Lead rule checker

People get this wrong in both directions

One manager assumes every old building is covered and pays for containment and certification on jobs that never needed it. Another assumes it doesn’t apply and finds out from a fine. The rule itself is short — two area thresholds, two things that trigger regardless of area, three exemptions, and four answers to “who has to be certified”. It is a decision, so this is a decision tool rather than an article.

The two traps

Full window replacement and demolition are carved out of the exception. The square-footage thresholds belong to the minor repair and maintenance exception, and replacing a whole window is one of the things expressly excluded from it — so the rule applies in pre-1978 housing however small the area. Window troughs and friction surfaces are exactly where lead dust concentrates.

Repairing a window is not replacing it. Sash replacement, glass replacement and balancer work are ordinary jobs measured against the same thresholds as anything else. Treating a glass repair as an automatic trigger sends somebody to buy a certification they do not need, which is its own wrong answer — so the tool asks which of the two you are doing.

The measurement is the whole project, over 30 days. 6 square feet inside a room is about a two-by-three-foot patch, and the threshold is measured per room across a 30-day window — so doing the job over four afternoons does not make it four small jobs. If the scope grows mid-job, the answer can change — which is worth re-checking before the extra work starts rather than after.

Working on your own rental doesn’t exempt you

This is the one that surprises people. An owner-occupant renovating their own home is outside the rule. A landlord doing the same work on a unit they rent out is not — they need firm and renovator certification. Hire an outside contractor instead and the obligation moves to them, but you should ask to see the firm certificate rather than take a logo on a business card for it.

Where it meets the other tools

The PM checklist already flags buildings built before 1978; this is the tool that flag points at. A unit turn almost always means repainting, which is where this question comes up most often in multifamily. Before dispatching a work order to an outside contractor on an old building, this is the check — and their certification sits alongside their insurance on the COI register.

If lead work does go ahead and somebody is hurt doing it, the OSHA 300 log is a separate question with separate rules.

A self-check against the federal Renovation, Repair and Painting rule (40 CFR Part 745, Subpart E), reviewed August 2026. CompliMaint is not EPA, issues nothing, and makes no determination — this records your own answers to the rule’s questions. Not legal advice and not a substitute for the rule. Several states run their own authorized lead programmes which can be stricter than the federal floor, so check yours. Confirm current requirements and any firm’s certification status at epa.gov. Everything runs on your device.