On April 30, 2025, Michigan made universal blood lead testing law. Every child in the state must now be tested at 12 months and 24 months of age, with additional testing at other intervals based on exposure risk. It is the physician's legal responsibility to test or order the test — not the parent's. The statute is MCL 333.5474d, with implementing rules at R 330.301-304. The official MDHHS summary is at michigan.gov/mileadsafe.
Why this changes the math for GCs working pre-1978 housing
Before the universal-testing law, blood lead screening in Michigan was uneven — Medicaid kids were tested per federal rules, but private-pay families often weren't. That meant elevated blood lead level (EBLL) findings were under-detected, which kept Michigan PA 434 enforcement at a low simmer. PA 434 (MCL 333.5475a) gives local public health departments inspection authority — and civil or criminal liability — over landlords who knowingly rent a unit with a lead hazard to a family whose child has an EBLL.
Universal testing flips that. Every kid gets a blood draw at 12 and 24 months. Pediatricians and family-medicine practices across the state are now ordering blood lead panels by default. The EBLL detection rate will climb. The PA 434 referral rate will climb with it.
Where you, the contractor, sit in that chain
When a county health department investigates an EBLL finding, they trace the source. Lead-based paint in a pre-1978 unit is the dominant suspect, and the investigation pulls in the renovation history of the unit — windows, doors, kitchens, baths, anything that disturbed paint. If the most recent renovation was done without 40 CFR Part 745 documentation, you (the renovating firm) and the property owner are both in the frame for the EBLL.
The federal RRP rule has had this exposure all along. What the new universal-testing law changes is the discovery rate. Old workflow: do a sloppy job, hope nobody tests, hope no EBLL gets traced back. New workflow: every kid is tested, every EBLL gets traced.
What the compliance packet does for you here
When a Washtenaw or Wayne or Ingham county health investigator knocks, the first thing they ask the property owner is: who did the last renovation, and do they have the documentation?
The ECT compliance packet — delivered to the contracting firm within 24 hours of job completion and retained for 39 months — is the answer to that question. Signed Renovate Right acknowledgment, EPA Certified Renovator credentials, containment photos, cleaning verification card test result, three-point chain of custody on waste. It demonstrates that the renovation followed federal lead-safe work practices and isn't a plausible source of the EBLL. Investigation moves to other candidates (paint chips in the yard, water lines, imported goods) and the contracting firm stays out of it.
Without that packet, the renovating firm is the first plausible source and stays in the investigation indefinitely.
The Mitchell Method read on this
Universal testing isn't a risk to good contractors. It is the operating environment where documented compliance becomes a competitive moat. GCs who can hand a homeowner (or the homeowner's attorney, or the county investigator) a clean packet within 24 hours of any job will out-earn GCs who can't. Pricing reflects that: ECT charges $550 flat per job to cover the EPA RRP piece end-to-end, while "DIY" compliance costs a GC roughly $30-80 per labor hour in pre-job training, daily containment management, and post-job documentation — plus the open liability of any gap in that chain.
What to do this week
- Tell your project managers that every pre-1978 job from this point forward needs a compliance packet on file. Not optional.
- If you don't hold an EPA Lead-Safe Certified Firm credential, partner with one that does — either ECT or another firm in your service area. The ECT service area covers Washtenaw, Wayne, Jackson, Lenawee, and Ingham counties.
- Read the county-specific enforcement posture for your jobs: Washtenaw, Wayne, Ingham, Jackson, and Lenawee.
The universal-testing law is the kind of regulatory shift that rewards contractors who already had their RRP house in order and punishes the ones who didn't. The lead has been in the paint since 1978. The change isn't the lead — it's Michigan finally measuring who's been exposed to it.