Why does 1978 matter for a siding job?
Lead-based paint for homes was banned in 1978, so a house built before then is presumed to have lead paint on its trim, old clapboards or shingles unless testing shows otherwise. Tearing off siding means cutting, scraping and breaking painted surfaces, which is exactly the kind of work that releases lead dust. In much of Massachusetts this is most homes: in many towns more than half the housing was built before 1980 (see the numbers on each town page).
Who regulates lead-safe renovation in Massachusetts?
The state, not the EPA. Since 2010 the Massachusetts Department of Labor Standards (DLS) has run its own lead-safe renovation program under 454 CMR 22.00, in place of the federal RRP rule. Anyone paid to do work that disturbs paint in a pre-1978 home must hold a Lead-Safe Renovation Contractor license from DLS, and a trained Lead-Safe Renovator Supervisor must be on site while that work is going on.
What should happen before work starts?
The contractor must give the owner (and any tenants) the EPA pamphlet *Renovate Right* no more than 60 days before the work begins and get a signed acknowledgment that it was received. Ask for the contractor's DLS license number at the same time as their HIC registration.
What does lead-safe work look like on a siding job?
- The work area is set off and the ground is covered with plastic sheeting to catch chips and dust.
- Windows and doors near the work are closed and covered.
- Painted surfaces are not dry-scraped or power-sanded without proper dust controls, and paint is not burned off with an open flame.
- Debris is bagged, the area is cleaned up each day, and the cleanup is checked when the job is done.
The details are in the work-practice section of the regulation (454 CMR 22.11).
Could your old siding contain asbestos?
Possibly. Many mid-century homes were covered in asbestos-cement shingles — hard, brittle, often gray or white shingles with a slightly textured face. You can't tell for sure by looking; a lab test of a sample can.
What does MassDEP require for asbestos siding?
MassDEP regulates asbestos-cement siding under 310 CMR 7.15. Removing more than 100 square feet of exterior asbestos-cement shingles, siding or panels requires an asbestos notification (form ANF-001) filed with MassDEP at least 10 working days before work begins. Removing 100 square feet or less is exempt from notification, but the work practices still apply: each shingle has to be wetted before removal and taken off without breaking it. Owner-occupied homes with four or fewer units are exempt from MassDEP's notification fee, not from the rules.
How does this affect cost and schedule?
It adds steps: testing, a notification period of at least two weeks when asbestos siding is involved, containment, careful removal and disposal. A written estimate for an older home should say how lead and asbestos will be handled. If it doesn't mention either, ask.
Can you cover old siding instead of removing it?
Sometimes new siding is installed over old, but it hides the condition of the sheathing and flashing, and in a historic district the commission may weigh in. On many older Massachusetts homes, removal is the only way to find and fix rot around windows and sills before closing the wall up again.
Quick answers
Do lead-safe rules apply to siding replacement in Massachusetts?
Yes, for homes built before 1978. Paid work that disturbs paint must be done by a contractor licensed by the Massachusetts Department of Labor Standards, with a Lead-Safe Renovator Supervisor on site.
What is the Renovate Right pamphlet?
An EPA lead-safety pamphlet the contractor must give the owner and occupants no more than 60 days before work starts on a pre-1978 home, with a signed acknowledgment.
Do I need to notify MassDEP to remove asbestos siding?
If you remove more than 100 square feet of exterior asbestos-cement siding, an ANF-001 notification must be filed at least 10 working days before work starts. Smaller jobs are exempt from notification but must still follow the work practices.
How do I know if my siding contains asbestos?
Only a lab test of a sample can confirm it. Asbestos-cement shingles were common on mid-century homes and are hard, brittle and usually gray or white.
Sources
- 454 CMR 22.00 — Deleading and lead-safe renovation (Cornell LII)
- 454 CMR 22.11 — Work practices for renovation work
- 310 CMR 7.15 — MassDEP asbestos regulation (Cornell LII)
- MassDEP — File an AQ 04 (ANF-001) asbestos removal notification
Rules change and towns differ. This article is general information, not legal advice — confirm requirements with your building department.
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