Why 1978 is the line
EPA's renovation rule covers work that disturbs painted surfaces in housing built before 1978, the year lead-based residential paint was banned.[1]
The rule follows the house, not the specific room, so a tub replacement in an otherwise updated bathroom can still fall under it if the home as a whole predates 1978.[1]
What actually triggers the rule
The rule applies once a renovation disturbs more than six square feet of painted surface on an interior wall, which a tub removal can easily reach if it means prying off tile, trim or an old surround along with the tub itself.[1]
What a certified renovation firm has to do
A firm working under the rule has to be certified with the EPA and employ a certified renovator, post warning signs, contain the work area, and clean up and verify the cleanup before calling the job done.[1]
The firm also has to keep records of that work for at least three years.[1]
Where an old tub makes this more likely, not less
A cast iron tub set into an original alcove, in a home old enough to fall under this rule, often means removing painted trim or tile around it to get the tub out, which is exactly the kind of work the rule was written to cover.[1]
A lighter acrylic or fiberglass replacement tub does not change this. What triggers the rule is the surface being disturbed on the way out, not the material of what goes in afterward.[1]
This is separate from the permit question
A tub swap can trigger EPA's rule, a building permit, both, or neither, depending on the home's age and whether the plumbing itself is moving. They are two different checks, not one.
A pre-1978 home getting a same-footprint tub swap might clear the permit question easily while still triggering the renovation rule the moment old trim or tile comes off with the tub.[1]
Asking about it before the work starts
A firm that regularly works in older housing should already know whether a job needs this step and should be able to say so without being pressed.
It is a reasonable question to ask alongside license and insurance questions, not a separate, awkward one.
A bid that already accounts for containment and cleanup, rather than adding it as a surprise line item later, is a sign the firm has done this kind of job before.
Checking your own home's age
The share of a city's housing built before 1980, and a specific home's own build year, are the first things worth checking before a tub swap starts, well before the crew shows up.
It is a question worth asking any pro bidding the job directly, not just assuming one way or the other.