Pre-1978 homes in the United States were painted during a period when lead was used as a standard paint ingredient. The older the home, the higher the likely lead content in the existing paint layers. Lead concentrations in paint manufactured before 1940 could reach 50 percent by weight. By comparison, lead was already being phased out by the early 1970s, so homes built closer to 1978 may have little or no lead depending on the manufacturer and the specific paint used. Any home built before 1978 should be assumed to have lead paint until testing confirms otherwise.
Lead in intact, well-adhered paint does not present an acute health hazard. The risk emerges when lead paint is disturbed: scraped, sanded, heat-stripped, or pressure-washed in a way that creates dust or paint chips containing lead particles. Lead dust at particle sizes below 10 microns is respirable, meaning it reaches deep into the lungs. At any particle size, lead paint chips create ingestion hazards, particularly for children and for pets. Managing a repaint on an older exterior requires understanding exactly when and how lead becomes dangerous, and following specific legal and practical requirements to control that risk.
How to Test for Lead Paint on Older Exterior Surfaces
Testing is not optional before beginning any work that will disturb exterior paint on a pre-1978 home. Testing is the step that determines whether a straightforward paint job requires additional precautions and legal compliance.
Two EPA-recognized lead paint test kits are available to homeowners and contractors: 3M LeadCheck Swabs and D-Lead test kit. Both are recognized by the EPA as accurate for testing painted surfaces on wood, metal, plaster, and drywall. LeadCheck produces results in approximately 30 seconds. The swab tip is crushed to release the test chemical, and a pink or red color response indicates lead presence. Each swab tests one component. A component is defined as a discrete area of painted surface with the same paint and paint history, such as one window sill, one door face, or one section of fascia. You need one swab per component, not one per square foot.
For definitive quantitative results rather than a positive-or-negative field test, lab analysis of paint chips provides lead content by percentage by weight. Paint chip samples from each suspected component can be sent to a certified environmental laboratory. Lab analysis is the gold standard when a positive swab result is ambiguous or when documentation is needed for a real estate transaction or remediation record.
Professional lead inspectors and risk assessors can perform comprehensive testing using X-ray fluorescence (XRF) analyzers. XRF instruments read lead content non-destructively through multiple paint layers, including paint buried under subsequent repainting, providing results immediately. Hiring a certified lead inspector produces a written report with tested component locations, lead levels, and remediation recommendations. This report is the most defensible documentation available if questions arise later.
EPA RRP Rule and Legal Requirements for Lead Paint Disturbance
The EPA’s Renovation, Repair, and Painting Rule, commonly called the RRP Rule, governs work that disturbs lead-based paint in homes and childcare facilities built before 1978. Any exterior renovation disturbing more than 20 square feet of painted surface on a pre-1978 home triggers RRP compliance requirements when the work is performed by a contractor.
A contractor performing this work must be employed by an EPA-certified Renovation Firm and must use at least one EPA-certified Renovator on the job. Firm certification requires an EPA application fee of approximately 300 dollars and at least one employee who has completed an eight-hour EPA-accredited Renovator training course. Certified Renovators may train other workers on the job through on-the-job training. Documentation of compliance, including test results, worker training records, and containment and cleanup records, must be retained for five years. Violations carry civil penalties of up to $44,792 per day per violation.
Homeowners working on their own owner-occupied residence are exempt from RRP Rule requirements, provided the home is not rented to tenants and does not serve as a childcare facility. The exemption applies to the homeowner personally performing the work, not to contractors they hire. Contractors must comply regardless of the homeowner’s wishes.
In states where the EPA has authorized state-administered RRP programs, state rules apply and may be more stringent than federal requirements. Check your state environmental agency’s requirements before assuming federal RRP Rule parameters apply exclusively.
Safe Containment and Removal Practices for Exterior Lead Paint
The work practices required for lead-safe exterior renovation differ substantially from standard repainting practice. The goal is to contain paint chips and dust at the work area, prevent them from spreading to the surrounding property, and ensure cleanup is complete before anyone with lead exposure risk contacts the area.
The containment setup begins before any scraping or removal starts. Cover the ground surface below the work area with heavy plastic sheeting extending at least 10 feet from the base of the wall. Secure the sheeting with weights or stakes. For active work areas, tape overlapping sheets together and create a containment perimeter. Any vegetation in the immediate work zone should be covered with breathable fabric rather than plastic, since plastic overheats plants within an hour in direct sun.
Wet scraping is required for lead paint removal under RRP work practices. Wet methods reduce the generation of lead dust by keeping paint chips moist during removal. Mist the painted surface with water immediately before scraping, and apply additional moisture as work progresses. Wet scrapings are heavier and fall more predictably onto the containment sheeting below rather than becoming airborne.
The ProScraper lead-safe scraping system combines a tungsten carbide blade with a hollow body that connects directly to a standard shop vacuum. Used with a HEPA-filter vacuum such as a Festool or Milwaukee HEPA shop vac, the ProScraper is an EPA-approved dry-scraping method that captures dust and chips at the point of generation before they disperse. The HEPA filter captures particles down to 0.3 microns at 99.97 percent efficiency, which is the standard required for lead dust containment. This system dramatically reduces lead exposure compared to open scraping methods.
Workers must wear N-100 respirators, not standard dust masks, when removing lead paint. Nitrile gloves and disposable protective coveralls prevent skin and clothing contamination. Remove and dispose of coveralls at the work site before entering any clean area or vehicle.
Encapsulation as an Alternative to Full Lead Paint Removal
Encapsulation is an EPA-accepted alternative to removing lead paint on surfaces where the existing paint is intact and well-adhered. Encapsulation applies a specially formulated coating over the existing lead paint, creating a barrier that physically seals the lead-containing layers from the environment. The lead paint remains in place, but the encapsulant prevents it from creating dust or chips under normal conditions.
Zinsser Perma-White and specific lead encapsulant products formulated for this application are film-forming barriers applied over intact lead paint. The encapsulant is a thicker-than-standard coating that creates a durable, adhered layer over the existing paint. Encapsulation is only appropriate when the existing lead paint is in good condition: firmly adhered, not peeling, not flaking, not chalking significantly. If the existing paint is in poor condition, the encapsulant has nothing stable to bond to, and it will fail along with the failing paint beneath it.
Encapsulation must be performed by a certified renovator under RRP requirements and documented with the specific encapsulant product used, application thickness, and the surfaces treated. The documentation is important because encapsulated lead paint must be disclosed to future homeowners and managed as lead paint in any future renovation.
Encapsulated surfaces must be monitored periodically for failure of the encapsulant layer. If the encapsulant begins to peel or crack, the underlying lead paint is again exposed and the surface must be retreated or the lead paint fully removed.
Disposal Requirements for Lead Paint Waste
Lead paint debris from residential exterior projects must be disposed of appropriately. Requirements vary by jurisdiction, but certain baseline standards apply broadly.
Paint chips and dust collected from lead paint removal are classified as hazardous waste in many jurisdictions if they fail the Toxicity Characteristic Leaching Procedure (TCLP) test for lead. For practical purposes, debris from heavy lead paint removal should be treated as hazardous waste unless testing confirms it does not qualify.
Place all collected debris, contaminated plastic sheeting, disposable coveralls, and materials from the work area in sealed plastic bags rated for hazardous waste. Wet debris with water before bagging to prevent dust during the bagging process. Double-bag and seal. Label the bags appropriately. Do not place lead paint debris in standard curbside recycling or composting.
Check with your local solid waste authority for lead paint debris disposal options. Many municipalities have household hazardous waste drop-off days or permanent facilities that accept lead paint debris from residential projects. Some jurisdictions allow residential quantities of lead debris in sealed bags to go to the municipal landfill. Contact local authorities before disposing.
Wash water used in wet scraping or cleanup of lead paint areas must not be discharged to storm drains. Collect wash water and dispose of it through appropriate hazardous waste channels or discharge to a sanitary sewer if permitted by the local authority.
When You Must Hire a Certified Lead Paint Contractor
Certain situations require a certified lead paint contractor regardless of the homeowner exemption or personal preference to handle the work yourself.
Any rental property with pre-1978 lead paint that requires exterior work disturbing more than 20 square feet triggers mandatory RRP compliance. Landlords cannot perform exempt homeowner work on rental properties. Hiring a certified RRP firm is required.
Homes with children under six years old or pregnant women as occupants warrant hiring a certified contractor even when the homeowner exemption technically applies. The health consequences of lead exposure are most severe for young children and developing fetuses, and professional certified contractors have training, equipment, and protocols that meaningfully reduce exposure risk compared to a self-managed project.
Homes with extensive or severely deteriorated lead paint, such as pre-1940 construction where paint may have been applied in many layers with very high lead concentrations, are best handled by certified professionals. The volume of lead-contaminated material and the complexity of safe containment on large-scale removal projects exceed what most homeowners can safely manage without professional equipment and training.
If any exterior surface will be heat-stripped, power-sanded, or chemically stripped as part of the repainting prep, these methods generate lead dust in volumes that require professional-level containment. Certified contractors with appropriate equipment and trained crews are the right choice for any work method that produces high-volume lead dust.