Lead-Safe Work Orders for Paint Repairs in Pre-1978 Homes

A painter receives a work order that says:

Patch peeling paint around two bedroom windows and repaint white.

The home was built in 1948.

That one sentence does not tell the crew:

• whether the federal EPA Renovation, Repair and Painting Rule or an authorized state, tribal, or territorial program governs;
• whether the firm and assigned renovator hold the right credentials for that jurisdiction;
• which sash, casing, stool, apron, wall, and trim surfaces will be disturbed;
• whether the work includes window replacement, demolition, sanding, scraping, cutting, drilling, or heat;
• whether there is acceptable component-specific lead-free documentation;
• who received the required lead pamphlet and how delivery was documented;
• whether the room is occupied, where children and pets will be, or how emergency egress will remain available;
• how containment, dust collection, tools, waste, and daily cleanup will be handled;
• what the employer's OSHA exposure assessment and any required written compliance or respiratory-protection program require;
• who performs the applicable visual inspection, cleaning verification, or clearance and who may release the area; or
• what records go to the owner and what stays in the firm file.

“Lead-safe” cannot be a checkbox added after the price is approved. It changes authorization, staffing, work methods, setup time, daily controls, cleanup, handoff, and records.

EPA's current RRP contractor guidance says the rule generally applies to paid work that disturbs painted surfaces in pre-1978 houses, apartments, and child-occupied facilities. Covered firms—including sole proprietorships—must be certified, assign a certified renovator, and use required work practices. In an EPA-administered jurisdiction, the controlling requirements are in 40 C.F.R. Part 745, Subpart E. Authorized jurisdictions may have their own certification, notification, work-practice, fee, record, or enforcement requirements.

Federal coverage also uses defined property categories. EPA says that target housing generally excludes zero-bedroom dwellings and housing reserved for older adults or people with disabilities unless a child under six resides or is expected to reside there. Under 40 C.F.R. § 745.83, a child-occupied facility depends on recurring visits by the same child under six; an occasional visit is not enough. Record the actual housing type and use, then check the administering program rather than deciding from the construction year alone.

This guide turns those requirements into a work-order structure. Follow it in four passes: screen coverage and jurisdiction; document credentials, notices, and authorization; define components, methods, containment, and worker controls; then complete the applicable verification or clearance path and preserve the records. It is not a training course, certification, exposure-control plan, abatement design, or jurisdiction-specific legal opinion. The certified firm, certified renovator, employer, property owner, program administrator, and any HUD or local program each retain their own responsibilities.

Documentorium can organize the customer and field record without pretending to supply certification or a regulated government form. Use the site assessment checklist or rental inspection report to record the property date, use, unit, affected components, observed coating condition, access, and documents supplied. Put the priced disturbance, lead basis, notices, setup, cleanup, finish, exclusions, and allowances in the quote estimate and contract agreement. Once approved, issue the work order with the exact components and assigned qualified roles. The safety-briefing work-order guide shows how customer-approved scope and crew controls remain connected without treating a customer signature as the safety plan.

Screen the job before anyone promises a standard repaint

Use a coverage screen at intake and repeat it when the scope changes.

EPA's Small Entity Compliance Guide to Renovate Right describes renovation broadly as activity that disturbs painted surfaces, including most repair, remodeling, maintenance, and window replacement. It also identifies federal exclusions and exceptions, but those should be treated as decision branches requiring evidence—not as estimating shortcuts.

Write the first decision this way:

RRP screen: Pre-1978 target housing or child-occupied facility? [Yes / No / Unknown]. Performed for compensation? [Yes / No / Review]. Painted surfaces disturbed? [Yes / No / Unknown]. Administering program: [EPA / state / tribe / territory]. Additional housing program: [None identified / HUD / local / unknown]. Work on affected painted components may not begin until this screen and required credentials, notices, methods, and records are approved.

If the year is unknown, do not turn unknown into post-1978 merely because the customer wants a quick price.

Do not misuse the minor-repair threshold

Under the federal RRP program, EPA identifies a minor repair and maintenance exception for work disturbing six square feet or less of painted surface per room on the interior or 20 square feet or less on the exterior. Window replacement, demolition of painted surfaces, and projects involving prohibited practices do not become minor repair simply because the measured area is small.

For the federal calculation, § 745.83 also treats non-emergency jobs performed in the same room within the same 30 days as one job. The work-order register therefore needs room and date history, not only the current ticket number.

The work order should show the calculation:

The running totals use the unrounded dimensions and are rounded only after addition. This example is only arithmetic; it does not decide the exception. The reviewer still asks:

• Is every affected painted surface included?
• Will damage expand during prep?
• Are both faces or any additional painted surfaces of the component affected?
• Is a window being replaced?
• Is painted-surface demolition involved?
• Will any prohibited method be used?
• Have other non-emergency jobs in this room disturbed paint during the same 30 days?
• Does the authorized state or other program use the same threshold and interpretation?
• Is another part of the same renovation being split into a separate ticket?

Do not divide one renovation into multiple work orders to stay under a threshold. Do not estimate about five square feet after the crew has already scraped eight.

Use a stop-and-change rule:

The disturbed-area estimate applies only to the components and methods listed. If paint failure, access, demolition, preparation, or customer-requested work expands the disturbed area or changes the method, stop affected work, maintain the area safely, update the coverage determination, and issue an approved change before continuing.

Separate renovation from abatement and clearance

RRP renovation, lead abatement, lead inspection, risk assessment, dust sampling, and clearance are not interchangeable labels.

The Washington Department of Commerce, for example, expressly separates RRP renovation certification from lead-based paint activities: inspections, risk assessments, clearance, and abatement follow a different certification path. Massachusetts similarly distinguishes ordinary lead-safe renovation from deleading, which is work intended to achieve compliance with the state's lead law.

Do not promise lead removal, lead-free, abatement, clearance, or a compliance letter when the approved scope is only a repair conducted with RRP work practices.

Identify the administering program and credentials

EPA does not administer every RRP program directly. Start with EPA's current program resources, then confirm the job-site jurisdiction with the relevant regulator.

The work order should capture:

• administering agency and program name;
• firm legal name and certification/license number;
• firm certification expiration or validity check;
• assigned certified renovator name and certificate details;
• training provider and applicable refresher path;
• workers trained by the assigned renovator and training record;
• additional contractor or home-improvement license;
• required project notification or permit number;
• program contact used for an unusual interpretation; and
• subcontractor firm and renovator credentials.

EPA's current firm-certification guidance says federal firm certification is valid for five years and that each renovation must have an assigned certified renovator. It also says people disturbing painted surfaces must be certified renovators or trained by one, and the firm must ensure compliance with work-practice and recordkeeping requirements.

State authorization can create meaningful differences.

• The Washington RRP program has its own firm and individual certification/registration paths and explains that an EPA or other-state individual certificate does not by itself complete Washington registration.
• The Massachusetts Deleading and Lead Safety Program administers state lead-safe renovation licensing under 454 CMR 22.00. Its current lead-safe renovation guidance says a licensed lead-safe renovation contractor must have a trained and certified lead-safe renovation supervisor on staff and that the supervisor must be on site at all times while the work is in progress.

Those are examples, not universal rules. The correct lesson is to store jurisdiction-specific credentials in the job record rather than printing EPA certified on every work order regardless of location.

Make the work order component-specific

Repair paint in bedroom does not control disturbance.

Use a component schedule:

For each component, attach:

• wide photo showing location;
• close photo showing paint condition;
• marked disturbance boundary;
• dimensions;
• planned tool and dust-control method;
• nearby openings, ducts, belongings, landscaping, play areas, and adjacent property;
• existing damage that should not be attributed to the work; and
• lead-test or inspection reference if relied upon.

If the scope includes windows, treat them as high-control components. Friction and impact surfaces, removal, opening protection, interior/exterior sides, weights, pockets, trim, glazing, debris paths, and security all need explicit decisions.

Record the lead determination without overclaiming it

Federal 40 C.F.R. § 745.82 does not require a firm to test paint; the firm may assume the affected paint is lead-based and follow RRP. If the firm relies on a negative determination instead, that determination must come through one of the rule's accepted paths.

The work order should use one of these statuses:

Avoid these weak notes:

• Owner says there is no lead.
• House was repainted in 2005.
• Topcoat tested negative.
• Similar window was negative.
• Lead disclosure form says unknown.
• Paint looks modern.

A later coat does not prove every underlying layer is lead-free. A property disclosure document is not necessarily a component-specific RRP determination. One tested wall does not decide another window.

Tie pre-renovation education to authorization

The Renovate Right pamphlet is not an optional brochure left on the counter after setup.

EPA's current small-entity guide describes different federal delivery paths for:

• owner-occupied dwelling units;
• tenant-occupied dwelling units;
• common areas of multifamily housing; and
• child-occupied facilities.

Under 40 C.F.R. § 745.84, pre-renovation information generally may not be delivered more than 60 days before work begins. For an owner-occupied unit, deliver the pamphlet to the owner and obtain written acknowledgment before renovation, or mail it at least seven days before renovation and retain a certificate of mailing. Tenant-occupied units add the adult occupant. Common-area and child-occupied-facility work can require notices or posting for affected occupants, parents, or guardians, plus the pamphlet or access to it. A change in common-area scope, location, or timing can require a supplemental notice.

Use a notice log:

Do not ask the owner to sign a false acknowledgment. Do not backdate pamphlet delivery. If the occupant is unavailable, use only the self-certification procedure the applicable rule allows and record the facts.

The customer contract and the RRP receipt serve different purposes. The FTC's home-improvement guidance recommends a written contract that identifies the contractor, scope, price, dates, and promises. The FTC's Cooling-Off Rule can separately require cancellation disclosures for covered sales made at a home or certain other locations. A signed Renovate Right acknowledgment does not replace a home-improvement contract or cancellation notice, and the contract does not replace pre-renovation education.

Plan occupant protection before plastic goes down

The work order should state who can be where, not simply contain area.

Record:

• occupants, children, pets, and routine visitors;
• mobility, vision, hearing, language, or other access needs communicated for safe routing;
• room vacancy or temporary relocation plan;
• work hours and no-entry periods;
• restroom, kitchen, sleeping, medication, and essential-access impacts;
• alternate path and emergency egress;
• HVAC, returns, supplies, portable units, and fan status;
• doors and windows that must remain closed;
• keys, alarms, security, and daily lock-up;
• common-area traffic and neighbor protection;
• exterior play areas, gardens, vehicles, and property lines;
• warning-sign locations and languages; and
• daily customer contact.

Under 40 C.F.R. § 745.85, federal RRP warning signs must define the work area and tell occupants and others not involved in the renovation to stay out. Signs are posted before work and remain through cleaning verification. The rule also requires containment not to interfere with emergency egress.

Use a release rule:

Keep occupants, pets, non-project personnel, and removed belongings out of the controlled work area until the applicable release steps are complete and the authorized person has released it. Under federal RRP, the certified renovator completes the visual inspection and, for interiors, cleaning verification—or required clearance in its place—before warning signs are removed. Exterior work uses the required visual inspection unless another governing program or contract also requires clearance.

Do not let the customer waive containment or ask the crew to just work around the child for an hour.

Write the interior containment plan in measurable terms

For federal RRP work, § 745.85 requires the firm to isolate the work area so dust and debris do not leave and to maintain containment integrity.

An interior setup record should include:

• work-area boundary and sketch;
• objects removed or impermeably covered and sealed;
• floors covered six feet beyond the renovation perimeter or farther as needed to contain dust, subject to the vertical-containment provision;
• ducts closed and covered with taped impermeable material;
• windows and doors closed;
• door openings covered in a way that allows controlled passage while confining dust;
• vertical containment where used;
• egress and emergency path;
• warning signs;
• tool, worker, and waste exit route;
• HEPA vacuum and equipment inspection;
• decontamination steps for people, tools, and container exteriors; and
• pre-work photos and certified-renovator setup verification.

Example:

Interior containment B1: Bedroom door closed and controlled flap barrier installed; supply register and return opening closed and sealed; bed and curtains removed; remaining dresser wrapped with sealed impermeable covering; floor covered wall-to-wall because the room dimension does not allow six feet beyond each window; warning sign at hallway approach; the required exit route through the hall remains usable; workers exit over a protected hall runner to the waste-staging point; tools and bag exteriors HEPA-vacuumed or wet-wiped before exit.

Plastic as needed is not measurable. Room sealed can also be unsafe if it blocks a required path or hides how airflow and ducts were handled.

Write the exterior containment plan around migration

For federal RRP exterior work, § 745.85 requires doors and windows within 20 feet of the renovation to be closed. On a multistory building, that means openings within 20 feet on the same floor and openings on every floor below at the same horizontal distance from the renovation. A door in the work area that must remain in use needs a plastic or other impermeable covering that lets workers pass while confining dust and debris.

Record:

• elevation and work height;
• every opening within the applicable zone, including lower floors;
• door protection and controlled access;
• ground-cover boundary and property-line limitation;
• vertical containment or equivalent extra precautions when work is within 10 feet of a property line;
• wind, rain, and weather stop conditions;
• roof, porch, scaffold, lift, and ladder interfaces;
• neighboring buildings, sidewalks, vehicles, HVAC intakes, gardens, and play equipment;
• falling-chip and tool-drop controls;
• waste lowering method; and
• daily ground and adjacent-surface inspection.

The federal rule generally calls for ground covering ten feet beyond affected surfaces or far enough to collect falling debris, whichever is greater, unless the property line prevents it. That is a minimum rule, not proof ten feet will always contain dust on a windy multi-story project.

Sample stop condition:

Exterior paint disturbance stops when wind, rain, loss of containment, pedestrian traffic, opening use, or equipment movement could carry dust or debris outside the controlled area. The assigned renovator must reassess and document additional containment before work resumes.

Lock the method before the crew arrives

The work order should list approved and prohibited tools by component.

Federal RRP work-practice standards prohibit open-flame burning or torching of painted surfaces. They prohibit high-speed paint-removal machines—such as sanding, grinding, power planing, needle guns, abrasive blasting, or sandblasting—unless the machine has the required shroud or containment and HEPA vacuum attachment operated so there is no visible release outside the system. Heat guns must stay below 1,100°F.

Use a method table:

The assigned certified renovator determines and supervises the compliant RRP setup and methods. The employer separately determines the worker controls required by exposure assessment and OSHA.

Keep the OSHA worker plan separate and connected

EPA RRP focuses on preventing renovation lead hazards to occupants and the environment. OSHA's construction lead standard protects employees.

29 C.F.R. § 1926.62 applies to construction work where an employee may be occupationally exposed to lead, including alteration, repair, renovation, painting, decorating, demolition, cleanup, transportation, storage, and containment. It sets an action level of 30 micrograms per cubic meter as an eight-hour time-weighted average and a permissible exposure limit of 50 micrograms per cubic meter as an eight-hour time-weighted average. It requires exposure assessment and, depending on the work and results, engineering and work-practice controls, respiratory protection, protective clothing, hygiene, housekeeping, medical surveillance, training, signage, and records.

Do not copy N95 required into every lead-safe work order. Respirator selection, medical evaluation, fit testing, program administration, cartridge choice, change schedule, facial-hair restrictions, and exposure basis belong to the employer's respiratory-protection process.

Reference the controlling safety documents:

• project job-hazard analysis;
• lead exposure assessment and similar-exposure-group basis;
• OSHA interim protection category if applicable;
• engineering and work-practice controls;
• respiratory-protection program and assigned equipment;
• protective clothing and changing plan;
• handwashing and hygiene facilities;
• eating, drinking, smoking, and cosmetics restrictions;
• HEPA housekeeping method;
• employee information and training;
• medical surveillance or biological monitoring path;
• competent-person assignment; and
• emergency and exposure-incident response.

Also check whether the state operates an OSHA-approved State Plan, because state occupational-safety requirements can be different or more stringent.

One work order can coordinate the plans without pretending they are the same:

RRP occupant-control plan: LR-031-RRP. Employer exposure assessment and written compliance program: ECP-LD-07. JHA: JHA-884. Work may proceed only after the assigned renovator and the employer's designated safety lead or competent person, as applicable, confirm the prerequisites within their respective responsibilities.

Control waste from creation through transport

Federal RRP rules require renovation waste to be contained before it leaves the work area, protected from release and access at the end of each day, and contained during transport.

The work order should specify:

• waste types expected;
• collection at the point of generation;
• heavy-duty bags, wrapping, rigid containers, or other approved containment;
• sharp or breakable-component handling;
• bag closure and exterior decontamination;
• label or identification required by the applicable program or disposal facility;
• daily secure staging location;
• chute controls if used;
• vehicle containment;
• destination and acceptance confirmation;
• weight tickets or receipts where relevant;
• spill or torn-container response; and
• person responsible for end-of-day inspection.

EPA says contractors may send lead-containing waste from residential renovations to a municipal solid-waste landfill or combustor, and the federal household-waste exclusion can apply to contractor-generated residential renovation waste. That does not remove RRP containment duties, override stricter state, tribal, or local rules, or guarantee facility acceptance; nonresidential waste may remain subject to hazardous-waste requirements. Confirm the destination before pricing, and do not dump or open-burn the waste.

Use a daily open-and-close record

Containment can fail after setup.

At the start of each shift, record:

• signs present and readable;
• containment intact;
• openings and ducts still controlled;
• egress clear;
• occupants and pets outside the area;
• HEPA equipment inspection complete;
• approved methods and worker controls ready;
• weather acceptable for exterior work;
• waste route and staging available; and
• no scope change since the prior shift.

At the end of each shift, record:

• work completed and components disturbed;
• actual disturbed area versus estimate;
• containment repairs or incidents;
• visible dust and debris removed;
• tools, workers, and material exits controlled;
• waste sealed and secured;
• openings and building systems left in approved condition;
• occupant route restored or still restricted;
• photos taken;
• customer or property contact notified; and
• work area secured against entry.

If the project continues overnight, daily cleaning and secure containment are not the same as final cleaning verification. Label the status accurately.

Define the emergency-renovation boundary

A pipe bursts behind painted plaster in a pre-1978 rental. Immediate work may be needed to stop water and prevent major property damage.

EPA's emergency-renovation guidance treats the emergency provision as limited to activities immediately necessary to respond. Under the federal program, certain pre-renovation education, warning-sign, containment, training, and certification provisions can be affected for the emergency portion, but cleaning, cleaning verification, and recordkeeping remain. Later work to restore the opened wall is ordinary renovation work, not an indefinite continuation of the emergency exception.

The emergency plumbing work-order guide shows how to document shutoff, access authorization, stabilization, and the later restoration handoff without stretching that exception.

Use two authorizations:

1. Emergency stabilization: shut off source, open only what is necessary, protect health/property, collect debris, clean, verify, and record under the applicable emergency provisions.
2. Restoration: reassess scope, issue normal notices, confirm credentials, establish containment, and complete the patch and paint under the ordinary applicable rules.

The emergency record should state:

• unexpected event and discovery time;
• immediate hazard or threatened damage;
• why delay was not practical;
• work strictly necessary to end that condition;
• who authorized entry and actions;
• requirements still followed;
• cleaning, verification, waste, and records;
• stabilization endpoint; and
• remaining restoration scope held for normal authorization.

Customer wanted it today is not an emergency.

Make final cleaning and verification a release gate

Under federal 40 C.F.R. § 745.85, the firm cleans until no dust, debris, or residue remains. The rule specifies collection and bagging, handling of protective sheeting, interior high-to-low cleaning, HEPA vacuuming, damp wiping, and floor mopping. The assigned certified renovator then performs the required visual inspection and cleaning-verification steps for interiors. Exterior work receives a visual inspection of surfaces in and below the area, including windowsills and ground.

The closeout form should identify:

• renovation complete time;
• debris and chips collected;
• sheeting misted, folded dirty-side inward, and sealed;
• walls, objects, fixtures, floors, carpets, and surfaces cleaned by the applicable method;
• certified renovator visual inspection result;
• each windowsill verified;
• floor and countertop sections, including section size and cloth result;
• re-cleaning and waiting steps where required;
• exterior ground and adjacent-surface inspection;
• warning-sign removal authorization;
• optional or required dust-clearance sampler and results;
• release time; and
• renovator name, certificate, signature, and date/time of the activity.

Do not write passed lead test when the process was cleaning verification. Cleaning verification is not a laboratory test for a lead concentration and does not certify the home is lead-free.

Federal § 745.85 allows cleaning verification to be replaced in certain circumstances by required dust-clearance sampling performed by a qualified certified professional, with re-cleaning until results meet the applicable standard. If HUD, an authorized program, local law, grant, owner specification, or contract requires clearance, identify that before the job starts.

Add the HUD and assisted-housing branch

Do not assume EPA RRP is the whole rule set when federal housing assistance is involved.

A 2026 EPA/HUD guide to the additional Lead Safe Housing Rule requirements for RRP firms and renovators explains that the Lead Safe Housing Rule applies to covered pre-1978 federally owned residential property and housing receiving federal assistance. Depending on the program and activity, it can require evaluation, hazard reduction, occupant notices, work methods, and clearance. The current regulation is at 24 C.F.R. Part 35.

Add an intake question:

Is this property federally owned, receiving federal housing assistance, part of a rehabilitation grant or loan, public housing, project-based or tenant-based assistance, or otherwise subject to a lead-safe housing program? [Yes / No / Unknown]. Program and administrator: [ ].

If yes or unknown, obtain the program's written scope before pricing the work or defining release conditions. The program administrator, owner, and contractor should identify:

• applicable Part 35 subpart;
• evaluation or presumption method;
• occupant protection and relocation;
• interim controls or abatement;
• training and supervision;
• prohibited methods;
• clearance and laboratory requirements;
• notices to occupants;
• documentation and retention; and
• who may approve release and payment.

A standard RRP cleaning-verification record may not satisfy the HUD project closeout.

Price the lead-safe scope as work

Lead-safe work consumes labor, materials, equipment, supervision, and time in the schedule.

Use transparent line items:

The FTC's home-improvement guidance urges consumers to get written estimates and contracts describing work, materials, timing, and price. A lead-safe quote should therefore say which containment and verification path is included—not simply add an unexplained environmental fee.

Use a change order when:

• disturbed area expands;
• another painted component enters scope;
• an assumed exemption no longer applies;
• testing or records conflict;
• the customer requests window or trim removal;
• the project changes from renovation to abatement or HUD-regulated work;
• clearance is required;
• hidden rot, moisture, plaster failure, or structural damage changes the repair;
• access or occupancy changes containment; or
• weather, property line, or adjacent-property conditions require added exterior controls.

Get the change approved before the newly added disturbance begins. If there is an emergency, limit unapproved work to the narrow actions genuinely necessary to control it, then document and authorize the later restoration.

Deliver the required closeout information

Federal 40 C.F.R. § 745.86 requires covered firms to retain specified records for three years after completion. It also sets delivery rules for post-renovation compliance information: provide it to the owner and, when different, an adult occupant of a renovated dwelling or an adult representative of a child-occupied facility. For common-area renovations, post the information—or instructions for obtaining it—where occupants of the affected units are likely to see it. Delivery or posting is due when the final invoice is delivered or within 30 days after completion, whichever is earlier.

The job file should include:

• property, unit, owner, and occupant;
• contract and approved changes;
• property-age and use evidence;
• program-jurisdiction determination;
• firm and renovator credentials;
• worker training records;
• pamphlet acknowledgments, mailing proof, notices, posting records, and supplemental notices;
• paint-test or lead-free reports relied upon;
• component schedule and disturbed-area calculations;
• work methods and equipment;
• warning-sign and containment records;
• daily checks, exceptions, incidents, and corrective actions;
• waste containment and disposal evidence;
• cleaning and cleaning-verification checklist;
• clearance report when applicable;
• required owner/occupant delivery record;
• photos with labels and context;
• completion sign-off and final invoice; and
• any longer state, HUD, grant, contract, insurance, tax, warranty, or litigation retention requirement.

Do not retain only photos. Do not retain only the signed contract. Do not make the only copy of the certified renovator's checklist an attachment inside an accounting system that deletes files after payment.

A field-ready lead-safe work-order layout

Use the general work order as the operational shell, then attach the regulated lead record.

Use the employer's job hazard analysis and safety inspection checklist for the actual crew controls, qualifications, PPE decision, containment checks, and stop conditions. The PPE and hazard-assessment guide explains that boundary. At handoff, record completed work and cleaning verification in the service report, then connect the completion sign-off and invoice to the same work-order ID. For exterior scope and weather assumptions, continue with the exterior painting bid guide.

Header and authority

• work-order number and revision;
• customer, property, building, unit, and access contact;
• contract/quote/change references;
• exact scope and exclusions;
• owner or customer authorization and occupant notice/access status;
• scheduled work window; and
• emergency status, if any.

Coverage and program

• construction year and evidence;
• property use and occupancy;
• target-housing/child-occupied-facility determination;
• compensation and covered-firm determination;
• EPA/state/tribal/territorial program;
• HUD or local overlay;
• minor-repair analysis or other exception evidence; and
• lead determination by component.

Qualifications

• certified firm/license;
• assigned certified renovator;
• trained workers;
• employer safety lead or competent person, when required by the applicable OSHA program;
• subcontractor credentials; and
• inspector/risk assessor/dust sampler when applicable.

Notices

• owner pamphlet delivery;
• occupant pamphlet delivery;
• common-area or child-facility notice/posting;
• acknowledgment, self-certification, or mailing proof;
• language and accessibility steps; and
• supplemental notice trigger.

Field plan

• component and disturbance schedule;
• work-area sketch;
• occupant and egress plan;
• interior/exterior containment;
• approved tools and prohibited methods;
• OSHA plan references;
• daily open/close checklist;
• waste route and destination;
• emergency response; and
• stop-work/change conditions.

Closeout

• final cleaning steps;
• visual inspection;
• cleaning-verification record;
• clearance record if required;
• warning-sign removal and release;
• owner/occupant compliance handoff;
• photos and exceptions;
• completion acknowledgment; and
• record-retention location and responsible person.

The work order should allow not applicable only when the reason is stated. Blank fields invite after-the-fact reconstruction.

A pre-start checklist for the assigned renovator and supervisor

• [ ] Property, unit, year, use, and occupancy are verified.
• [ ] The administering RRP program and any HUD/local overlay are identified.
• [ ] Firm and renovator credentials, any required contractor or subcontractor licenses, and worker training records are current for the jurisdiction.
• [ ] Every painted component and planned disturbance method is listed.
• [ ] Any minor-repair or lead-free determination has component-specific supporting evidence.
• [ ] Renovate Right and all owner, occupant, common-area, or child-facility notifications are complete and documented.
• [ ] Occupants, children, pets, belongings, access, language, and emergency egress are addressed.
• [ ] Containment is installed, measurable, photographed, intact, and compatible with egress.
• [ ] Tools, HEPA equipment, waste containers, and cleaning supplies are ready.
• [ ] Prohibited and restricted methods are blocked in the work order.
• [ ] The OSHA exposure, respiratory, hygiene, training, and medical pathways are confirmed by the employer.
• [ ] Daily cleaning, waste staging, security, and customer communication are assigned.
• [ ] Scope-expansion and emergency stop rules are understood.
• [ ] The correct cleaning-verification or clearance release path is identified.
• [ ] The people responsible for record delivery and retention are assigned.

If the checklist is incomplete, “be careful” is not a control. Do not disturb the affected paint until the missing prerequisite is resolved.

Sources

The federal regulations and agency program pages below were checked on August 27, 2026. The eCFR displayed Title 40 as current through August 25, 2026. State, tribal, territorial, local, HUD-program, and worker-safety requirements can change or differ, so verify the rules for the job site before bidding or disturbing paint.

• U.S. EPA — Renovation, Repair and Painting Program: Contractors
• U.S. EPA — Lead Renovation, Repair and Painting Program
• U.S. EPA — RRP Firm Certification
• U.S. EPA — Small Entity Compliance Guide to Renovate Right
• U.S. EPA — Lead-Based Paint Program Frequent Questions
• U.S. EPA — Renovate Right pamphlet
• U.S. EPA — Emergency renovations under the RRP Rule
• U.S. EPA — Handling and disposal of lead-containing waste from RRP renovations
• Electronic Code of Federal Regulations — 40 C.F.R. § 745.82, applicability and emergency renovations
• Electronic Code of Federal Regulations — 40 C.F.R. § 745.83, definitions and 30-day aggregation
• Electronic Code of Federal Regulations — 40 C.F.R. § 745.84, information distribution
• Electronic Code of Federal Regulations — 40 C.F.R. § 745.85, work-practice standards
• Electronic Code of Federal Regulations — 40 C.F.R. § 745.86, recordkeeping and reporting
• Electronic Code of Federal Regulations — 40 C.F.R. § 745.89, firm certification
• OSHA — 29 C.F.R. § 1926.62, Lead in Construction
• OSHA — State Plans
• Washington State Department of Commerce — RRP Program
• Washington State Department of Commerce — Lead-Based Paint Programs
• Massachusetts Department of Labor Standards — Deleading and Lead Safety Program
• Massachusetts — 454 CMR 22.00, Deleading and Lead-Safe Renovation Regulations
• Massachusetts — Lead-Safe Renovation for Homeowners
• U.S. EPA and HUD — Additional Requirements of HUD's Lead Safe Housing Rule for EPA Certified Renovation Firms and Certified Renovators (2026)
• Electronic Code of Federal Regulations — 24 C.F.R. Part 35, Lead-Based Paint Poisoning Prevention in Certain Residential Structures
• HUD — Guidelines for the Evaluation and Control of Lead-Based Paint in Housing
• Federal Trade Commission — How To Avoid a Home Improvement Scam
• Federal Trade Commission — Cooling-Off Period for Sales Made at Homes or Certain Other Locations