The rule that covers most houses here
Window replacement is never exempt from the federal lead rule, at any size. In a metro where 58.8% of homes predate 1980, that is most jobs.
This is the rule most homeowners in St. Louis have never heard of and almost every window or siding job in this metro is subject to. It is federal, it is not optional, and both of our trades sit right in the middle of it.
The short version
58.8% of the homes in this metro were built before 1980. On anything built before 1978, a contractor being paid to disturb painted surfaces has to be an EPA-certified firm, has to have a certified renovator running the job, has to give you an EPA pamphlet before starting, and has to follow specific containment and cleanup practices. Window replacement is never exempt from this at any size. A whole-house re-side clears the threshold on the first wall.
How old the housing here actually is
| County | Housing units | Built before 1980 | Before 1940 |
|---|---|---|---|
| St. Louis City | 173,920 | 85.9% | 58.3% |
| St. Louis County | 445,472 | 69.2% | 9.6% |
| St. Charles County | 164,594 | 25.0% | 2.0% |
| Jefferson County | 93,276 | 48.6% | 3.2% |
| Madison County | 118,942 | 62.2% | 14.7% |
| St. Clair County | 115,348 | 55.3% | 13.4% |
ACS Table B25034, Year Structure Built, 2023 five-year estimates The lead rule turns on 1978 and this table's buckets break at 1980, so these shares slightly overstate the pre-1978 count. 1980 is the closest the table allows.
The spread is the real story. St. Louis City is 85.9% pre-1980 and 58.3% pre-1940. St. Charles County is 25.0% and 2.0%. Two contractors quoting the same job on opposite sides of the Missouri River are working under materially different obligations, and only one of them has to price for it.
What triggers the rule
Work performed for compensation, in housing built before 1978, that disturbs painted surfaces. There is a minor-repair carve-out at 20 square feet of painted surface for exterior work — and two exclusions from that carve-out that matter enormously here:
- Windows. Window replacement is never exempt. EPA states it plainly: window replacement and demolition of painted surfaces are always covered regardless of square footage. One window in a pre-1978 house triggers the whole rule.
- Siding. A whole-house re-side disturbs the entire painted exterior, which is far past 20 square feet, and tearing off painted wood siding is separately excluded from the minor-repair carve-out as demolition of a painted surface.
Testing is not mandatory, but unless documentation proves the paint is lead-free the rule applies. The three ways out are a certified inspector's report, EPA-recognised test kits used by a certified renovator, or paint-chip analysis by a recognised lab, against 1.0 mg/cm2 or 0.5 percent by weight.
What the contractor has to hold
- Firm certification from EPA — $300, valid five years. This includes sole proprietors. A firm cannot lawfully advertise or perform covered renovations without it.
- A certified renovator on the job. An EPA-accredited course. A refresher with hands-on training renews for five years; without hands-on, three, and the next renewal must include hands-on.
- Presence and direction. The certified renovator has to be physically present when the warning signs go up and during containment setup and cleaning, has to regularly direct the other workers, and has to be reachable on site or by phone at all times the work is going on.
Non-certified workers are allowed, but the certified renovator has to train them on site in lead-safe practices.
What you are owed
- The pamphlet. The Renovate Right pamphlet, delivered no more than 60 days before work starts, with either a signed acknowledgment or a certificate of mailing obtained at least seven days ahead.
- Records. Three years after completion, including the lead determination, the signed acknowledgment, proof a certified renovator was assigned, training records, and cleaning verification. A compliance summary goes to the owner within 30 days of finishing.
Who enforces it here
Neither Missouri nor Illinois runs its own authorised RRP programme. Both are administered by EPA directly, so a St. Louis firm applies to EPA Region 7, not to Jefferson City or Springfield, and one certification covers both sides of the river. Region 7's line is 1-800-223-0425.
What it costs to ignore
The statutory maximum is $49,772 per violation per day. That figure is not what happens in practice: EPA's own published settlements in a recent batch ran from about $1,000 to $23,600. But the exposure is real, and it sits with the contractor, not with you.
The question worth asking every bidder
If your house predates 1978 and a contractor's quote does not mention lead-safe work practices, one of two things is true: they are not certified, or they are certified and have not priced the containment and cleanup that certification requires. Neither is good, and the second one usually turns into a change order. Ask for the EPA firm certification number. It is a real number and it is checkable.
The other one: asbestos-cement siding
Asbestos-cement siding, common on St. Louis houses built before about 1980, is a Category II non-friable asbestos-containing material.
It becomes regulated at 160 square feet, 260 linear feet or 35 cubic feet, or whenever the work practices used make it friable. That last clause is the trap: breaking, sawing, sanding or power-washing turns a non-friable material into a regulated one. Missouri exempts a single residential structure of four or fewer dwelling units from the regulated-structure requirements. That is a regulatory exemption, not a safety clearance, and it does not carry over if the house was converted to commercial use or is being demolished alongside others.
Any siding on a house built before 1980 that looks like asbestos-cement shingle should be tested before anyone disturbs it, and current requirements confirmed with Missouri DNR and the city, because the single-family exemption makes the paperwork go away and does not make the material safe.
Siding over intact asbestos-cement, rather than tearing it off, is a recognised approach precisely because removal is what triggers the burden. It has to be a disclosed decision, and it leaves the material for the next owner.
Sources: ecfr.gov · epa.gov · ecfr.gov · ecfr.gov · epa.gov · health.mo.gov · ecfr.gov · dnr.mo.gov · epa.gov · data.census.gov
Common questions
Does the rule apply if I do the work myself?
No. It applies to renovations performed for compensation. A homeowner working on their own house is outside it — which is a legal fact, not a safety one. The dust is the same dust.
My house is from 1975 but was repainted in the nineties. Does that get me out of it?
No. What matters is when the house was built, not when it was last painted, because the old paint is still under the new paint. The only way out is documentation that the paint is lead-free — a certified inspector's report, recognised test kits used by a certified renovator, or lab analysis of paint chips.
Will this make my job more expensive?
Yes, modestly, and it should. Containment, specialised cleanup and verification take real time. A bid that is meaningfully cheaper than the others on a pre-1978 house is often cheaper because it has left this out.
Is asbestos siding dangerous to leave alone?
Intact asbestos-cement shingle sitting on a wall is non-friable and generally left alone. The risk comes from disturbing it. That is exactly why siding over the top of it is a recognised approach — but it has to be a decision you made knowingly, not one made for you.
Tell us about the house
We answer the phone. If we miss you, we call back.