Most talk about EPA’s Renovation, Repair and Painting rule is about the job site: containment, cleanup, paperwork. For a painting company it is also an advertising rule, and that is the part marketing for this trade most often gets wrong.
Who it covers. Paid work that disturbs paint in houses, apartments and child-occupied facilities, such as schools and child care centers, built before 1978. EPA says that includes every firm, “even sole proprietorships”, and it names painters among the special trade contractors it means. Painting preparation is listed as covered work, and no repaint skips the prep.
What it says about ads. Without firm certification, a company may not advertise covered work in those buildings, let alone do it. An ad for exterior repaints aimed at a neighborhood of 1950s houses is an ad for covered work. The exemption is narrow: six square feet or less of paint disturbed per room inside, or 20 square feet or less on the exterior, which no full repaint meets.
What certification gets you. A certified firm may advertise that EPA has certified it under the program and may use EPA’s Lead-Safe Certified Firm logo. The firm application costs $300 in every jurisdiction EPA administers, and each covered job must be performed or directed by a certified renovator, trained in a one-day course.
Why it is worth showing. EPA, citing HUD’s American Healthy Homes Survey II, says 34.6 million homes, 29.4% of all housing units, still contain lead-based paint applied before the 1978 ban. Parents of young children in those houses have every reason to ask about it. The rule is also enforced against the biggest names: in December 2020 EPA announced that Home Depot would pay a $20,750,000 penalty after finding that firms it subcontracted to did not always use lead-safe practices, hand occupants the required pamphlet or keep records. The case turned on subcontracted work, which is worth remembering for any painter who takes jobs from a larger company.
What this means for the marketing: the logo on the site, the profile and every estimate; a page that explains lead-safe prep in plain words for owners of older homes; and ads aimed at pre-1978 neighborhoods only once the certificate is in hand.