Lead-safe rules for floor work in homes built before 1978

When sanding a floor, cutting baseboards or putting in carpet comes under the EPA's lead-safe rule, what the company then has to do, and which states run their own program.

Updated October 12, 202622 official sources

On this page5 sections

1Which homes it covers
2When floor work is covered
3What the company has to do
4States that run their own program
5What to ask before work starts

Old paint can contain lead, and some floor work disturbs paint: sanding a painted floor, or cutting or taking off painted baseboards and trim. A federal rule sets how companies have to work when that happens in a home built before 1978. Here's when it applies to floor work, what it asks, and where a state runs the program itself.

Which homes it covers

The rule covers target housing: any housing built before 1978, except housing for the elderly or people with disabilities and homes with no separate bedroom, unless a child under 6 lives there or is expected to.^1-2

When floor work is covered

The rule covers a renovation: work that disturbs painted surfaces, including surface preparation such as sanding or scraping. A painted surface is one covered in whole or in part with paint or other surface coatings, and floors, doors, door trim and stair treads are among the parts of a home the rule names.² So sanding a painted floor or taking off painted trim in a pre-1978 home can come under it.

A small job can be exempt as minor repair and maintenance: 6 square feet or less of painted surface per room inside. When painted parts are taken off, the whole surface of what's taken off counts, and jobs in the same room within 30 days count as one job.²

The EPA's answers on floor jobs:³

Cutting baseboards and door casings. When an installer trims the bottom of painted baseboards or door casings with an undercut saw, the area that counts is the surface of the strip cut off, not the width of the saw blade. Cutting a 1-inch strip off a 36-inch-wide door counts as 36 square inches.
Carpet. A carpet job that disturbs 6 square feet or less of painted surface per room isn't covered.
New flooring that disturbs no paint. A project that doesn't disturb a painted surface isn't covered.
Glazed tile. Ceramic tile glaze is neither a surface coating nor a painted surface, so a job that disturbs it isn't covered.

The EPA says these answers are guidance, and that they don't necessarily bind the EPA or anyone else.³

What the company has to do

Be certified. No firm may do, offer or claim to do renovations in target housing without certification.⁴
Put a certified renovator in charge. Renovations have to be directed by a certified renovator and done by certified renovators or workers they've trained.⁴
Give you the Renovate Right pamphlet. The firm has to give the owner the EPA's pamphlet no more than 60 days before work starts.⁵
Sand only with dust collection. A machine that sands or grinds paint off can be used on a painted surface only with a shroud or containment system and a HEPA vacuum attachment that collects the dust where it's made.⁶
Cover the floor, and clean it after. Inside, the firm has to cover the floor of the work area with taped-down plastic sheeting, unless that's impossible, as it can be while flooring is being taken up, a hardwood floor is being sanded or carpet is going in or coming out. Either way it has to clean the floor at the end with a HEPA vacuum.³

States that run their own program

In most states the EPA certifies firms. Fifteen states are authorized to run their own program in place of the federal one, and a firm working there gets its lead-safe certification from the state.⁷

State	The program
Alabama	EPA has authorized Alabama to run its own program.^7-8
Delaware	EPA has authorized Delaware to run its own program. Delaware's Division of Public Health certifies renovation firms and renovators (16 DE Admin. Code 4459B), and its rule reaches homes, child care facilities and schools built before 1978 when a job disturbs more than 6 square feet of painted surface in a room.^{7, 9}
Georgia	EPA has authorized Georgia to run its own program.^{7, 10}
Iowa	EPA has authorized Iowa to run its own program. Iowa's licensing department certifies lead-safe renovators and their firms, and says Iowa law requires its lead poisoning booklet to be given before renovating more than one square foot of painted surface.^{7, 11}
Kansas	EPA has authorized Kansas to run its own program.^{7, 12}
Massachusetts	EPA has authorized Massachusetts to run its own program.^{7, 13}
Mississippi	EPA has authorized Mississippi to run its own program.^{7, 14}
North Carolina	EPA has authorized North Carolina to run its own program.^{7, 15}
Oklahoma	EPA has authorized Oklahoma to run its own program.^{7, 16}
Oregon	EPA has authorized Oregon to run its own program. In Oregon a licensed contractor gets a Lead-Based Paint Renovation (LBPR) license from the Construction Contractors Board; firms that don't need a CCB license are certified by the Oregon Health Authority.^{7, 17-18}
Rhode Island	EPA has authorized Rhode Island to run its own program. Rhode Island's rule reaches homeowners as well as contractors and landlords. A licensed Lead Renovation Firm must notify the Department of Health at least 7 days before work that includes interior mechanical paint removal or interior demolition, a certified renovator must be on site, and lead hazard control work ends with a clearance inspection by a licensed lead inspector.^{7, 19}
Utah	EPA has authorized Utah to run its own program.^{7, 20}
Vermont	EPA has authorized Vermont to run its own program. Vermont's RRPM rules count any paint, coating, stain or seal made before 1978 as lead-based paint in pre-1978 housing, and require a Lead-Safe RRPM license for work disturbing more than 1 square foot per interior room (the federal line is 6). Homeowners working on their own homes don't need the license.^{7, 21}
Washington	EPA has authorized Washington to run its own program.⁷
Wisconsin	EPA has authorized Wisconsin to run its own program.^{7, 22}

Each state's rules page on this site, linked above, has its lead-safe section.

What to ask before work starts

Whether any part of the floor, the baseboards or the trim the job will touch is painted.
Whether the company is a lead-safe certified firm, and who certified it: the EPA or your state.
Who the certified renovator on your job will be.
When you'll get the Renovate Right pamphlet.
How the crew will contain the dust and clean up.

Each company on this site is listed with its phone number where it has one. You can also send a request through the request form.

Rules from the Electronic Code of Federal Regulations and the US Environmental Protection Agency, and state lead programs, checked October 2026.