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Lead on a commercial building is an OSHA problem before it is an EPA problem.

A RocketLevel awareness guide, backed by decades of experience in the trade. You already survey for asbestos on older buildings. Lead is the one crews get wrong, because the rule many contractors have heard of is the wrong rule for the building they are standing in. The EPA Renovation, Repair and Painting rule (RRP) at 40 CFR 745 Subpart E reaches target housing and child-occupied facilities only. EPA never finished a companion rule for public and commercial buildings (the history is below), so an office, a store, or a warehouse carries no RRP obligation at all. What does govern that job is OSHA 29 CFR 1926.62, which applies to all construction work and has no building-year cutoff. This is awareness of which rule applies and what each one requires, not an abatement how-to.

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Reviewed October 2026. OSHA and EPA lead rules and penalty amounts change, states can set stricter ones, and none of it can be waived by a private agreement, so use this page to know what to ask, then confirm with your state agency or a construction attorney before you rely on it.

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When RRP applies

• Renovation, repair, or painting that disturbs lead-based paint in two categories of pre-1978 property: target housing (most housing built before 1978) and child-occupied facilities (a building, or part of one, regularly visited by the same child under age six, such as a daycare, preschool, or kindergarten).
• A child-occupied facility can sit inside an otherwise commercial or public building. That pocket of the building is covered and the rest of it is not, so scope the covered footprint on paper before you mobilize. A healthcare site is covered only when it meets the same child-occupied test.
• General commercial space on its own has no RRP obligation. EPA never proposed a public and commercial building rule. It went as far as an advance notice of proposed rulemaking on 6 May 2010, published at 75 FR 24848, and a Small Business Advocacy Review panel, and the proposed-rule stage was never reached, so there is no federal RRP standard waiting to be applied to an office or a warehouse. If someone tells you otherwise, ask them for the citation.
• Disturbing the paint, cutting, sanding, demolition, is the trigger, which is exactly what restoration does.
• Minor repair and maintenance is carved out, narrowly. The definition sits at 40 CFR 745.83. Work disturbing 6 square feet or less of painted surface per room inside, or 20 square feet or less outside, sits outside RRP. The carve-out dies the moment the job includes window replacement, demolition of painted surface areas, or a prohibited practice: open-flame burning or torching, machine sanding, grinding, power planing, needle gunning or blasting without HEPA exhaust control, or a heat gun at or above 1,100°F. Work in the same room within any 30 days aggregates, so you cannot slice one job into small pieces to stay under the number.
• The pamphlet has a clock. On covered work, deliver EPA's lead-hazard pamphlet and obtain written acknowledgment no more than 60 days before work begins. Late delivery is its own violation, independent of anything you did to the paint.
• Emergency work gets partial relief, not a pass. Under 40 CFR 745.82(b), an unplanned renovation forced by a sudden event that threatens safety, health or property, which describes a lot of water and fire mitigation, is excused from the pamphlet step and, only as far as the emergency requires, from signage, containment, waste handling, training and certification. Cleaning, cleaning verification and the job records still apply. Once the emergency is controlled, the rest of the job is ordinary RRP work again.

The rule that does cover your commercial jobs

RRP not applying is not the end of the analysis, and this is where restoration contractors get hurt. RRP is a resident-protection rule. Your workers are protected by a separate standard that has no 1978 date and no housing limit: OSHA 29 CFR 1926.62, which applies to all construction work where an employee may be occupationally exposed to lead. Demolition, material removal, cleanup of lead-contaminated debris and reconstruction are all named construction work under it.

The two numbers to know are in 1926.62 itself. The action level is 30 µg/m³ as an 8-hour time-weighted average (TWA), measured without regard to respirator use, and it is what triggers exposure monitoring and medical surveillance. The permissible exposure limit (PEL) is 50 µg/m³ as an 8-hour TWA. Those are the federal numbers, and in California they are not the numbers. Cal/OSHA rewrote its construction lead standard effective January 1, 2025. 8 CCR 1532.1 sets the action level at 2 µg/m³ and the PEL at 10 µg/m³, and a separate PEL of 25 µg/m³ for abrasive blasting until January 1, 2030, which is an exception to the PEL rather than a third action level.

Medical removal there is measured in blood, not air, so watch which unit you are reading: removal follows a blood lead level at or above 30 µg/dL, and from January 1, 2026 also on either the last two results at or above 20 µg/dL or a six-month average at or above 20 µg/dL. The California action level is fifteen times lower. A California job assessed against 30 is assessed against a line that state does not use. Twenty-two OSHA-approved State Plans cover private employers and any of them can go past the federal floor, so settle your own state's lead numbers before you set a monitoring threshold. The map is in The State Plan Overlay: Where Your State Owes More Than Federal OSHA. For an office building or a warehouse, then: RRP does not apply, 1926.62 does, and you still owe your crew an exposure assessment before they start cutting painted steel or sanding painted plaster.

The part that catches crews is the presumption. Under 1926.62(d)(2) you do not get to wait on lab results before you protect anyone. Named trigger tasks carry a presumed exposure level until your own assessment documents otherwise, and until it does you owe the crew all six interim measures at (d)(2)(v): respirators, protective clothing and equipment, change areas, hand washing facilities, training, and biological monitoring, which means blood sampling analyzed for lead and zinc protoporphyrin, not lead alone.

Each tier carries a number. Manual demolition of painted surfaces, manual scraping and sanding, heat gun work, and power tool cleaning with dust collection are presumed above the PEL but not above 500 µg/m³, and spray application of lead paint sits with them. Rivet busting, lead burning, work with lead-containing mortar, power tool cleaning without dust collection, cleanup where dry expendable abrasives are used, and abrasive blasting enclosure movement and removal are presumed above 500. Abrasive blasting, welding, cutting, and torch burning on coated structures are presumed above 2,500 µg/m³, fifty times the PEL. That last group is ordinary fire and impact restoration on a commercial frame. It is the reason "the building went up in 1994, so lead is not an issue" is a sentence that should stop the job.

Read the power tool line twice, because it is the one that gets reversed. Dust collection on the tool puts the task in the lowest group. No dust collection puts it five times higher. It is the same grinder on the same paint with a very different respirator. And you cannot assess your way around any of this with borrowed numbers: 1926.62(d)(3)(iv)(B) lets objective data substitute for initial monitoring generally, but not for the exposure assessment tied to these (d)(2) tasks. On the tasks that matter most, you monitor.