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Pre-1978 lead renovation scope before work checklist

A pre-work checklist for determining whether renovation in pre-1978 housing or a child-occupied facility may disturb painted surfaces, verifying the responsible firms and certified renovator, identifying state-authorized program differences, documenting testing or applicable determinations, defining occupant protection and exclusions, and preventing demolition, sanding, cutting or paint disturbance before the lead-safe scope is settled.

6 items to check

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Building age, occupancy and exact painted components to be disturbed are documented

Critical item

The applicability review should use actual construction and work scope rather than assumptions from appearance.

The controlling EPA or authorized state lead program and any HUD or local requirements are identified

Critical item

Jurisdiction-specific requirements should be resolved before bids and scheduling.

Every paid firm that will disturb paint has appropriate firm certification and a responsible certified renovator

Critical item

Covered firms and individuals should hold current credentials applicable to the work and jurisdiction.

Any lead-free determination or testing basis is made by an authorized person using an accepted method

Critical item

Visual appearance, paint age guesses and homeowner test claims should not substitute for an applicable documented determination.

Pre-renovation education, occupant communication and protection for children, pregnant occupants, pets and belongings are planned

Critical item

Required information and a workable occupancy plan should precede disturbance.

The written scope names lead-safe practices, containment, cleaning, verification, waste handling, records and change control

Critical item

Lead controls should be enforceable project requirements rather than an informal promise.

Use before contracting or starting paint-disturbing work in older housing. EPA RRP requirements generally apply to paid renovation in covered pre-1978 housing and child-occupied facilities, while authorized state programs or additional HUD and local rules may differ. Stop work when suspect hazardous material, uncontrolled dust, sewage, extensive mold, unsafe structure, damaged containment, exposed energized work or an unplanned release is found. Homeowners should not collect asbestos samples, disturb suspect materials, enter regulated containments or perform specialist clearance testing unless properly qualified and permitted.

Reference standards

  • Current EPA lead, asbestos, mold and radon guidance; applicable federal, state, tribal and local environmental, occupational, licensing, disposal, permit and notification requirements; the signed remediation scope; laboratory and field reports; building and mechanical requirements; and exact containment, filtration, cleaning, disposal, mitigation-system and product instructions
  • EPA Renovation, Repair and Painting Rule, Renovate Right materials and March 2026 lead-safe renovation guidance

    • Tools

  • Building-age and renovation records, environmental reports, laboratory results, contractor credentials, scope, permits, notifications, waste records, photographs and occupant-protection plan
  • Camera, flashlight, tape measure and owner-safe observation tools; specialist sampling, pressure monitoring, moisture instruments, clearance testing and radon devices where required
  • Qualified lead, asbestos, mold, industrial-hygiene, radon, mechanical, electrical, laboratory and medical professionals as appropriate

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