Lead RRP cleaning verification and dust clearance study guide
After a renovation covered by 40 CFR Part 745 Subpart E in target housing or a child-occupied facility, the firm cleans the work area and a certified renovator then performs post-renovation cleaning verification under 745.85(b). This guide sets out what the federal rule text states on the interior visual inspection, the windowsill and floor/countertop checks with wet and dry disposable cleaning cloths and the cleaning verification card, the exterior visual inspection, the optional dust clearance testing that 745.85(c) allows in place of verification, the duties of certified dust sampling technicians, and the Subpart L action levels with their dates (the term "action levels" applies on or after January 13, 2025, and the values change on or after January 12, 2026). Duties differ for interiors and exteriors and fall on the firm or on the certified renovator as each point notes. Your State or Tribe may run its own authorized program, so check its rules too. Every point links to the regulation and quotes its exact words.
Key terms and who performs verification
A cleaning verification card is a card developed and distributed, or otherwise approved, by EPA. It is used to determine whether post-renovation cleaning has been properly completed, by comparing wet and dry disposable cleaning cloths with the card.
“Cleaning verification card means a card developed and distributed, or otherwise approved, by EPA for the purpose of determining, through comparison of wet and dry disposable cleaning cloths with the card, whether post-renovation cleaning has been properly completed.”
A wet disposable cleaning cloth is a commercially available, pre-moistened white disposable cloth designed for cleaning hard surfaces such as uncarpeted floors or counter tops.
“Wet disposable cleaning cloth means a commercially available, pre-moistened white disposable cloth designed to be used for cleaning hard surfaces such as uncarpeted floors or counter tops.”
A dry disposable cleaning cloth is a commercially available dry, electrostatically charged, white disposable cloth designed for cleaning hard surfaces such as uncarpeted floors or counter tops.
“Dry disposable cleaning cloth means a commercially available dry, electrostatically charged, white disposable cloth designed to be used for cleaning hard surfaces such as uncarpeted floors or counter tops.”
The work area is the area the certified renovator establishes to contain the dust and debris generated by a renovation.
“Work area means the area that the certified renovator establishes to contain the dust and debris generated by a renovation.”
A child-occupied facility is a building, or portion of a building, constructed prior to 1978 and visited regularly by the same child under 6 years of age on at least two different days within any week (Sunday through Saturday), where each day's visit lasts at least 3 hours, the combined weekly visits last at least 6 hours and the combined annual visits last at least 60 hours.
“Child-occupied facility means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.”
Certified renovators are responsible for ensuring compliance with 745.85 at all renovations they are assigned to.
“Certified renovators are responsible for ensuring compliance with § 745.85 at all renovations to which they are assigned.”
40 CFR 745.90, Renovator certification and dust sampling technician certification
A certified renovator must perform all of the tasks in 745.85(b) (cleaning verification), and must either perform all of the tasks in 745.85(a) or direct workers who perform them.
“Must perform all of the tasks described in § 745.85(b) and must either perform or direct workers who perform all of the tasks described in § 745.85(a).”
40 CFR 745.90, Renovator certification and dust sampling technician certification
Not covered here
The work practices in 745.85(a) (signs, containment, prohibited practices, waste and cleaning) are a separate study guide; only the parts that cleaning verification points back to are quoted here. The definitions in 745.83 do not include a definition of "dust sampling technician"; the duties of a certified dust sampling technician are in 745.90. We only write what an official source states, so study these parts with your certifying program's materials.
Visual inspections, re-cleaning and signs
Interiors: a certified renovator must perform a visual inspection to see whether dust, debris or residue is still present. If it is, it must be removed by re-cleaning and another visual inspection must be performed.
“A certified renovator must perform a visual inspection to determine whether dust, debris or residue is still present. If dust, debris or residue is present, these conditions must be removed by re-cleaning and another visual inspection must be performed.”
The cloth checks in 745.85(b)(1)(ii) are performed by a certified renovator after a successful visual inspection.
“After a successful visual inspection, a certified renovator must:”
Interiors: when the work area passes the post-renovation cleaning verification, the warning signs are removed.
“When the work area passes the post-renovation cleaning verification, remove the warning signs.”
Firms must post signs defining the work area and warning others to stay out. To the extent practicable the signs must be in the occupants' primary language. They must be posted before the renovation begins and stay in place and readable until both the renovation and the post-renovation cleaning verification have been completed.
“Firms must post signs clearly defining the work area and warning occupants and other persons not involved in renovation activities to remain outside of the work area. To the extent practicable, these signs must be in the primary language of the occupants. These signs must be posted before beginning the renovation and must remain in place and readable until the renovation and the post-renovation cleaning verification have been completed.”
Before verification, after the renovation has been completed the firm must clean the work area until no dust, debris or residue remains (745.85(a)(5)).
“After the renovation has been completed, the firm must clean the work area until no dust, debris or residue remains.”
Re-cleaning step 745.85(a)(5)(ii)(B), which the verification procedure refers to: thoroughly vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum, equipped with a beater bar when vacuuming carpets and rugs.
“Remaining surfaces. Thoroughly vacuum all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum. The HEPA vacuum must be equipped with a beater bar when vacuuming carpets and rugs.”
Re-cleaning step 745.85(a)(5)(ii)(C): wipe all remaining surfaces and objects in the work area, except carpeted or upholstered surfaces, with a damp cloth, and mop uncarpeted floors thoroughly with a method that keeps wash water separate from rinse water (such as the 2-bucket method) or with a wet mopping system.
“Wipe all remaining surfaces and objects in the work area, except for carpeted or upholstered surfaces, with a damp cloth. Mop uncarpeted floors thoroughly, using a mopping method that keeps the wash water separate from the rinse water, such as the 2-bucket mopping method, or using a wet mopping system.”
Exteriors: a certified renovator must perform a visual inspection for dust, debris or residue on surfaces in and below the work area, including windowsills and the ground.
“Exteriors. A certified renovator must perform a visual inspection to determine whether dust, debris or residue is still present on surfaces in and below the work area, including windowsills and the ground.”
Exteriors: if dust, debris or residue is present it must be eliminated and another visual inspection performed. When the area passes the visual inspection, the warning signs are removed.
“If dust, debris or residue is present, these conditions must be eliminated and another visual inspection must be performed. When the area passes the visual inspection, remove the warning signs.”
Activities that do not disturb paint, such as applying paint to walls that have already been prepared, are not regulated by Subpart E if they are conducted after post-renovation cleaning verification has been performed.
“Activities that do not disturb paint, such as applying paint to walls that have already been prepared, are not regulated by this subpart if they are conducted after post-renovation cleaning verification has been performed.”
Not covered here
The exterior rule sets a visual inspection only; it does not describe a cloth-and-card procedure for exteriors. We only write what an official source states, so study these parts with your certifying program's materials.
Windowsill verification
Interiors: after a successful visual inspection, the certified renovator must verify that each windowsill in the work area has been adequately cleaned, using the procedure in 745.85(b)(1)(ii)(A).
“Verify that each windowsill in the work area has been adequately cleaned, using the following procedure.”
Step 1: wipe the windowsill with a wet disposable cleaning cloth that is damp to the touch. If the cloth matches or is lighter than the cleaning verification card, the windowsill has been adequately cleaned.
“Wipe the windowsill with a wet disposable cleaning cloth that is damp to the touch. If the cloth matches or is lighter than the cleaning verification card, the windowsill has been adequately cleaned.”
Step 2: if the cloth does not match and is darker than the card, re-clean the windowsill as directed in 745.85(a)(5)(ii)(B) and (C), then either use a new cloth or fold the used cloth so an unused surface is exposed, and wipe again. If the cloth matches or is lighter than the card, that windowsill has been adequately cleaned.
“If the cloth does not match and is darker than the cleaning verification card, re-clean the windowsill as directed in paragraphs (a)(5)(ii)(B) and (a)(5)(ii)(C) of this section, then either use a new cloth or fold the used cloth in such a way that an unused surface is exposed, and wipe the surface again. If the cloth matches or is lighter than the cleaning verification card, that windowsill has been adequately cleaned.”
Step 3: if the cloth still does not match and is darker than the card, wait for 1 hour or until the surface has dried completely, whichever is longer.
“If the cloth does not match and is darker than the cleaning verification card, wait for 1 hour or until the surface has dried completely, whichever is longer.”
Step 4: after waiting for the windowsill to dry, wipe it with a dry disposable cleaning cloth. After this wipe, the windowsill has been adequately cleaned.
“After waiting for the windowsill to dry, wipe the windowsill with a dry disposable cleaning cloth. After this wipe, the windowsill has been adequately cleaned.”
Uncarpeted floors and countertops
Interiors: after a successful visual inspection, the certified renovator must wipe uncarpeted floors and countertops within the work area with a wet disposable cleaning cloth.
“Wipe uncarpeted floors and countertops within the work area with a wet disposable cleaning cloth.”
Floors must be wiped using an application device with a long handle and a head to which the cloth is attached.
“Floors must be wiped using an application device with a long handle and a head to which the cloth is attached.”
The cloth must remain damp at all times while it is being used to wipe the surface for post-renovation cleaning verification.
“The cloth must remain damp at all times while it is being used to wipe the surface for post-renovation cleaning verification.”
If the surface within the work area is greater than 40 square feet, it must be divided into roughly equal sections that are each less than 40 square feet.
“If the surface within the work area is greater than 40 square feet, the surface within the work area must be divided into roughly equal sections that are each less than 40 square feet.”
Each section is wiped separately with a new wet disposable cleaning cloth. If the cloth for each section matches the cleaning verification card, the surface has been adequately cleaned.
“Wipe each such section separately with a new wet disposable cleaning cloth. If the cloth used to wipe each section of the surface within the work area matches the cleaning verification card, the surface has been adequately cleaned.”
If a section's cloth does not match the card, re-clean that section as directed in 745.85(a)(5)(ii)(B) and (C), then use a new wet disposable cleaning cloth to wipe it again. If the cloth matches, that section has been adequately cleaned.
“If the cloth used to wipe a particular surface section does not match the cleaning verification card, re-clean that section of the surface as directed in paragraphs (a)(5)(ii)(B) and (a)(5)(ii)(C) of this section, then use a new wet disposable cleaning cloth to wipe that section again. If the cloth matches the cleaning verification card, that section of the surface has been adequately cleaned.”
If a section's cloth still does not match after re-cleaning, wait for 1 hour or until the entire surface within the work area has dried completely, whichever is longer.
“If the cloth used to wipe a particular surface section does not match the cleaning verification card after the surface has been re-cleaned, wait for 1 hour or until the entire surface within the work area has dried completely, whichever is longer.”
After the entire surface has dried, wipe each section that has not yet achieved post-renovation cleaning verification with a dry disposable cleaning cloth. After this wipe, that section has been adequately cleaned.
“After waiting for the entire surface within the work area to dry, wipe each section of the surface that has not yet achieved post-renovation cleaning verification with a dry disposable cleaning cloth. After this wipe, that section of the surface has been adequately cleaned.”
Not covered here
The rule's wording differs by surface: for windowsills the cloth passes if it "matches or is lighter than" the card; for floor and countertop sections the text says the cloth "matches" the card. We only write what an official source states, so study these parts with your certifying program's materials.
Optional dust clearance testing
Cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation, or another Federal, State, Territorial, Tribal, or local law or regulation, requires the items listed in 745.85(c). The first is that the renovation firm perform dust clearance sampling at the conclusion of a renovation covered by Subpart E.
“Cleaning verification need not be performed if the contract between the renovation firm and the person contracting for the renovation or another Federal, State, Territorial, Tribal, or local law or regulation requires: (1) The renovation firm to perform dust clearance sampling at the conclusion of a renovation covered by this subpart.”
The second listed item: the dust clearance samples are required to be collected by a certified inspector, risk assessor or dust sampling technician.
“The dust clearance samples are required to be collected by a certified inspector, risk assessor or dust sampling technician.”
The third listed item: the renovation firm is required to re-clean the work area until the dust sample results are below the dust-lead action levels in 745.227(e)(8) or any applicable State, Territorial, Tribal, or local standard.
“The renovation firm is required to re-clean the work area until the dust sample results are below the dust-lead action levels in § 745.227(e)(8) or any applicable State, Territorial, Tribal, or local standard.”
If dust clearance sampling is performed in lieu of cleaning verification as 745.85(c) permits, the renovation firm must provide a copy of the dust sampling report to the owner of the building and, if different, an adult occupant of the residential dwelling (or an adult representative of the child-occupied facility). It is due when the final invoice is delivered or within 30 days of completion of the renovation, whichever is earlier.
“If dust clearance sampling is performed in lieu of cleaning verification as permitted by § 745.85(c), the renovation firm must provide, when the final invoice for the renovation is delivered or within 30 days of the completion of the renovation, whichever is earlier, a copy of the dust sampling report to: (1) The owner of the building; and, if different, (2) An adult occupant of the residential dwelling, if the renovation took place within a residential dwelling, or an adult representative of the child-occupied facility, if the renovation took place within a child-occupied facility.”
For renovations in common areas of multi-unit target housing, firms must post the dust sampling reports, or information on how interested occupants can obtain a copy, where they are likely to be seen by the occupants of all of the affected units.
“When performing renovations in common areas of multi-unit target housing, renovation firms must post these dust sampling reports or information on how interested occupants of the housing being renovated can obtain a copy of the report. This information must be posted in areas where they are likely to be seen by the occupants of all of the affected units.”
Dust sampling technicians
To become a certified renovator or certified dust sampling technician, an individual must successfully complete the appropriate course accredited by EPA under 745.225 or by a State or Tribal program authorized under subpart Q. The course completion certificate serves as proof of certification.
“To become a certified renovator or certified dust sampling technician, an individual must successfully complete the appropriate course accredited by EPA under § 745.225 or by a State or Tribal program that is authorized under subpart Q of this part. The course completion certificate serves as proof of certification.”
40 CFR 745.90, Renovator certification and dust sampling technician certification
EPA dust sampling technician certification allows the individual to perform dust clearance sampling under 745.85(c) in any State or Indian Tribal area that does not have a renovation program authorized under subpart Q.
“EPA dust sampling technician certification allows the certified individual to perform dust clearance sampling under § 745.85(c) in any State or Indian Tribal area that does not have a renovation program that is authorized under subpart Q of this part.”
40 CFR 745.90, Renovator certification and dust sampling technician certification
Individuals currently certified as lead-based paint inspectors or risk assessors may act as certified dust sampling technicians without further training.
“Individuals who are currently certified as lead-based paint inspectors or risk assessors may act as certified dust sampling technicians without further training.”
40 CFR 745.90, Renovator certification and dust sampling technician certification
When performing optional dust clearance sampling under 745.85(c), a certified dust sampling technician must collect dust samples in accordance with 745.227(e)(8), send them to a laboratory recognized by EPA under TSCA section 405(b), and compare the results to the action levels in accordance with 745.227(e)(8). The technician must also have at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate.
“When performing optional dust clearance sampling under § 745.85(c), a certified dust sampling technician: (1) Must collect dust samples in accordance with § 745.227(e)(8), must send the collected samples to a laboratory recognized by EPA under TSCA section 405(b), and must compare the results to the action levels in accordance with § 745.227(e)(8). (2) Must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate.”
40 CFR 745.90, Renovator certification and dust sampling technician certification
For accredited training programs, the dust sampling technician course must last a minimum of 8 training hours, with a minimum of 2 hours devoted to hands-on training activities.
“The dust sampling technician course must last a minimum of 8 training hours, with a minimum of 2 hours devoted to hands-on training activities.”
40 CFR 745.225, Accreditation of training programs: target housing and child occupied facilities
The listed topics for the dust sampling technician course include the role and responsibility of a dust sampling technician, background on lead and its health effects, regulations and guidance, dust sampling methodologies, and action levels and testing.
“Role and responsibility of a dust sampling technician. (ii) Background information on lead and its adverse health effects. (iii) Background information on Federal, State, and local regulations and guidance that pertains to lead-based paint and renovation activities. (iv) Dust sampling methodologies. (v) Action levels and testing.”
40 CFR 745.225, Accreditation of training programs: target housing and child occupied facilities
Not covered here
Refresher timing for dust sampling technicians (745.90(a)(4)) and training-provider accreditation details in 745.225 are covered in other guides. We only write what an official source states, so study these parts with your certifying program's materials.
Action levels and their dates
Action levels are the values that indicate the amount of lead in dust on a surface following completion of an abatement activity. To complete abatement when dust sampling is required, values below these levels must be achieved. EPA previously called them "clearance levels".
“Action levels are the values that indicate the amount of lead in dust on a surface following completion of an abatement activity. To complete abatement when dust sampling is required, values below these levels must be achieved. EPA previously used the term “clearance levels” to refer to these levels.”
Before January 13, 2025, the levels in 745.227(e)(8)(viii) were referred to as clearance levels. On or after January 13, 2025, they are referred to as action levels.
“Before January 13, 2025, the levels identified in 40 CFR 745.227(e)(8)(viii) were referred to as clearance levels. On or after January 13, 2025, the levels identified in § 745.227(e)(8)(viii) are referred to as action levels.”
Before January 12, 2026, the action levels for lead in dust are 10 µg/ft2 for floors, 100 µg/ft2 for interior window sills and 400 µg/ft2 for window troughs. On or after January 12, 2026, they are 5 µg/ft2 for floors, 40 µg/ft2 for interior window sills and 100 µg/ft2 for window troughs.
“Before January 12, 2026, the action levels for lead in dust are 10 µg/ft2 for floors, 100 µg/ft2 for interior window sills, and 400 µg/ft2 for window troughs. On or after January 12, 2026, the action levels for lead in dust are 5 µg/ft2 for floors, 40 µg/ft2 for interior window sills, and 100 µg/ft2 for window troughs.”
In Subpart L (abatement), the post-abatement procedures in 745.227(e)(8) are performed only by a certified inspector or risk assessor.
“The following post-abatement procedures shall be performed only by a certified inspector or risk assessor:”
Post-abatement dust samples must be taken a minimum of 1 hour after completion of final post-abatement cleanup activities.
“Dust samples for post-abatement testing purposes shall be taken a minimum of 1 hour after completion of final post-abatement cleanup activities.”
Post-abatement: if a single-surface dust sample equals or exceeds the applicable action level, or a composite sample equals or exceeds the applicable action level divided by half the number of subsamples, the components represented by the failed sample must be recleaned and retested.
“If the residual lead level in a single surface dust sample equals or exceeds the applicable action level or if the residual lead level in a composite dust sample equals or exceeds the applicable action level divided by half the number of subsamples in the composite sample, the components represented by the failed sample shall be recleaned and retested.”
Dust-lead hazard (Subpart D): before January 12, 2026, it is surface dust in a residential dwelling or child-occupied facility with lead equal to or exceeding 10 µg/ft2 for floors or 100 µg/ft2 for interior window sills based on wipe samples. On or after January 12, 2026, it is surface dust with any reportable level of lead for floors or interior window sills based on wipe samples analyzed by an NLLAP-recognized laboratory.
“Before January 12, 2026, a dust-lead hazard is surface dust in a residential dwelling or child-occupied facility that contains a mass-per-area concentration of lead equal to or exceeding 10 µg/ft2 for floors or 100 µg/ft2 for interior window sills based on wipe samples. On or after January 12, 2026, a dust-lead hazard is surface dust in a residential dwelling or child-occupied facility that contains a mass-per-area concentration of any reportable level of lead for floors or for interior window sills based on wipe samples analyzed by an NLLAP-recognized laboratory.”
Reportable level means the lowest analyte concentration (or amount) without a "less than" qualifier that is reported with confidence for a specific method by a laboratory recognized by EPA under TSCA section 405(b).
“Reportable level means the lowest analyte concentration (or amount) that does not contain a “less than” qualifier and that is reported with confidence for a specific method by a laboratory recognized by EPA under TSCA section 405(b).”
Not covered here
The action levels and sampling steps in 745.227(e)(8) are written for abatement; Subpart E applies them to renovations only through optional dust clearance testing (745.85(c)) and dust sampling technician duties (745.90(c)). Sampling locations for abatement (745.227(e)(8)(v)) are not set out here. We only write what an official source states, so study these parts with your certifying program's materials.
Records and emergency renovations
Retained records include documentation of compliance with 745.85, including documentation that a certified renovator was assigned, provided on-the-job training, performed or directed the 745.85(a) tasks, and performed the post-renovation cleaning verification in 745.85(b).
“Documentation of compliance with the requirements of § 745.85, including documentation that a certified renovator was assigned to the project, that the certified renovator provided on-the-job training for workers used on the project, that the certified renovator performed or directed workers who performed all of the tasks described in § 745.85(a), and that the certified renovator performed the post-renovation cleaning verification described in § 745.85(b).”
This documentation must include a copy of the certified renovator's training certificate and a certification by the certified renovator assigned to the project.
“This documentation must include a copy of the certified renovator's training certificate, and a certification by the certified renovator assigned to the project that:”
One of the items certified: the certified renovator performed the post-renovation cleaning verification, with the results briefly described, including the number of wet and dry cloths used.
“The certified renovator performed the post-renovation cleaning verification (the results of which must be briefly described, including the number of wet and dry cloths used).”
Emergency renovations other than interim controls are also exempt from the warning sign, containment, waste handling, training, and certification requirements in 745.85, 745.89 and 745.90 to the extent necessary to respond to the emergency.
“Emergency renovations other than interim controls are also exempt from the warning sign, containment, waste handling, training, and certification requirements in §§ 745.85, 745.89, and 745.90 to the extent necessary to respond to the emergency.”
Emergency renovations are not exempt from the cleaning requirements of 745.85(a)(5), which must be performed by certified renovators or individuals trained in accordance with 745.90(b)(2); the cleaning verification requirements of 745.85(b), which must be performed by certified renovators; or the recordkeeping requirements of 745.86(b)(6) and (b)(7).
“Emergency renovations are not exempt from the cleaning requirements of § 745.85(a)(5), which must be performed by certified renovators or individuals trained in accordance with § 745.90(b)(2), the cleaning verification requirements of § 745.85(b), which must be performed by certified renovators, and the recordkeeping requirements of § 745.86(b)(6) and (b)(7).”
Sources
- eCFR: 40 CFR 745.83, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.90, Renovator certification and dust sampling technician certification (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.85, Work practice standards (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.86, Recordkeeping and reporting requirements (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.225, Accreditation of training programs: target housing and child occupied facilities (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.223, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.61, Scope and applicability (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.227, Work practice standards for conducting lead-based paint activities: target housing and child-occupied facilities (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.65, Lead-based paint hazards (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.63, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.82, Applicability (as of Nov 4, 2026)Checked November 6, 2026
Other EPA Lead RRP study guides: Scope and definitions, Firm and renovator certification and training, Pre-renovation information and recordkeeping, Work practice standards, Lead hazard standards and abatement basics