Lead-Safe Screening on Pre-1978 Homes: the full procedure

Determine whether a job is in a pre-1978 home that triggers the EPA RRP rule, and stop to follow lead-safe requirements before disturbing painted surfaces.

• Applies to: Owner / lead (certified renovator where required)
• Frequency: Every job in a pre-1978 structure
• Scope: Covers the business process of screening for the EPA RRP trigger and routing the job to lead-safe handling. This SOP does NOT teach lead-safe work practices or certification — all of that defers entirely to the EPA Renovation, Repair and Painting (RRP) rule, EPA-approved training, and your business safety plan. When the rule applies, follow it; this SOP only ensures you catch it.

What you need

• Job intake form with build-year field
• EPA RRP "Renovate Right" pamphlet
• EPA-recognized lead test kit (where used)
• Firm/renovator certification records
• Documentation/photo log

The procedure, step by step

1. Determine the build year — At intake, record whether the home or child-occupied facility was built before 1978. This single question routes the entire job.
2. Apply the RRP trigger — If the structure predates 1978 and the work will disturb painted surfaces above the minor-repair threshold (more than 6 sq ft of interior paint per room, or 20 sq ft exterior), the EPA RRP rule applies. Treat it as triggered until proven otherwise.
3. Stop and route to lead-safe handling — When triggered, do not begin work under the normal production SOPs. The job must be handled by a certified firm with a certified renovator and lead-safe work practices per the EPA RRP rule — this SOP defers entirely to that rule and EPA training for how.
4. Verify certification and notification — Confirm the firm certification and assigned certified renovator are current, and that the required EPA lead-hazard information ("Renovate Right") was provided to the owner/occupants as the rule requires.
5. Confirm testing or assume lead — Either test painted surfaces using an EPA-recognized method, or assume lead-based paint is present and proceed lead-safe. The choice and procedure defer to the RRP rule.
6. Document the determination — Record the build year, the RRP applicability decision, certification on file, and the information delivered. This protects the business and is required recordkeeping under the rule.
7. Brief the crew on constraints — If the job is lead-safe, the crew must follow the RRP-required containment, work practices, and cleanup — not the standard dust-control setup alone. Defer the specifics to the safety plan and EPA training.
8. Proceed only when compliant — Resume normal production only once the lead-safe requirements are satisfied or the job is confirmed exempt (post-1978, or under the minor-repair threshold).

Quality check before you finish

• Build-year (pre- vs post-1978) is recorded on every job intake.
• The RRP applicability decision (triggered / exempt) is documented with the reason.
• For triggered jobs, current firm certification and an assigned certified renovator are confirmed on file.
• Required lead-hazard information was delivered to the owner/occupants per the rule.
• Painted surfaces are tested or assumed lead-based per the RRP rule.
• Crew briefing reflects lead-safe constraints, not standard dust control alone.
• All lead-safe handling defers to the EPA RRP rule, EPA training, and the safety plan — this SOP only screens and routes.

This is a free, source-anchored standard operating procedure (SOP) you can print and hand to staff. It documents the work sequence for a Drywall business — not safety or regulatory rulings, which defer to the cited authorities, the applicable code, and your own health-and-safety plan. Open the tool above to print it, toggle ink-saver, or (with a free ToolFluency Business account) edit it to match your own workflow.

Sources

• EPA — Lead Renovation, Repair and Painting (RRP) Program (https://epa.gov)
• EPA — Renovate Right lead-hazard information (https://epa.gov)
• OSHA — Lead in Construction 29 CFR 1926.62 (https://osha.gov)