Painting over sound paint without disturbing it isn’t covered by EPA’s Renovation, Repair and Painting (RRP) rule. Most real paint jobs on older Philadelphia rowhomes include scraping and sanding, though, and that prep is covered.
Who is doing the work
Pennsylvania isn’t one of the states that runs its own RRP program, so a firm working on a Philadelphia, Bucks or Montgomery County home needs EPA firm certification, not just a state credential. That applies to one-person businesses too. Separately, EPA requires a certified renovator assigned to each job. That person has to be on site when warning signs go up, while containment is set up and during cleaning, and reachable by phone the rest of the time. Other workers can be trained on the job by that renovator.
Ask for a copy of the firm certificate and the renovator’s course certificate, and check the expiration date: a renovator’s certification lasts five years after a hands-on refresher, or three after an online one. Before work starts you should also get EPA’s Renovate Right pamphlet and sign for it.
Is it really a “minor” job?
Some painters write small jobs up as exempt. The exemption covers disturbing 6 square feet or less of paint per room inside, or 20 square feet or less on the whole exterior. EPA’s FAQ says that’s 20 square feet total, not per side of the house, and work in the same room within 30 days counts as one job. Window replacement and demolition of painted surfaces never qualify. If the quote claims the exemption, ask for the measurements.
Unless a certified inspector, risk assessor or the certified renovator (using an EPA-recognized test kit or lab paint-chip samples) has shown the surfaces are lead-free, the firm has to treat the paint as lead-based. If testing is offered, the quote should say who tests, which surfaces, and what it costs. Don’t scrape a sample yourself.
Containment and prep, in writing
EPA’s 2026 small-entity guide spells out the minimum steps. For outside work, the crew covers the ground with plastic or similar sheeting at least 10 feet past the surfaces being worked on (unless the property line is closer) and closes doors and windows within 20 feet. Inside, they remove or cover belongings, seal ducts in the work area with taped-down plastic, and cover doorways. On tight rowhome blocks, ask how they’ll handle the neighbor’s side and the sidewalk.
The quote should also rule out the prohibited methods: open-flame burning or torching, heat guns above 1,100°F, and power sanding, grinding or blasting unless the tool has a shroud and a HEPA vacuum attachment. “Machine sand trim” with no mention of HEPA is a red flag.
How cleanup gets checked
Inside, the certified renovator cleans with a HEPA vacuum and wet wiping, then wipes floors, countertops and windowsills with a wet disposable cloth and compares it with EPA’s cleaning verification card, re-cleaning any area that fails. Outside, the renovator does a visual inspection for remaining dust, chips and debris. Ask who does this check and that the price includes re-cleaning.
If you want lab dust testing instead, the contract has to say so. EPA’s work practice FAQ says post-renovation dust-lead testing can replace cleaning verification only when the contract or another law requires it, the samples are taken by a certified inspector, risk assessor or dust sampling technician, and the firm re-cleans until results are below the standard.
Paperwork and cost traps
Firms must keep the job records for three years, including who the certified renovator was, test results and proof you got the pamphlet. Ask for a copy of the completed records when the job ends. Since 2010, homeowners can’t sign away these work practices, so be wary of a lower price that depends on you opting out.
When comparing quotes, line up the same items: testing, containment, prep method, cleanup, cleaning verification and disposal. A cheaper total that leaves out containment or cleanup isn’t cheaper. EPA can seek penalties of up to $49,722 per violation per day, so a firm that won’t put these steps in writing is taking a risk on your house.
If a child in your home has a blood lead level of 3.5 µg/dL or higher, Philadelphia’s Lead and Healthy Homes Program (215-685-2788) offers a free home visit and lead inspection, and may help with removal costs depending on income. Our guide to Philadelphia’s lead rules for repairs covers the City’s rental certificate law, and the contractor hiring checklist covers the rest of the vetting. Planning outside work this fall? Check how long exterior paint needs before rain or cold.