴.
3. Clean up thoroughly. The area is cleaned daily and, when the job is done, cleaned with a HEPA vacuum followed by wet wiping and wet mopping before the plastic is taken down ⁴.

After cleaning, the rule requires a cleaning verification: the contractor wipes the floor and other surfaces with disposable cloths and compares them with an EPA cleaning verification card (Renovate Right) ⁴. If you want a lead-dust test on top of that, the pamphlet suggests writing into the contract, before the job starts, that a test will be done, who will do it, and whether re-cleaning follows from the result ⁴.

Do you have to test for lead first?

EPA says paint testing is not required by the RRP rule (EPA RRP for contractors) ². _Renovate Right_ gives you options: assume the paint contains lead and have the crew follow lead-safe practices throughout, hire an inspector or risk assessor to find where lead is, or have a trained renovator test the parts being disturbed with an EPA-recognized test kit or paint chip samples sent to an EPA-recognized laboratory ⁴. The pamphlet adds that, especially in older homes, you may simply want to assume lead-based paint is present and follow lead-safe practices ⁴.

Living in the house during the work

Contained rooms are off limits until the work there is finished, cleaned and the plastic removed ⁴. The pamphlet suggests planning for that: other bedroom, bathroom and kitchen arrangements if work is in those rooms, a safe place for pets, a separate path for the crew to carry materials in and out, somewhere to store furniture, and possibly turning off forced-air heating and cooling while work is under way ⁴. For the general steps of getting a house ready for installers, see how to prepare for window installation.

Checking a company before you hire

EPA keeps a lead-safe firm search that lists firms registered under the RRP program; ask whether the firm quoting your windows is listed, and look it up yourself ¹. Some states run their own authorized programs instead of EPA ¹. _Renovate Right_ also suggests asking ⁴:

• Whether the crew is trained in lead-safe work practices, and to see the training paperwork.
• Which lead-safe methods it will use to set up, do and clean up the job in your house.
• For references from at least three recent jobs in homes built before 1978.

It also suggests making the contract clear about how the work will be set up, performed and cleaned ⁴. Put that next to the general checks in how to choose a window installer, and if your house is in a historic district, the review steps in historic home window replacement.

If you do the work yourself

EPA says the RRP rule generally does not apply to homeowners working on their own pre-1978 homes, with exceptions: it does apply if you rent out all or part of the home, run a child care center in it, or buy, renovate and sell homes for profit (EPA RRP program) ¹. EPA points do-it-yourselfers to its lead-safe practices for DIY projects ¹. Renters should know the landlord or property manager has to comply when work disturbs paint ¹.

Lead-safe work adds setup and cleanup time, so it may show up in the price. When you compare window quotes, check that each one includes containment and cleaning, and see the window replacement cost guide for overall ranges. When you are ready, you can compare quotes from window installers.

About these figures

• ¹ Official record: EPA RRP program page on who the rule covers, the three-quarters lead-based paint estimate for pre-1978 homes, the homeowner exemption and its exceptions, renters, authorized state programs and the firm search, checked October 27, 2026.
• ² Official record: EPA RRP contractor page on the six and 20 square foot minor repair limits, window replacement always being covered, and paint testing not being required, checked October 27, 2026.
• ³ Official record: EPA RRP work practices page on distributing the pamphlet before work starts and documenting it, checked October 27, 2026.
• ⁴ Official record: EPA's Renovate Right pamphlet on the seven-day mailing rule, containment, the three prohibited methods including heat guns above 1100°F, cleanup, cleaning verification, testing options, preparation and questions for contractors, checked October 27, 2026.
• ⁵ Official record: EPA consumer page naming window replacement among activities that create lead dust, checked October 27, 2026.
• ⁶ Official record: EPA RRP rules page citing 40 CFR 745, Subpart E, fully effective April 22, 2010, and the firm approval and work practice requirements, checked October 27, 2026.