Lead-Safe Bathroom Remodeling in Pre-1978 Chicago Homes
If your Chicago home was built before 1978 and a contractor will disturb painted surfaces during your bathroom remodel, federal law (the EPA Renovation, Repair and Painting, or RRP, Rule) requires that contractor’s firm to be EPA lead-safe certified and to follow set work practices. Ask to see the firm’s certification, check it in EPA’s free database, and put the lead-safe practices in the written contract.
Updated October 22, 2026. Sources are EPA, Illinois and City of Chicago pages, linked below. This is general information, not legal or health advice. For health questions about lead, talk with your doctor or the Chicago health department.
Why 1978 matters in Chicago
The federal rule uses 1978 as its cutoff, because older paint can contain lead. Chicago’s housing is old: in the 2019–2023 American Community Survey five-year estimates, about 39 percent of the city’s housing units were built in 1939 or earlier and about three-quarters before 1980, and the median unit dates to 1952 (CMAP Local Housing Profile). The Illinois Department of Public Health says about 75 percent of Illinois homes built before 1978 contain some lead-based paint, and that even deep layers can be disturbed during remodeling.
A bathroom is a common place for this to happen. Demolishing plaster walls, cutting into painted trim, replacing a window or scraping old paint all create dust. Lead dust is the concern, not intact paint that is left alone.
What the EPA RRP Rule requires
EPA says the rule applies to anyone paid to do work that disturbs paint in housing built before 1978. That includes general contractors, painters, plumbers, carpenters and electricians, and it covers sole proprietors. Firms may not advertise or do covered work without EPA firm certification. Certifications are good for five years.
| Question | What EPA says |
|---|---|
| Which homes? | Housing and child-occupied facilities built before 1978. Housing built in 1978 or later is not covered. |
| Which work? | Any activity that disturbs paint, including remodeling, plumbing, electrical work, carpentry and window replacement. Cutting openings in walls and demolishing painted plaster are examples EPA lists. |
| Is there a small-job exception? | Minor repair and maintenance that disturbs 6 square feet or less of paint per room indoors (20 square feet or less outdoors) is excluded. Window replacement and demolition of painted surfaces are always covered, and prohibited practices are never excluded. Work in the same room within 30 days counts as one job. |
| Who must be certified? | The firm, plus a certified renovator assigned to the job. Other workers must be certified renovators or trained by one. |
| What about the homeowner? | The rule puts no requirements on homeowners, so hiring an uncertified firm is not a violation by you. The firm would be in violation. The rule generally does not cover owners doing work in their own home, but it does cover landlords and anyone who renovates to sell for profit. |
A typical bathroom remodel (gutting walls, replacing a tub surround, moving fixtures) easily goes past 6 square feet of painted or plastered surface, so plan on the rule applying to a pre-1978 home unless testing shows otherwise.
What lead-safe work looks like
EPA’s work-practice standard asks certified firms to do three things, and each is something you can look for on site:
- Contain the work area. Warning signs go up, floors and furniture are covered with plastic, doors and vents are sealed, and dust and debris must not leave the work area. Indoors, floor covering extends at least 6 feet beyond the surfaces being worked on, or farther if needed.
- Avoid the worst dust makers. Open-flame burning, power sanding or grinding without a shroud and HEPA vacuum, and heat guns above 1,100°F are prohibited.
- Clean up thoroughly. Daily cleaning, then a final HEPA vacuum and wet wiping or mopping before the plastic comes down. If there is visible dust, paint chips or debris, the area must be cleaned again.
Before work starts, the firm must give the owner EPA’s “Renovate Right” pamphlet. For an owner-occupied home, the firm gets your written acknowledgment or sends the pamphlet by certificate of mailing at least seven days before work. The firm keeps its records for three years.
What to ask and put in writing
- Is your firm EPA lead-safe certified? Show me the certificate, and the assigned renovator’s training certificate.
- Which of your people will be on site, and are they certified or trained by a certified renovator?
- How will you set up and contain the bathroom and the path to it? Where will debris go?
- Will you test or presume lead? (See the testing section below.)
- How will you clean up and verify the cleaning? Who re-cleans if dust remains?
- Are plumbing and electrical subcontractors also certified, since their work disturbs paint too?
EPA’s homeowner brochure suggests that the contract name the lead-safe work practices, define the work area, and state that the contractor will clean, verify the cleaning, and re-clean if needed. It also suggests asking for references from recent pre-1978 jobs. Apply the same checks on any remodeler you find yourself. Our guide on how to choose a bathroom remodeler in Chicago covers the rest of the hiring checklist.
How to check a firm’s certification
- Ask for the certificate. A certified firm can show it, and may use EPA’s Lead-Safe Certified Firm logo.
- Search EPA’s database. EPA’s lead-safe certified firm search is free.
- Not listed? EPA notes a newly certified firm may not appear yet. Call the National Lead Information Center at 1-800-424-LEAD (5323) to confirm.
- Keep it with your license check. This is separate from the City trade licenses described in how to verify a Chicago contractor license.
In Illinois, EPA itself runs the RRP program; the state is not on EPA’s list of states authorized to run their own.
Testing for lead
Testing can sometimes show a job is not covered, but who tests matters.
- Certified inspector or risk assessor. A written determination that the affected components are free of lead-based paint means the rule does not apply, and EPA says such a determination does not expire. EPA recommends a certified inspector or risk assessor to find out whether lead paint is in your home. Illinois licenses these professionals through the Illinois Department of Public Health (IDPH), which lists them on its lead program site.
- Certified renovator with a test kit. A certified renovator may use an EPA-recognized test kit or collect paint chips for a lab, but must test every component the job will affect. Recognition applies only to use by certified renovators.
- Hardware-store kits. EPA notes that the Consumer Product Safety Commission has cautioned that home lead test kits can be unreliable. Do not use one to decide that your contractor can skip lead-safe practices.
- Presume lead. Many firms simply assume lead is present in a pre-1978 home and work lead-safe throughout.
Chicago and Illinois layers
- City notice. Chicago’s Municipal Code requires a notice (Form LRRP) to the City when a renovation is subject to the federal RRP Rule, after the building permit is issued and before work begins. The City’s environmental permitting functions were moved from the Department of Public Health to the Department of Environment in 2026, so use the City’s current permit portal. Your contractor normally files this; ask who will. See the Chicago bathroom permit guide for the building permit itself.
- Lead abatement is different. Removing a lead hazard for good requires an Illinois-licensed lead abatement contractor, and the City’s lead rules require an approved mitigation plan for abatement or mitigation work, including by owners. A routine remodel under the RRP Rule is a separate category from abatement.
- Lead in water. Chicago’s plumbing code required lead service lines until 1986, and the Department of Water Management counts about 412,000 known or suspected lead service lines. Illinois law bars partial replacement when a lead line is disturbed. If your remodel touches the water service, ask your plumber about it.
- Children and testing. The Chicago health department advises talking with your child’s doctor about a blood lead test and with the health department about testing paint and dust if your home predates 1978.
Protect your household during the job
- Keep children, pregnant women and pets out of the work area for the whole job.
- Ask the firm how dust will be kept out of the rest of the house.
- Do not let anyone dry-sweep or use a household vacuum on dust. The rule calls for HEPA vacuums and wet cleaning.
- If you do any painted-surface work yourself, EPA recommends the same steps: contain, minimize dust, and clean with a HEPA vacuum and wet wiping.
Older bathrooms can also hide asbestos in flooring, pipe wrap or adhesive. EPA says you cannot tell by looking and recommends sampling by an accredited professional before a renovation disturbs a suspect material. See bathrooms in Chicago bungalows, greystones and two-flats.
Before you hire anyone
Lead-safe work is a normal part of remodeling an older Chicago bathroom, and it can add setup and cleanup to a scope. Ask each remodeler to list it as its own line in the itemized written scope and price, so you can compare like with like. The remodelers we match you with are independent companies; confirm each firm’s certification yourself using the steps above. For the work itself, see bathroom remodeling.
Frequently asked questions
Does the EPA lead rule apply to my Chicago bathroom remodel?
If the home was built before 1978 and a paid contractor will disturb painted surfaces, usually yes. Work above 6 square feet of paint per room indoors is covered, and window replacement and demolition of painted surfaces are always covered.
What does EPA lead-safe certified mean?
The firm is certified by EPA, a certified renovator is assigned to each job, and workers follow containment, prohibited-practice and cleaning rules. Firm certifications last five years.
How do I check that a contractor is lead-safe certified?
Ask for the certificate and search EPA's free lead-safe certified firm database. If the firm is not listed, call the National Lead Information Center at 1-800-424-5323.
Am I breaking the rule if I hire an uncertified contractor?
EPA says the rule puts no requirements on homeowners, but the uncertified firm would be in violation. Hiring a certified firm protects your household.
Can a hardware-store test kit show my home is lead-free?
Not reliably. EPA recognizes certain kits only for use by certified renovators, and recommends a certified inspector or risk assessor to find out whether your home has lead-based paint.
Does the rule apply if I do the work myself?
Generally not for an owner working on their own home, according to EPA, but it applies to landlords and people who renovate to sell. EPA still recommends containing dust, keeping children out and cleaning with a HEPA vacuum and wet wiping.
Does Chicago add its own requirement?
Chicago's Municipal Code requires a notice to the City for renovations covered by the federal rule, after the building permit is issued and before work begins. The City moved environmental permitting to its Department of Environment in 2026, so confirm the current process.
Sources
- U.S. EPA, Lead Renovation, Repair and Painting Program: epa.gov; Contractors page (covered activities, 6 and 20 square feet, window replacement): epa.gov. Accessed October 22, 2026.
- U.S. EPA, firm certification (five-year term): epa.gov; work practices and three-year records: epa.gov. Accessed October 22, 2026.
- U.S. EPA, frequently asked questions on covered renovations, general RRP information, do-it-yourselfers and pre-renovation education: covered renovations, general information, do-it-yourselfers, pre-renovation education. Accessed October 22, 2026.
- U.S. EPA, “The Lead-Safe Certified Guide to Renovate Right”: epa.gov. Accessed October 22, 2026.
- U.S. EPA, find a lead-safe certified firm: cdxapps.epa.gov; 40 CFR 745.85 work practice standards: ecfr.gov. Accessed October 22, 2026.
- U.S. EPA, EPA lead test kit and paint chip sampling FAQ: epa.gov; EPA lead-based paint FAQ (test kits, Consumer Product Safety Commission caution): nepis.epa.gov. Accessed October 22, 2026.
- U.S. EPA, asbestos and home remodeling: epa.gov. Accessed October 22, 2026.
- Illinois Department of Public Health, Illinois Lead Program: idph.illinois.gov; Lead Poisoning Prevention Act, 410 ILCS 45/11.1: ilga.gov. Accessed October 22, 2026.
- City of Chicago, Lead Poisoning Prevention: chicago.gov; Control and Mitigation of Lead Bearing Substances rules: chicago.gov. Accessed October 22, 2026.
- City of Chicago, Environmental Permitting Overview: chicago.gov; Demolitions, Renovations and Asbestos Abatement FAQ for Contractors (Chicago Municipal Code 11-4-2170(h)): chicago.gov. Accessed October 22, 2026.
- City of Chicago Department of Water Management, lead service line replacement project plan: chicago.gov. Accessed October 22, 2026.
- CMAP, Chicago Local Housing Profile (ACS 2019–2023, table B25034): cmap.illinois.gov. Accessed October 22, 2026.
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