Stronger Federal Standards Enacted in 2025 Became Effective Jan. 13, 2026
By Rachael Rossmeissl-Stone, Senior Project Manager, Partner Engineering & Science, Inc.
The U.S. Environmental Protection Agency has finalized stronger requirements about how lead dust hazards are identified and addressed in homes and child-occupied facilities built before 1978. These changes are part of the agency’s effort to reduce lead exposure, especially for young children who are most at risk from even small amounts of lead. The changes are part of EPA’s lead hazard standards and clearance levels under the Toxic Substances Control Act.
The rule became effective in 2025, and full compliance with key elements is required starting January 12, 2026.
Basics of the New Requirements
Under the updated standards, any detectable level of lead in dust on surfaces like floors and windowsills counts as a lead hazard for the purposes of a risk assessment if it is reported by an accredited laboratory. Known as Dust-Lead Reportable Level (DLRL), this is a significant change from the past when EPA used specific numerical thresholds to determine if lead dust qualified as a hazard.
In addition, after lead cleanup or abatement work, the amount of lead that can remain before EPA considers the work complete has been lowered. For example, the allowable lead dust on floors is now 5 micrograms per square foot, with stricter amounts also set for window sills and window troughs. These post-abatement levels are now referred to as Dust-Lead Action Level (DLAL).
Who and What is Covered
These rules apply to target housing and child-occupied facilities built before 1978. Target housing generally includes residential buildings built before lead-based paint was banned, with some exceptions, and places where young children are regularly present. The standards do not themselves require evaluations or abatement, but they do set the thresholds that define when a hazard exists and when cleanup has been satisfactorily achieved.
For commercial real estate buyers, owners, lenders, and property managers, this means that when you are conducting due diligence, managing leasing and occupancy, or planning renovation or maintenance in older buildings, lead dust assessments must take into account the new, stricter levels. If a risk assessment or clearance test shows any detectable lead dust above the laboratory’s reporting limit, professionals will consider that a lead hazard for disclosure. Once the hazard has been identified, the hazard must be addressed, even if the loan or transaction that triggered the lead assessment falls through.
Practical Implications for Commercial Real Estate
These changes matter in several common CRE scenarios:
- When planning renovations that disturb painted surfaces in pre-1978 residential/child-occupied properties, certified lead professionals are required by EPA’s other lead rules to use lead-safe work practices and to conduct appropriate testing before and after work. The new action levels mean post-work cleanup must be more thorough to meet the updated criteria.
- Lenders should be aware that lead hazard reports based on the new limits could influence appraisals, underwriting, and risk profiles for older properties.
- Managers of childcare facilities or residential spaces need to ensure compliance and protect occupants by evaluating existing lead hazards under the new reporting framework.
Complying with the New Standards
A qualified lead assessment professional can provide accurate testing, interpretation, and documentation of the new EPA standards. These experts understand how the new standards apply in real-world situations and can help owners and managers meet regulatory obligations, protect occupants, and avoid potential liabilities.
Given the complexity of EPA’s lead regulations and how they interact with other rules, such as disclosure and renovation requirements, engaging a trained consultant early in the transaction, renovation planning, or property management process is an investment in clarity and compliance.
If you are taking ownership of, renovating, or managing older buildings where lead paint hazards could be present, reach out to Partner’s team of certified assessors and abatement professionals who can help ensure you understand and meet the new EPA requirements.
