If you’re working in New York City, you can’t ignore the EPA lead-safety rules. Most NYC residential buildings were built before 1978, which means most of them contain lead-based paint. Anytime you disturb painted surfaces during renovation, you risk creating lead dust — and lead dust is a health hazard, especially for children and older adults.

DCWP knows this, which is why they require proof of EPA compliance at the time you apply for your Home Improvement Contractor (HIC) License. Fail to submit the correct certification or affirmation, and your application won’t move forward.

This guide explains when you need EPA certification, which certification applies to which kind of work, and how NYC contractors comply with DCWP’s rules.

Why NYC Contractors Must Pay Attention to Lead

Most NYC housing was built long before lead paint was banned in 1978. If you’re working in pre-1978 apartments, brownstones, co-ops, condos, or multifamily buildings (which is almost all of them), your work is likely to disturb lead paint. Anything that creates dust or chips can trigger EPA requirements:

• Demolition

• Sanding

• Window replacement

• Baseboard removal

• Door casing removal

• Wall repair and patching

• Any renovation that cuts, drills, or scrapes painted surfaces

DCWP reinforces this risk in the city’s Home Improvement Consumer Guide, which states that contractors must comply with health laws and specifically calls out the hazards of scraping or sanding painted surfaces.

If you disturb lead paint and you’re not certified, you’re violating federal law (EPA) and NYC licensing requirements (DCWP).

The Three EPA Compliance Options

DCWP makes this simple: when you apply for your HIC license, you provide ONE of three things. The screenshot you shared matches the official DCWP structure, which aligns with the EPA Affirmation form.

Option A — You Perform Work That Disturbs Lead Paint

Submit BOTH of these:

• EPA Lead Renovation, Repair & Painting (RRP) Certification

• EPA Lead Abatement Certification

This applies if you do any work that disturbs lead-based paint in pre-1978 residential properties — which is practically all standard NYC renovation work.

When RRP is required

You need RRP if you’re renovating, repairing, or painting surfaces that may contain lead, and your work will disturb more than:

• 6 sq. ft. of interior paint per room,

• 20 sq. ft. of exterior paint, or

• Any window replacement or demolition.

When Lead Abatement certification is required

Lead abatement certification is required when you’re performing lead hazard reduction — not general renovation. Abatement is a specialized activity (usually ordered by HPD or DOH) where the goal is to permanently eliminate lead hazards.

Most HICs don’t do formal abatement, but if you advertise or offer it, you must be certified.

Option B — Only One Certification Applies to You

Submit:

• One EPA certification (RRP or Abatement)

• AND the DCWP EPA Affirmation stating the other certification is not required

This applies when:

• You perform renovation work that requires RRP but you never perform full abatement, OR

• You only perform abatement work and never perform standard renovation that disturbs paint.

Most NYC contractors fall into the RRP-only category.

Option C — Neither Certification Applies

Submit:

• A signed DCWP EPA Affirmation stating neither program applies to your business

This is for contractors who do not disturb painted surfaces at all.

Examples:

• Carpet installation (no baseboard removal)

• Cabinet replacement without wall work

• Appliance installation

• Finish carpentry that never cuts into painted surfaces

Be honest here — DCWP expects you to update your status within five business days if your scope changes.

In reality, very few NYC contractors can truthfully select this option because almost all remodeling work involves touching painted surfaces.

How DCWP Enforces This

DCWP requires EPA documentation when you submit your HIC application, and they treat missing EPA paperwork the same way they treat missing insurance or tax documents — your application just sits.

Their consumer guidance reinforces the safety rules and the expectation that contractors follow all health laws, including lead-safety laws.

If DCWP finds that you’re doing work requiring certification but you filed an affirmation saying you’re exempt, you’re in violation of:

• Federal EPA regulations

• NYC Consumer Protection Law

• Your HIC license agreement

Penalties can include fines, license suspension, and revocation.

How to Know Which Option You Should Choose

Use this quick decision tool:

1. Do you ever disturb painted surfaces in pre-1978 buildings? If yes, you need RRP at minimum.

2. Do you ever perform lead abatement (hazard reduction)? If yes, you also need Lead Abatement Certification.

3. Do you perform renovations that NEVER disturb paint? If yes, you may file the Affirmation instead of certification.

Most NYC HICs realistically fall under:

• Option A (if they do heavy renovation) or

• Option B (RRP only, no abatement)

Option C should only be used by truly limited-scope contractors.

What to Submit in Your DCWP Application

You must upload one of the following:

If you choose Option A:

• PDF of RRP Certificate

• PDF of Lead Abatement Certificate

If you choose Option B:

• One EPA certificate (RRP or Abatement)

• DCWP EPA Affirmation Form (stating the other doesn’t apply)

If you choose Option C:

• Only the DCWP EPA Affirmation Form

Final Word: Don’t Guess

If your work touches walls, ceilings, windows, doors, or trim in older NYC buildings, get RRP certified. It’s safer, and it prevents delays with DCWP.