Lead Paint in California: The Rules, Certifications, and Lead-Safe Dos and Don'ts for Pre-1978 Buildings

Lead-based paint was banned for residential use in 1978. Any house, apartment, or child-occupied facility (like a pre-school or daycare) built before 1978 is treated as potentially containing lead-based paint until testing proves otherwise.

Paint is "lead-based" if it contains lead at or above 1.0 mg/cm² or 0.5% by weight (5,000 ppm).

The trigger is building age — not how the building looks or how recently it was repainted. Newer paint often sits on top of old lead paint, and some imported materials still contain lead.

Four authorities can apply to the same project:

EPA Renovation, Repair & Painting (RRP) Rule (40 CFR 745, Subpart E): lead-safe work practices for ordinary renovation, repair, and painting that disturbs paint in pre-1978 housing and child-occupied facilities. Requires certified firms and certified renovators. The EPA currently administers the RRP program in California.

Federal Lead Disclosure Rule (Title X, Section 1018): sellers and landlords of pre-1978 housing must disclose known lead paint/hazards and give buyers and tenants the EPA information pamphlet.

CDPH Lead-Related Construction (Title 17, CCR, §§36000–36100): California certification and work-practice rules for lead inspection, risk assessment, clearance testing, and abatement in residential and public buildings.

Cal/OSHA Lead in Construction (8 CCR §1532.1): worker protection — exposure limits, training, respirators, hygiene, and medical surveillance.

Two more apply in specific cases: the California Education Code (§32243) for public schools, pre-schools, and daycares, and the HUD Lead Safe Housing Rule (24 CFR Part 35) for federally assisted housing.

These are two different kinds of work with two different certification systems.

Renovation (RRP) is ordinary remodeling, repair, or painting where disturbing lead paint is incidental — the goal is to do the work lead-safely. It is governed by the EPA RRP Rule, and the firm must be EPA Lead-Safe Certified with a certified renovator on the job.

Abatement is work whose specific purpose is to permanently eliminate lead-based paint or hazards (designed to last 20 years or more). It is governed by CDPH Title 17 and must be performed by CDPH-certified Lead Supervisors and Workers.

Short version: if the point of the job is to get rid of the lead, it's abatement (CDPH); if the lead just happens to be in the way of a renovation, it's RRP (EPA).

The EPA RRP Rule applies to compensated renovation, repair, or painting in pre-1978 housing or child-occupied facilities that disturbs more than 6 square feet of painted surface per room (interior), more than 20 square feet (exterior), or any window replacement or demolition of painted surfaces (covered regardless of size).

Work below those amounts is minor repair and is exempt — but if you cross the threshold mid-project, the rule applies. A homeowner working on their own primary residence is not subject to the RRP firm-certification requirement, though lead-safe practices are still strongly advised. The moment you pay someone to do the work, or the home is a rental, certification applies.

There is no standalone statewide "lead permit" for most residential renovation. Compliance runs through certification (EPA firm/renovator for RRP; CDPH for abatement), work-practice rules, and required notifications, plus any local building permit for the underlying construction. Abatement activities must follow Title 17 work practices, and CDPH requires notification of abatement work. School and HUD-funded projects carry added requirements.

Do: assume pre-1978 paint contains lead until tested; hire an EPA Lead-Safe Certified firm for renovations and a CDPH-certified professional for inspection or abatement, and ask to see the certification; get a lead inspection before major work, especially with young children or a pregnant person in the home; keep kids and pregnant people away from the work area and use wet cleaning and HEPA vacuuming; ask for the EPA pamphlet and keep all documentation.

Don't: dry-sand, power-sand or grind without HEPA, use a heat gun above 1100°F, or open-flame burn or torch lead paint; sweep or use a regular household vacuum on lead dust; assume a newer-looking or recently repainted building is lead-free; hire an uncertified contractor for paint-disturbing work on a pre-1978 property.

Do: hold the right credential — EPA Lead-Safe firm certification plus a certified renovator for RRP, or CDPH Lead-Related Construction certification for abatement — with the appropriate CSLB license; give the owner/occupant the EPA pamphlet before work and keep RRP records at least three years; test or presume lead, then contain, control dust, and perform cleaning verification; comply with Cal/OSHA §1532.1 (exposure assessment, respirators, hygiene, training, medical surveillance). The Cal/OSHA permissible exposure limit is 50 µg/m³ (8-hour average) with a 30 µg/m³ action level.

Don't: perform RRP work on pre-1978 housing without both firm and renovator certification; treat an abatement job as if it were RRP (abatement requires CDPH certification); use prohibited work practices or skip containment and cleanup verification; let workers exceed Cal/OSHA exposure limits without controls.

Do: for pre-1978 units, meet the federal Lead Disclosure Rule — disclose known lead paint and hazards, provide available records, give tenants and buyers the EPA pamphlet, and include the required lead warning in leases and sales contracts; use EPA Lead-Safe Certified firms for paint-disturbing maintenance or turnovers and CDPH-certified contractors for abatement; keep disclosure and work records on file; respond promptly to tenant lead concerns or a child's elevated blood-lead level; for federally assisted housing, follow the HUD Lead Safe Housing Rule.

Don't: let in-house maintenance disturb pre-1978 paint above the minor-repair thresholds without RRP-certified personnel; skip lead disclosure (violations carry significant federal penalties); rely on building age or fresh paint to assume a unit is lead-safe.

Does lead paint law depend on building age? Yes — it applies to housing and child-occupied facilities built before 1978.

What counts as lead-based paint? Lead at or above 1.0 mg/cm² or 0.5% by weight (5,000 ppm).

What's the difference between RRP and abatement? RRP is doing renovation lead-safely (EPA-certified firm and renovator); abatement is permanently eliminating lead (CDPH-certified personnel under Title 17).

Can I remove lead paint myself in my own home? A homeowner on their own primary residence isn't subject to RRP firm certification and can test their own home, but should use lead-safe practices and never prohibited methods.

Do I need a permit in California? No standalone lead permit; compliance is through certification, work practices, and notifications, plus any local building permit.

Who must be certified? Paid lead inspection, assessment, clearance, and abatement require CDPH certification; paid renovation disturbing paint in pre-1978 housing requires an EPA Lead-Safe Certified firm with a certified renovator.

All Clear Environmental is a licensed abatement contractor serving Los Angeles County (CSLB #824771, DOSH #897). We handle lead the way the rules require — with the right certifications, containment, and documentation — so your project stays safe and compliant.

Whether you're a homeowner planning a remodel, a contractor who needs qualified abatement on a pre-1978 job, or a property manager preparing a turnover, we'll help you figure out which requirements apply and take care of the work.

Book a free job walk at https://allclearenvironmental.com/free-estimate or call 818-762-2030. This article is informational and not legal advice.