Lead-Safe Work Practices (Deferral): the full procedure

Confirm build age and route any pre-1978 work to the controlling lead-safe authorities before disturbing painted surfaces.

• Applies to: Owner, lead painter, all field staff
• Frequency: Every job — screen for pre-1978 surfaces
• Scope: This is a routing and documentation procedure only. It does not instruct how to perform lead-safe work. All lead-safe work practices, certification, containment, and cleanup defer entirely to the EPA RRP rule, the product label and SDS, OSHA, and the written safety plan.

What you need

• Build-year records
• Job file or checklist
• EPA "Renovate Right" pamphlet
• RRP firm and renovator certificates
• Signage
• Safety plan binder

The procedure, step by step

1. Determine the build year — Confirm whether the structure was built before 1978 using records or the customer. Pre-1978 housing and child-occupied facilities are where lead obligations may apply.
2. Check the disturbance threshold — Note whether the work will disturb painted surfaces beyond the rule's thresholds. Whether and how the rule applies is determined by the EPA RRP rule, not this manual.
3. Stop and route to the authority — If pre-1978 and surfaces will be disturbed, stop and apply the EPA RRP rule, the product label and SDS, OSHA, and the safety plan. Do not improvise lead-safe methods from this SOP.
4. Confirm certification is in place — Confirm the firm certification and certified renovator requirements are met before work begins, as required by the EPA. This SOP only verifies they exist — the EPA defines them.
5. Provide required pre-renovation education — Provide the customer the EPA 'Renovate Right' pamphlet and document delivery, as the EPA requires before RRP-covered work. Keep proof in the job file.
6. Defer all work methods to the plan — Carry out containment, dust control, and cleanup strictly per the EPA RRP rule and the written safety plan. This manual does not specify those methods.
7. Keep the required records — Retain the records the EPA requires for the required retention period in the job file. Treat recordkeeping as part of closing the job.
8. Document the screening either way — Whether or not the rule applies, note the build-year screening result in the job file so the decision is traceable.

Quality check before you finish

• Build year determined and recorded
• Disturbance against EPA thresholds noted
• Pre-1978 disturbing work routed to EPA RRP and safety plan
• Firm and renovator certification confirmed before start
• "Renovate Right" pamphlet delivered and documented
• Required records retained in the job file
• Screening result logged regardless of outcome

This is a free, source-anchored standard operating procedure (SOP) you can print and hand to staff. It documents the work sequence for a Painting 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 Program (epa.gov)
• OSHA (osha.gov)
• Painting Contractors Association (pcapainted.org)