In a pre-1978 house, federal law is already involved in your floor
If your home was built before 1978 and someone is paid to sand your floors, the federal renovation rule is already part of the job. It covers paid work that disturbs painted surfaces in pre-1978 housing, and it restricts high speed machines specifically. Across the 635 places in our dataset at /data/, 60.5 percent of 3,899,409 housing units predate 1978. In Philadelphia the figure is 82.8 percent.
The short version
- The rule applies to paid work disturbing painted surfaces in housing built before 1978.
- Floor sanding reaches painted surfaces more often than people expect, because the edger runs to the baseboard and the shoe molding.
- 40 CFR 745.85(a)(3) restricts machines that remove coatings through high speed operation unless they carry containment and HEPA collection at the point of generation.
- The small job exemption is six square feet of painted surface per room, and a floor is never that small.
- 60.5 percent of the housing in our published dataset at /data/ predates 1978, and 45 of Philadelphia's 132 neighborhoods are above 90 percent.
Why a clear finished floor still triggers a rule about paint
Because the job is not only the field of the floor: the edger reaches the baseboard, the shoe molding and the door casing, and in older houses those carry many layers of paint.
A floor finished with polyurethane is not a painted surface, and if nothing painted is disturbed anywhere in the job the rule is not triggered. That is a narrower situation than it sounds, because the perimeter of every room is trim, and trim in this housing stock is painted.
So in practice most sanding jobs in pre-1978 housing here fall inside the rule. Treating that as an exception is how a crew ends up out of compliance without noticing.
The rule also is not about whether lead is actually present. Pre-1978 housing is treated as covered unless lead is ruled out by an approved determination. Age is the trigger, not a test result.
The question is not whether your floor has paint on it. It is whether anything painted gets disturbed anywhere in the job, and the edger decides that.
What the text actually restricts
It prohibits machines that remove coatings through high speed operation on painted surfaces unless the machine has containment and a HEPA vacuum collecting dust where it is generated.
The section is 40 CFR 745.85(a)(3), and it is specific about equipment rather than outcome. It names sanding, grinding, power planing and abrasive blasting, and it allows them only with containment and HEPA collection at the point of generation.
Read plainly, that is a description of how the sanding rig has to be assembled in an older house. It is the reason a properly set up crew arrives with extraction attached rather than a shop vacuum in the hallway.
It also explains why the honest version of dustless is a description and not a promise. The equipment the rule requires is the same equipment that makes a job low dust, and neither the rule nor the equipment claims zero.
How much of this region is covered
Most of it, and in the city almost all of it, which is why we treat the rule as the default condition of the work rather than a special case.
The dataset we published at /data/ covers 635 towns and Philadelphia neighborhoods with the American Community Survey 2023 five year estimates. Across the whole service area, 60.5 percent of 3,899,409 units predate 1978.
Philadelphia itself is 82.8 percent, and 45 of its 132 residential neighborhoods are above 90 percent. In those neighborhoods, a crew that treats the lead rule as an exception is out of compliance on nearly every job it takes.
The share is published per town and per neighborhood, so you can look up your own before anyone quotes you. That is the point of publishing it.
| Area | Share |
|---|---|
| Whole service area, 3,899,409 units | 60.5 percent |
| City of Philadelphia | 82.8 percent |
| Philadelphia neighborhoods above 90 percent | 45 of 132 |
Questions
My house is from 1925. Does that mean there is lead paint?
Not necessarily, but the rule treats pre-1978 housing as covered unless lead is ruled out by an approved determination. Age is the trigger, not a test result.
Does refinishing a clear coated floor count?
It depends on whether anything painted is disturbed, and floor work usually disturbs trim because the edger runs to the baseboard and shoe molding.
Is there a small job exemption?
Six square feet of painted surface per room for interior work. A floor is never that small.
What does the rule require of the machine?
Containment and a HEPA vacuum collecting dust at the point where it is generated, under 40 CFR 745.85(a)(3). It describes equipment, not tidiness.
How do I check my own neighborhood?
Every town and Philadelphia neighborhood we cover has its own page with the share of housing built before 1978, and the whole dataset is downloadable at /data/.
Sources and references
- Deco Hardwood Floor, housing stock of the Philadelphia region (CC BY 4.0). https://decohardwoodfloor.com/data/
- 40 CFR 745.85, EPA lead renovation work practice standards. https://www.law.cornell.edu/cfr/text/40/745.85
- US Census Bureau, ACS 2023 5-Year, tables B25034 and B25035. https://www2.census.gov/programs-surveys/acs/summary_file/2023/
Keep reading
Pillar GuideRefinishing a floor in an old Philadelphia houseWhat decides whether your floor can be sanded, and why the answer here is different from the answer in a newer suburb.
ComparisonPrefinished or site-finishedYou will be told the difference is dust and drying time. The difference that lasts is the bevel and whether the floor can ever be matched.
Decision GuideSolid or engineered, and why the basement decidesThe choice is presented as taste. It is usually settled by what is under the room, before anyone gets to taste.
Send a photo and we will tell you what you are looking at
Sanding & Refinishing starts with someone reading the house. We quote every job ourselves, with no salesperson in between, and a photo of the floor gets you a straight answer faster than a form does.
