Pre-1978 Window Removal, Lead-Safe Standard

Purpose

Pulling a painted window out of a pre-1978 house is one of the highest dust-generating acts in residential construction. The sash runs in a painted track, the stops are painted to the jamb, and on a weighted double-hung the counterweight pocket has been collecting chips since the house was built. Prying that apart dry puts decades of accumulated chips and fine paint dust onto the floor of a room a child sleeps in.

This procedure exists so the same house is left clean whichever crew ran it, and so the shop can prove it. Two duties run in parallel and neither substitutes for the other: the EPA Renovation, Repair and Painting rule at 40 CFR 745 Subpart E, which protects the occupant and requires the firm and the on-site renovator to be certified, and OSHA 29 CFR 1926.62, which protects your employee and attaches at the first disturbance regardless of what the occupant rule says. A shop that runs perfect containment and puts a trainee in the counterweight pocket in a t-shirt has satisfied one and failed the other.

Scope

Covers removal of existing windows and disturbance of painted surfaces around the opening in target housing and child-occupied facilities built before 1978, interior and exterior, insert and full-frame.

Does not cover: abatement, which is a different certification and a different rule and is never what a replacement crew is doing; the new unit's flashing, which the water-management procedure owns; and post-1977 housing, where these controls are good practice and not a legal duty. Window replacement is specifically outside the minor repair and maintenance exemption, so there is no square-footage threshold to argue about here.

Roles and responsibilities

The handoff that fails is the third row. A renovator whose training lapsed between the bid and the install date is an uncertified job, and nobody on site will notice.

Procedure

1. Establish whether lead is present before anything is disturbed, and default to present. Confirm the build year from the property record, then either have the certified renovator use an EPA-recognized test kit on each painted component to be disturbed and document the result, or presume lead-based paint and skip testing. Acceptance: a written determination per component, dated, in the job file. Wrong looks like an assumption carried from the house next door. Stop rule: no determination, no disturbance; the presumption path is always available and takes minutes, so there is no reason to start without one.

2. Confirm firm and renovator certification are current, and post the signs. Check the firm certification and the on-site renovator's certification expiry, then post warning signs at the entries to the work area and define its boundary before any tool comes out. Acceptance: both certifications unexpired on the day of work, signs posted and readable from the occupant's approach. Wrong looks like signs going up after the first stop is pried. Stop rule: an expired certification stops the job at the curb, because work performed without it cannot be made compliant retroactively.

3. Build interior containment for the room, floor first. Cover the floor with plastic sheeting extending out from the opening far enough to catch falling debris, close and cover the HVAC supply and return in that room, remove or fully cover furnishings, and close the door to the rest of the house. Acceptance: an unbroken plastic surface under and around the work zone with no gap at the baseline, and the room's air path to the rest of the house closed. Wrong looks like a drop cloth that shifts underfoot, which is a cloth, not containment. Stop rule: if the room cannot be isolated because of an open floor plan or a return that will not close, escalate to the project lead before starting rather than improvising a barrier.

4. Build exterior ground containment and measure the distance to the property line. Cover the ground with plastic extending out from the perimeter of the surfaces being disturbed, weighted at the edges, and measure the distance from the work surface to the property line. Acceptance: ground covering extending 10 ft from the perimeter, or vertical containment erected where the property line does not allow that distance. Wrong looks like a tarp thrown under the ladder. Stop rule: no vertical containment on hand and a close property line means the exterior work does not start that day, because paint chips crossing a boundary onto a neighbor's soil are not recoverable with a broom. Watch for wind: containment that lifts is containment that has failed, so stop and re-weight rather than working faster.

5. Remove the sash and stops wet, and never with a prohibited method. Mist painted surfaces before scoring and prying, score the paint film at the stop-to-jamb line with a knife before the stop moves, and pry with hand tools. Acceptance: visible surface wetness at the point of disturbance throughout, and stops removed intact rather than shattered. Prohibited outright under 40 CFR 745.85(a)(3): open-flame burning or torching a painted surface, any heat gun operated at or above 1100 degrees F, and machine sanding, grinding, power planing, needle gunning or abrasive blasting without HEPA exhaust control. Stop rule: if a stop will not come without a power tool, stop and get the renovator, because reaching for a grinder here is the most common way a compliant job becomes a non-compliant one. Cut-resistant gloves and eye protection for the knife and the pry, and no eating, drinking or smoking inside the work area, which is where an ingestion route opens.

6. Open the counterweight pocket wet and mist it before reaching in. On a weighted double-hung, open the pocket cover, mist the pocket interior before any hand or vacuum enters, then remove weights and chips into a lined container with a HEPA vacuum working alongside. Acceptance: pocket interior visibly damp before entry, and no dry chip fall onto the floor plastic. Wrong looks like a dry pocket dumping decades of chips down the wall cavity. Stop rule: a pocket that opens into an accessible wall cavity rather than a closed box goes to the project lead, because that is a path into the rest of the house containment does not cover. Lead-containing dust is an inhalation route, so the respirator required by the interim protection provisions of 29 CFR 1926.62(d)(2) goes on before the pocket opens, not after the dust is visible.

7. Wrap and remove the waste before cleanup starts. Wrap the removed sash and stops in plastic at the opening, seal the wrap, and move waste through a route that does not cross uncontained living space. Acceptance: every removed painted component sealed before it leaves the work area, and no debris on the transit route. Wrong looks like a painted sash carried loose down a hallway, spreading dust into rooms the cleaning verification will never touch. Stop rule: if the only route out crosses uncontained space, lay a covered walkway first. Two people on any sash the crew cannot control one-handed; the glass in an old sash is annealed and breaks along a cutting edge.

8. Clean, then verify with the cloth against the card, and act on a fail. HEPA-vacuum, wet wash, HEPA-vacuum again, then have the certified renovator wipe the interior windowsill and the work-area floor with a wet disposable cloth and compare each cloth against the EPA cleaning verification card. Acceptance: each cloth is the same shade as the card or lighter. Wrong looks like a cloth darker than the card, and the stop rule is written into the rule itself: re-clean that surface, wipe with a fresh cloth, and if the second cloth is still darker take the wait-and-final-wipe path at 40 CFR 745.85(b) rather than declaring the surface clean. Exterior work is verified by visual inspection for dust, debris and residue instead of the card.

The record this produces

The pre-renovation record and the post-work verification record, both filed to the job and retained by the firm for three years per 40 CFR 745.86.

Fields: the build-year source, the per-component lead determination and its method, the pamphlet acknowledgment from the occupant, firm and renovator certification numbers with expiry dates, the on-site renovator's name, the containment description including the measured property-line distance and whether vertical containment was used, the removal method per component, the cleaning verification result per surface with the number of cloths taken, and photographs of containment in place.

Who reads them later: an EPA or state inspector reads the certification numbers and the verification result, and a missing verification result is the finding, not the dust. The office reads the expiry dates when scheduling the next pre-1978 job. The project lead reads the containment description when a neighbor calls about chips in a garden bed, because a recorded property-line distance and a photograph of vertical containment answers that call in a minute and a memory does not.

Worked pass: three front-elevation openings, 1954 bungalow

Build year confirmed from the county property record. No test kit used; all three openings presumed lead-based paint, documented per component. Firm and renovator certifications checked in the office at scheduling, expiry dates recorded, both current.

Interior containment built room by room. The living room return was closed and covered; floor plastic ran from the wall out past the working position with the edges taped down.

Step 4 produced the first real decision. Ground covering ran out to 10 ft at the two street-facing openings. At the gable-end opening the neighbor's fence sits closer, and the measured distance from the work surface to the property line was 7 ft. Under the step 4 acceptance that is not a shortfall to accept, it is the trigger for vertical containment, which the crew erected along the fence line before the sash came out. The alternative reading, that 7 ft is most of the way to 10 ft, is exactly what the acceptance condition exists to shut down.

Step 6 ran on all three, which are weighted double-hungs. Pockets misted, respirators on before opening, weights and chips into lined containers alongside a HEPA vacuum.

Step 8 failed on the first attempt at the gable-end opening. The floor cloth matched the card and the sill cloth came off visibly darker. The stop rule applied without discussion: that sill was re-cleaned and wiped with a fresh cloth, and the second cloth was lighter than the card. Three cloths were taken at that opening, one failing and two passing, and all three counts went in the record. The two street-facing openings passed on the first cloth at both sill and floor. Exterior surfaces at all three were verified visually, with no card, per the rule.

Read that failure the right way. The sill sits directly under the disturbance and catches what the prying releases, so a first-wipe fail there is an ordinary outcome of an honest verification, not evidence of a bad crew. A bad crew is a renovator who sees a darker cloth, decides it is shadow, and writes a pass.

References

• 40 CFR 745 Subpart E, the EPA Renovation, Repair and Painting rule: work practices at 745.85, recordkeeping at 745.86, certification at 745.89 and 745.90. Some states run an EPA-authorized program with equivalent or stricter requirements, and there the state rule is what binds you.
• 29 CFR 1926.62, OSHA Lead in Construction, including the presumed-exposure and interim-protection provisions at (d)(2) that attach to manual demolition of painted surfaces.
• EPA cleaning verification card and the "Renovate Right" pamphlet, current editions, as the required job-site instruments.
• See related: the occupied-house phasing SOP for scheduling containment around a family, and the opening preparation and rot assessment procedure for what happens after the old unit is out.