Who regulates lead in Ohio?

Multiple agencies share jurisdiction. The Ohio Department of Health (ODH) licenses lead inspectors, risk assessors, abatement contractors, abatement workers, project designers, and clearance technicians under ORC 3742 and OAC 3701-32. U.S. EPA administers the RRP Rule (40 CFR 745) for renovation, repair, and painting in pre-1978 housing. OSHA regulates worker exposure during lead-disturbing activities under 29 CFR 1926.62 (construction) and 29 CFR 1910.1025 (general industry). Ohio EPA handles lead in soil and groundwater at contaminated sites through the VAP and other cleanup programs.

What is the difference between the RRP Rule and lead abatement?

The RRP Rule (Renovation, Repair, and Painting) applies to renovation work that disturbs lead-based paint in pre-1978 housing and child-occupied facilities. It requires EPA-certified renovators and lead-safe work practices but does not require the paint to be completely removed. Lead abatement is the permanent elimination of lead-based paint hazards through removal, encapsulation, or enclosure, and requires ODH-licensed personnel in Ohio. Different certifications, different rules, different standards.

Does Ohio EPA handle lead-based paint?

No. Lead-based paint licensing and regulation in Ohio is handled by the Ohio Department of Health (ODH), not Ohio EPA. Ohio EPA's role with lead is limited to lead contamination in environmental media (soil, groundwater) at sites being cleaned up under programs like the VAP or DERR Remedial Response. If you need a lead paint inspection license, contact ODH. If you are dealing with lead-contaminated soil at a cleanup site, contact Ohio EPA.

What is lead-based paint?

Under both federal (TSCA Section 401) and Ohio (OAC 3701-32-19) definitions, lead-based paint is paint or other surface coating material containing lead equal to or greater than 1.0 milligrams per square centimeter (mg/cm2) by XRF measurement, or 0.5% by weight (5,000 ppm) by laboratory analysis.

Ohio Lead Program Overview - Paint, Dust, Soil, and Water

Overview

Lead regulation in Ohio involves multiple agencies with distinct responsibilities. Unlike asbestos - where Ohio EPA handles most licensing and enforcement through a single division - lead work is split between the Ohio Department of Health (ODH), U.S. EPA, OSHA, and Ohio EPA depending on the type of activity and the media involved.

This page provides the big-picture framework. For detailed information on specific topics, see the linked pages throughout.

Who Regulates What

Ohio Department of Health (ODH)

ODH’s Lead Poisoning Prevention Program, housed within the Bureau of Environmental Health and Radiation Protection, handles:

Licensing of lead professionals (inspectors, risk assessors, abatement contractors, workers, project designers, clearance technicians) under ORC 3742{target=“_blank”} and OAC 3701-32- Approval of lead training courses
Approval of encapsulant products for abatement
Approval of environmental lead analytical laboratories
Lead hazard control orders in residential units and child care facilities
Childhood lead poisoning prevention and surveillance
Contact: lead@odh.ohio.gov or 614.466.1450

For the full breakdown of ODH license types, training, and fees, see Ohio Lead Licensing and Certification.

U.S. EPA

Renovation, Repair, and Painting (RRP) Rule (40 CFR 745 Subpart E) - requires certified renovators and firm certification for work in pre-1978 housing and child-occupied facilities
Lead-based paint hazard standards and action levels under TSCA Sections 402 and 403
Lead-based paint disclosure rule (40 CFR 745 Subpart F) for real estate transactions
AHERA-style requirements for lead in schools (not currently active in the same way as asbestos AHERA)
Lead in soil screening levels for CERCLA/RCRA sites
Lead and Copper Rule for drinking water (delegated to Ohio EPA Division of Drinking and Ground Waters for public water systems)

OSHA

Worker exposure limits during lead-disturbing construction activities under 29 CFR 1926.62
General industry lead standard (29 CFR 1910.1025)
Exposure monitoring, medical surveillance, respiratory protection, and recordkeeping

Ohio EPA

Lead in soil and groundwater at contaminated sites addressed through the VAP, DERR Remedial Response, or brownfield programs
Lead and Copper Rule implementation for public water systems (Division of Drinking and Ground Waters)
Ohio EPA does NOT license lead paint professionals - that is ODH’s role

Key Regulatory Thresholds

For a complete table of all lead standards and screening levels, see the Lead Standards Quick Reference.

The most important numbers to know:

Lead-based paint definition: 1.0 mg/cm2 by XRF or 0.5% by weight (5,000 ppm) by lab analysis
Pre-1978 trigger: The RRP Rule and most lead paint regulations apply to housing and child-occupied facilities built before 1978
Residential soil screening level: 200 ppm (lowered from 400 ppm in January 2024; 100 ppm for properties with multiple lead sources). Note: the October 2025 directive raised the removal management level to 600 ppm.
Drinking water action level: 10 ug/L (lowered from 15 ug/L under the Lead and Copper Rule Improvements)
OSHA PEL (construction): 50 ug/m3 as an 8-hour TWA; action level 30 ug/m3

RRP Rule vs. Lead Abatement

This is one of the most common sources of confusion. The RRP Rule and lead abatement are separate regulatory frameworks with different requirements:

RRP Rule (40 CFR 745 Subpart E):

Applies to renovation, repair, and painting that disturbs lead-based paint
Requires EPA-certified renovator and EPA-certified firm
Lead-safe work practices (containment, wet methods, HEPA vacuuming, cleaning verification)
Does NOT require complete removal of lead-based paint
Does NOT require ODH licensing in Ohio (separate federal certification)

Lead Abatement (ORC 3742 / OAC 3701-32):

Applies to the permanent elimination of lead-based paint hazards
Requires ODH-licensed personnel (inspector, risk assessor, abatement contractor, workers, project designer)
Includes removal, encapsulation, enclosure, or replacement of lead-based paint components
Requires clearance testing after completion
More comprehensive and expensive than RRP compliance

A renovation project in pre-1978 housing must comply with the RRP Rule. If the project involves permanent elimination of lead hazards (not just renovation with lead-safe practices), it is abatement and requires ODH licensing.

Lead and the VAP

Lead in environmental media (soil, groundwater) at contaminated sites is handled through Ohio EPA’s cleanup programs, not through ODH’s lead paint program. The VAP uses risk-based standards from CIDARS{target=“_blank”} for lead in soil and groundwater. These values may differ from EPA’s residential soil screening levels because they are derived through different risk assessment methodologies and target risk levels.

For CERCLA/Superfund sites and RCRA corrective action facilities, EPA’s October 2025 Residential Soil Lead Directive establishes the current screening framework for lead in soil.