Lead Paint - Where It Hides in an Older House

Why this matters

Most lead exposure from an older house does not come from a wall someone is repainting. It comes from the window a tech drilled to mount a sensor, the door stop a carpenter pried off to free a sticking door, the porch rail a handyman sanded before a coat of stain. None of those people thought they were doing lead work, and the RRP rule calls every one of them renovation. Knowing where lead paint sits in a house is what lets you see the job you are actually being asked to do before you start it.

This card owns the map: which surfaces, why those, and what a service visit does to them. The legal rule lives on the EPA RRP card and the general hazard on the Asbestos and Lead Paint Safety card; this one spends one paragraph on the rule and the rest on where to look.

The age line, and what it does and does not tell you

The Consumer Product Safety Commission banned lead paint for residential use in 1978 (16 CFR Part 1303), so the federal presumption is that a house built before 1978 may have it. EPA's published estimates put it in roughly 87 percent of homes built before 1940, 69 percent of homes built 1940 to 1959 and 24 percent of homes built 1960 to 1977, counting lead paint anywhere in the house.

Read those figures as odds about the house, not about the surface in front of you. A 1965 house is less likely than a 1925 house to have lead somewhere, but the 1965 house that does have it usually has it on the same few surfaces this card names, because those were the surfaces painted with the most durable, highest-lead enamels. Two corrections to the age line:

• The paint is older than the house can be younger. A 1985 addition on a 1920 house carries a 1920 window moved in, a salvaged door, original trim reused. The date that matters is the date of the painted component, not the deed.
• Newer paint on top does not remove the risk. Lead paint under three coats of latex is intact until something cuts, abrades or heats through to it. The surface reads as modern and is not.

See related: Dating a House by What You Find in It, for reading the age of the component rather than the listing.

Why lead concentrates where it does

Lead pigment made paint hard, glossy and washable. Painters used the highest-lead enamels exactly where a surface took the most wear or the most weather, so lead is not spread evenly through an old house. It is concentrated on three kinds of surface, and the kind tells you how the hazard reaches people:

• Friction surfaces rub against another surface in normal use: a window sash in its jamb, a door edge against its stop, a drawer side. Every opening grinds a little paint into dust, which is why window troughs (the channel the lower sash sits in) and the sill below them routinely carry the heaviest dust in an old house.
• Impact surfaces get struck: door jambs and stops, baseboards, stair risers, the threshold area. Chipped paint there is lead on the floor.
• Chewable and accessible surfaces a child can mouth or rub: window sills, stair rail edges, porch rails, crib-height trim.

A double-hung window in section shows why it is the worst surface in the house: almost every painted face rubs another one.

 jamb | parting bead | upper sash   <- sash rubs bead
      |              |              
      | stop         | lower sash   <- sash rubs stop
      |              | meeting rail <- two sashes rub
      +--------------+-------------
        trough (sash channel)       <- dust collects
      ===============================
        stool / interior sill       <- chewable
        apron

Exterior paint adds a fourth route. Old exterior paint weathers, chalks and flakes, and decades of it land in the soil at the drip line along the foundation. A crew trenching beside an old wall for a line set or a downspout extension is digging in that soil.

The house map: where to look first

The ranking below is by how often lead turns up there and how often a service visit disturbs it, not by surface area.

Two places people miss. A radiator painted with metallic paint may have a lead coat under it, and heating or wire-brushing it releases fume or dust. And in a house where the walls themselves were painted with lead in the early decades, a wall plaster surface you drill for an anchor is a lead surface too; trim is the likeliest place, not the only one.

Why a tech drilling a window frame is doing renovation work

Here is the one paragraph on the rule, and the details belong to the EPA RRP card. Under 40 CFR Part 745, Subpart E, renovation means modifying an existing structure in a way that disturbs painted surfaces in pre-1978 housing or a child-occupied facility, unless the work fits the minor repair and maintenance exemption: 6 square feet or less of painted surface per room inside, or 20 square feet or less outside, using none of the prohibited practices, and never a window replacement. A drill bit through a painted stop disturbs a painted surface, so it is renovation by definition and then, usually, exempt by size. The size test is cumulative across the job in each room, which is how a small service call crosses it without anyone noticing. States that EPA has authorized to run the program enforce their own version, and some are tighter; read your state's. The exemption only switches off the RRP work practices; OSHA's lead standard for construction work, 29 CFR 1926.62, still governs your employees' exposure whatever the square footage.

What disturbance releases, and the control for each

Lead reaches people by ingestion of dust and by inhalation of dust and fume. The act decides which:

• Drilling and screwing produce coarse dust and chips that fall onto the sill, the floor and the tech's sleeves. The control is a HEPA vacuum shroud or a HEPA vacuum nozzle held at the bit, plastic sheeting under the work, and a wet wipe and HEPA vacuum of the surface after. Dust on clothing goes home, so a disposable sleeve or coverall is part of the control, not a nicety.
• Sanding, planing and grinding with power tools make fine, breathable dust. RRP prohibits machine paint removal by high-speed operation unless the tool has a HEPA exhaust attachment, and the respiratory exposure is controlled under 1926.62, which means a respirator under a written program per 29 CFR 1910.134 where the exposure assessment calls for one. A crew without that program does not do that work.
• Heat is the worst. Open-flame burning and torching are prohibited under RRP, and heat guns at 1100 F or higher are prohibited too, because they fume lead. A tech warming a stuck sash with a heat gun or brazing a pipe against painted trim is generating fume at the face.
• Dry scraping and prying release chips and dust at hand height. Mist the surface first and collect the debris on sheeting.

A worked example: three windows in a 1924 bedroom

A handyman is booked to free three painted-shut sashes in one bedroom of a 1924 house and fit a sash lock to each. The customer then asks, while he is there, for the three sills to be scraped and touched up. A five-year-old lives in the house.

Start with the presumption. The house is 1924, the sashes are original, and nobody has a test result, so every painted surface in the job is presumed lead. The child under six makes the occupant side of the rule real, not academic.

Now the area, counted per room because that is how the exemption counts. Each window is about 30 by 60 inches. Freeing the sash means cutting the paint line where the sash meets the stops, both sides, full height, and the disturbed band is about an inch wide:

• Paint line per window: two sides of 60 inches is 120 inches, or 10 feet, times a 1-inch band (1/12 foot) is about 0.83 square feet.
• Three windows: 3 times 0.83 is about 2.5 square feet.
• The lock screws add a few square inches. Call the sash work 2.5 square feet.

That is inside the 6 square foot interior limit, so the sash work alone can run as exempt minor repair, provided no prohibited practice is used. He frees the sashes with a knife and a putty tool, misted, over sheeting, with a HEPA vacuum at the work, and no heat gun.

Then the sills. Each sill is about 32 inches long and 6 inches deep, and scraping it for a touch-up disturbs the whole top face:

• One sill: 32 by 6 is 192 square inches, which over 144 is about 1.33 square feet.
• Three sills: 3 times 1.33 is 4.0 square feet.
• Room total: 2.5 plus 4.0 is 6.5 square feet.

At 6.5 square feet the room is over the 6 square foot limit, and the exemption is gone for the whole job in that room, not just the sills. The job now needs a certified firm, a certified renovator directing the work, the pre-renovation pamphlet to the occupant, containment, cleaning and cleaning verification. He has two honest options: do the sash work today as quoted and leave the sills to an RRP-certified crew on a separate visit, or rebook the whole room under RRP. What he may not do is scrape one sill today and two next week; splitting a job to stay under the threshold is the failure the per-room count exists to stop.

What would change the answer. A lead inspection report showing those components are not lead-based paint (the federal definition is 1.0 milligram per square centimeter or 0.5 percent by weight) removes the presumption for the tested components, and some states and localities set their own definitions or require more. A 1985 house with original windows sits outside the federal age presumption, though a reused older component brings it back. And if he had reached for a heat gun to free the sashes, the area would not matter: the prohibited practice is the problem at any size.

How to verify you read the house right

• Before quoting, name the painted components the job touches and their likely age. If you cannot say whether a window is original, treat it as original.
• Add the disturbed area per room, including the add-ons the customer asks for once you are on site. The add-on is where the count goes wrong.
• Check your tools against the act: anything with heat, high speed or open flame on a painted surface gets stopped, not adjusted.
• Record what you saw as "presumed lead-based paint, pre-1978 component, not tested", with the location and photo. See related: How to Photograph and Record a Suspect Material.

References

• See related: EPA Lead RRP Rule for Contractors; Asbestos + Lead Paint Safety Reference; Recognize, Record, Route - the Rule for Legacy Materials
• EPA, Lead Renovation, Repair and Painting Program, 40 CFR Part 745, Subpart E (renovation definition, minor repair exemption, prohibited practices)
• CPSC, Ban of Lead-Containing Paint, 16 CFR Part 1303
• OSHA, Lead in Construction, 29 CFR 1926.62; Respiratory Protection, 29 CFR 1910.134