If your Duluth or Superior home was built before 1978, anyone you pay to disturb more than a small patch of paint must work as a lead-safe certified firm: 6 square feet in a room, 20 outside, and any window replacement. Expect plastic containment, warning signs, HEPA cleanup and a wipe test before the room is yours again.
Which lead rule covers your house
The line is the year 1978, and a lot of Twin Ports housing sits well behind it. An estimated 43% of Duluth's housing units were built before 1940, according to the city's 2025 Housing Needs Analysis, and in West Duluth a large share of homes, likely a majority, date from before 1939 (Wikipedia). In houses that old, the paint under today's paint is the part to plan around.
Which agency's rule applies depends on the side of the bridge. In Duluth and the rest of Minnesota, it's the federal Renovation, Repair and Painting (RRP) rule, run by the EPA. The EPA lists the states it has authorized to run their own programs, and Minnesota isn't one of them, while Wisconsin is (EPA). The Minnesota Department of Health has proposed rules that would let the state take the program over, but as of its March 2026 update that was still a proposal (MDH).
In Superior and the rest of Wisconsin, the Department of Health Services runs its own Lead-Safe Renovation Rule under EPA authorization (Wisconsin DHS). The two rules are built the same way, so the practical difference is mostly whose certificate your contractor should hold: an EPA firm certificate for work in Minnesota, a Wisconsin lead company certificate for work in Wisconsin.
Which jobs are covered, and which aren't
The EPA's rule isn't limited to painting. Its contractor page lists remodeling, repair and maintenance, electrical work, plumbing, painting preparation, carpentry and window replacement, and says the rule applies to every paid firm that disturbs paint in pre-1978 housing, sole proprietors included (EPA). The only carve-out for small jobs is minor repair and maintenance: six square feet or less of paint per room inside, or 20 square feet or less outside. Window replacement and demolition of painted surfaces are covered no matter how small.
Wisconsin draws its lines in the same places: 6 square feet of painted or varnished surface in a single room, 20 square feet anywhere outside, and any window replacement (Wisconsin DHS).
| Job | Duluth and Minnesota (EPA rule) | Superior and Wisconsin (DHS rule) |
|---|---|---|
| Patching a nail hole or small crack, well under 6 sq ft of paint in the room | Minor repair; outside the rule | Under the room threshold; outside the rule |
| Scraping and repainting peeling trim and walls in one room | Covered once more than 6 sq ft is disturbed | Covered at 6 sq ft in a room |
| Scraping exterior siding, a porch ceiling or railings | Covered once more than 20 sq ft is disturbed | Covered at 20 sq ft outside |
| Replacing a window, even one | Always covered | Always covered |
| Tearing out a painted wall, cabinet run or trim | Demolition of painted surfaces is always covered | Covered once the room or exterior threshold is passed |
| You working on the house you and your family live in | Generally not covered (unless part is rented, it's a child care, or you're flipping it) | Not covered if only you and immediate family live there and nothing is rented |
Six square feet goes fast. Cutting out a strip of cracked plaster, pulling a door casing, or scraping a single window's peeling sill and apron can pass it. Our plaster repair guide and wallpaper removal guide both run into the same limit.
The rules are for paid work. The EPA says its rule generally doesn't apply when you work on your own home, unless you rent part of it, run a child care there or are fixing it up to flip (EPA). Wisconsin's exemption is narrower in one way that matters in Superior's duplexes: it applies only when you and your immediate family are the only people living there and no part is rented (Wisconsin DHS). The EPA still recommends lead-safe practices for do-it-yourselfers.
What you'll see on the job: containment, cleanup, verification
Lead-safe work looks different from ordinary painting from the first day, and the steps are written into federal regulation (40 CFR 745.85).
Before work. Within 60 days before starting, the firm gives you the EPA's Renovate Right pamphlet and has you sign that you received it (40 CFR 745.84). If a contractor skips this, that tells you something.
Containment. Signs go up marking the work area and telling everyone else to stay out. Inside, floors are covered with taped plastic at least six feet past the work, and windows, doors and heating and cooling ducts in the area are closed and covered. Outside, plastic goes on the ground at least ten feet past the work, and doors and windows within 20 feet are closed. Plan to keep children and pets elsewhere, and to lose the use of that room until cleanup is done.
How paint comes off. The regulation bans open-flame burning or torching of paint, bans power sanders and other high-speed machines unless they have a HEPA vacuum attachment, and limits heat guns to under 1,100°F. Expect misting, hand scraping and shrouded tools rather than a belt sander and a fan in the window.
Cleanup and verification. Debris is bagged, surfaces are HEPA-vacuumed and wiped with damp cloths, and then windowsills and floors are wiped with a wet cleaning cloth and checked against the EPA's cleaning verification card. The signs stay up until that check passes. Wisconsin's rule requires the same cleaning verification (Wisconsin DHS).
None of this is abatement. Abatement means permanently eliminating lead hazards, and it's separate work done by abatement firms; lead-safe renovation is about doing a repair or remodel without spreading dust. We don't offer abatement.
What to ask any contractor before work starts
These questions work for a painter, a window installer or a remodeler:
- May I see your firm's certificate? Ask for the certificate itself. In Minnesota it's an EPA firm certification, valid for five years (EPA), and you can look a firm up with the EPA firm locator. In Wisconsin, both the company and the individual renovator need state certification (Wisconsin DHS).
- Who is the certified renovator on my job, and will they be there? Wisconsin requires eight hours of initial training for renovator certification (Wisconsin DHS).
- How will you contain the work, and which rooms will we lose? A clear answer names the plastic, the doors and ducts that get sealed, and how long.
- How will paint come off? You want to hear wet scraping or shrouded tools, never a torch.
- How will you verify cleanup? The answer should include the cleaning verification card.
- Is the lead-safe work in the written price? Setup, plastic and cleanup take real time, so they belong in the written price rather than showing up later as an extra.
Windows deserve their own note because they're always covered. If you're weighing new windows in an older house, see window replacement; for paint, trim and wallpaper, see painting and wallpaper. In Superior, paint and trim work needs no building permit (our Superior page covers the city's rules), but the lead rule still applies.
Does the lead rule apply if I paint my own house?
Generally no. The EPA's rule covers paid work, so a homeowner scraping and painting the house they live in isn't regulated, unless part of the house is rented, it's used for child care or it's being fixed up to flip. Wisconsin exempts owners only when just they and their immediate family live there and nothing is rented.
Either way, the EPA recommends lead-safe practices: mist before scraping, contain the dust and skip the torch.
How can I check a contractor's lead-safe certification?
Ask for the firm's certificate and check it. For Minnesota jobs, EPA firm certifications last five years, and the EPA's online firm locator lists certified firms by area. For Wisconsin jobs, the Department of Health Services certifies both the company and the individual renovator, so ask for both.
A certificate should name the firm and show an expiration date later than your project's finish.
Is lead-safe renovation the same as lead abatement?
No. Lead-safe renovation is a repair, remodel or paint job done under rules that keep lead dust contained and cleaned up. Abatement is work meant to permanently eliminate lead hazards, done by abatement firms, and it's a different kind of project.
If a test or a health department has found a lead hazard you need removed, look for abatement; if you're fixing up an older house, look for a certified renovation firm.
Does replacing one window in a pre-1978 house trigger the lead rules?
Yes. Both the EPA and Wisconsin cover window replacement no matter how little paint is disturbed, so even one window in a pre-1978 home means a certified firm, the pamphlet before work, containment and cleaning verification. Budget the extra setup time into the window job.
Planning work on an older house? Call or text (715) 919-7956 with photos of the rooms and the year the house was built, or send your project. We'll tell you up front which parts of the job fall under the lead rule, and you'll get a quote in writing before any work starts.
Next steps. The details of the job are on our painting and wallpaper page, with prices in How Much Does Interior Painting Cost in Duluth, MN? Based in Duluth, serving Superior.
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