Lead paint was banned in 1978, but it didn't disappear — it's still under the newer coats in many older homes across Hudson, Marlborough, Worcester and the surrounding MetroWest market. Here's what federal law requires and what Hudson-area homeowners need to verify before any paint job starts.
What is the EPA RRP rule?
The federal Renovation, Repair and Painting (RRP) rule (40 CFR Part 745) requires any contractor doing work that disturbs more than 6 sqft interior or 20 sqft exterior of painted surfaces in a pre-1978 home to be EPA Lead-Safe certified. This applies to painting, drywall repair, window replacement, siding work, demolition, and renovation.
Violations carry civil penalties up to $40,000+ per day. The rule applies to contractors, but the homeowner is the one who lives in the dust if it's not done right.
Why this matters in Hudson and MetroWest
Per the US Census, 60% of homes in Hudson and Marlborough and 77% in Worcester were built before 1980, and older towns across MetroWest are similar. In a house built before 1978, assume the original layers of paint may contain lead until a test says otherwise.
Lead dust is the primary health hazard, not intact paint. The dust gets created when paint is sanded, scraped, or chipped — exactly what happens during prep for a new paint job. A 50-microgram speck of lead dust on a windowsill exceeds the federal hazard threshold.
What an EPA Lead-Safe job actually looks like
If your home is pre-1978, the contractor must:
- Verify EPA Firm Certification — the company itself must be certified, not just the workers. Verify at the EPA Firm Locator.
- Use a Certified Renovator on site at all times during disturbance.
- Hand you the EPA pamphlet "Renovate Right" before starting.
- Contain the work area — plastic sheeting on floors, walls, doorways. Interior work requires 6-foot perimeter; exterior requires 10-foot ground containment.
- Use HEPA tools — HEPA vacuum, HEPA-filtered sanders, no dry scraping with open-air sanders.
- Prohibit certain practices — no open-flame burning, no high-temp heat guns above 1100°F, no power sanding without HEPA, no power-washing with high-pressure on exterior lead paint.
- Daily cleanup — HEPA vacuum the work area and 2 feet around it before crew leaves each day.
- Final cleaning verification — wet-wash all hard surfaces with a wet cloth, then a clean cloth, then verify cleanliness with a white cloth wipe.
- Provide records — keep training records and project documentation for 3 years.
How to verify a Hudson-area contractor is EPA certified
- Ask for the EPA Firm Certification number. It's a 7-digit number like NAT-12345-1.
- Go to the EPA Firm Locator and search by firm name or state.
- Confirm the listing shows "Active" certification status and the firm address matches.
- Ask which Certified Renovator will be on your job. That person's name should be on the contract.
If the contractor can't produce the EPA number or hesitates, walk away. The certification costs them ~$300 and 8 hours of training — there's no excuse not to have it if they work pre-1978 homes.

