Any firm paid to perform renovation, repair, or painting that disturbs paint in housing or child-occupied facilities built before 1978 needs EPA RRP firm certification. That covers general contractors, painters, plumbers, electricians, HVAC techs, window and door installers, drywall and flooring crews, handyman businesses, property managers, landlords who self-perform, and house flippers. If the building predates 1978, you are paid for the work, and the job disturbs more than 6 square feet of interior paint, more than 20 square feet of exterior paint, or any window, your company must be a Lead-Safe Certified Firm before you advertise for or start the work.
The rule comes from the federal Toxic Substances Control Act, and it applies to the firm as a business, not just to the person swinging the hammer. Even a one-person company (a sole proprietorship) needs firm certification. Federal penalties reach up to $37,500 per violation, per day, so this is not a paperwork formality you can skip and sort out later. If your firm works in older homes, start your filing at LeadSafeFiling.com and we handle the paperwork for you.
Three conditions decide whether RRP certification applies to a job. If all three are true, your firm must be certified. If any one of them is false, that particular job falls outside the rule. The trade you work in does not change this test. A plumber and a painter answer the exact same three questions.
The RRP Rule is written around the work, not the job title, so it sweeps in far more trades than most contractors expect. People assume it is a painter's rule. It is not. Any trade that cuts, drills, sands, scrapes, demolishes, or otherwise breaks a painted surface in a pre-1978 home can trip the 6-square-foot trigger fast. A plumber opening a wall to reach a stack, an electrician chasing a circuit, or an HVAC tech cutting a return all disturb paint.
If your firm sends crews into older homes for any of the work below, you almost certainly need certification. When a job is borderline, certify. It is far cheaper than a single penalty.
It depends on who actually does the work. If a landlord, a property management company, or in-house maintenance staff performs renovation, repair, or painting on a pre-1978 rental that crosses the disturbance threshold, the landlord's company must be a Lead-Safe Certified Firm, and the person doing the work must be (or be trained by) a certified renovator. The EPA treats rental property maintenance for compensation as covered work, because the rent is the compensation.
If instead you hire an outside contractor to do the work, you as the landlord do not need firm certification yourself. In that case the firm you hire must be the Lead-Safe Certified Firm, and they must use a certified renovator on the job. A property company with its own maintenance crew almost always needs firm certification. A hands-off owner who always subcontracts does not, as long as the contractors they hire are certified.
Yes, in most cases. If you flip a house built before 1978 and your own business or crew performs renovation, repair, or painting that disturbs paint above the threshold, your firm needs RRP certification, the same as any contractor. Flipping for profit is compensated work, and the heavy scraping, demolition, and window swaps typical of a flip blow past the 6-square-foot trigger immediately.
There is one narrow gap. The RRP Rule governs renovation work, not the real estate sale itself, and it does not apply to work you do on your own primary residence that you live in. A flip is an investment property you renovate to sell, so the work is covered. If you subcontract the entire renovation to certified firms and never have your own crew disturb paint, the certification obligation sits with those contractors instead. Most active flippers who self-perform any meaningful share of the work should be a certified firm.
The firm that physically performs the paint-disturbing work is the firm that must be certified. If you are a general contractor and you sub the demolition or painting to another company, that subcontractor must be a Lead-Safe Certified Firm. If your own crews also disturb paint on the project, then your company needs certification too.
A handshake or a contract clause does not shift the duty away from you. Both the hiring firm and the performing firm carry their own obligations under the rule, and the EPA can pursue whoever did the covered work without certification. The safe practice for a GC is to be certified yourself and to verify that every sub working in pre-1978 homes holds a current firm certification before they set foot on site.
These are two different things, and you likely need both. Firm certification is the company credential. It is what LeadSafeFiling.com prepares and files for you, it covers the business as a Lead-Safe Certified Firm, and EPA firm certification lasts five years. It does not require a Social Security number and it does not involve a class.
The Certified Renovator credential is an individual credential. A person earns it by taking an accredited 8-hour training course, and at least one certified renovator must be assigned to each covered job to direct lead-safe work practices and train other workers on site. A complete, compliant operation has both: a certified firm (the company) and at least one certified renovator (a trained person) available for the work.
The rule has real limits, and a few situations fall outside it. Knowing them keeps you from over-filing. When a job is borderline, the cautious move is still to certify, since the threshold is easy to cross.
A home built in 1978 or later is exempt only if it has no lead paint, and the safest assumption for any pre-1978 structure is that lead paint is present unless testing proves otherwise.
Once you have confirmed your firm needs certification, getting it is straightforward, and you do not have to navigate the EPA's CDX system or a state portal yourself. LeadSafeFiling.com prepares your firm certification application from the details you provide, files it as your authorized agent, and delivers your certificate and Lead-Safe Certified Firm logo by email. No Social Security number is ever required.
Pricing is a flat $129 service fee plus the government filing fee. All in, that is $429 for EPA-administered states (filed through the EPA CDX system), and we also file the four state-run programs directly: North Carolina ($429), Delaware ($429), Wisconsin ($379), and Washington ($154). Pick your state and start your filing at LeadSafeFiling.com, and we handle the rest.
Any firm paid to perform renovation, repair, or painting that disturbs paint in housing or child-occupied facilities built before 1978 must hold EPA RRP firm certification. This includes general contractors, painters, plumbers, electricians, HVAC techs, window installers, landlords who self-perform, and house flippers. Even a one-person company needs it.
Yes, if they are paid to work on pre-1978 homes and the job disturbs more than 6 square feet of interior paint, more than 20 square feet of exterior paint, or any window. Painters trip the threshold through scraping and sanding, and plumbers trip it by opening walls, ceilings, or floors. The rule follows the work, not the trade.
Yes. If a GC or its crews disturb paint in pre-1978 housing above the threshold, the GC's company must be a Lead-Safe Certified Firm. Subcontractors that perform paint-disturbing work must also be certified on their own. The duty sits with whoever actually does the covered work.
If a landlord or property management company does its own renovation, repair, or painting on a pre-1978 rental above the threshold, the company must be a certified firm and use a certified renovator. If they instead hire an outside contractor, the landlord does not need certification, but the contractor they hire must be a certified firm.
Yes, in most cases. Flipping a pre-1978 house is compensated work, and typical flip activities like demolition, scraping, and window replacement disturb paint well above the threshold. If your own crew self-performs the work, your firm needs RRP certification. If you fully subcontract to certified firms, the obligation sits with them.
The firm that physically performs the paint-disturbing work must be certified. If your own crews also disturb paint on the job, your company needs certification too. A contract clause does not transfer the duty, and the EPA can pursue any firm that did covered work without certification, so a GC should be certified and verify every sub is as well.
No. Federal law requires all renovation, repair, and painting firms, including sole proprietorships, to be certified when working on pre-1978 housing or child-occupied facilities. A solo contractor needs firm certification just like a large company.
Firm certification is the company credential and is what LeadSafeFiling.com files for you; EPA firm certification lasts five years and needs no Social Security number. A Certified Renovator is an individual who completes an accredited 8-hour course and must be assigned to each covered job. Most operations need both.
Operating without required firm certification exposes your business to federal penalties of up to $37,500 per violation, per day. A firm must be certified before it advertises for or performs covered work, so the safe move is to certify before you take the job.
Start your filing at LeadSafeFiling.com. We prepare your firm certification application, file it with the EPA or your state as your authorized agent, and deliver your certificate by email, typically in about one to two weeks. Pricing is a flat $129 service fee plus the government filing fee, with no SSN required.
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