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EPA’s Lead Renovation, Repair, and Painting Program

December 5, 2022

Author: Kreg Wagner

What is the Lead-Based Paint Renovation, Repair, and Painting (RRP) Rule?

Passed in 2008, the rule’s purpose is to protect the public from lead-based paint hazards during renovations, repairs, and painting on a property that was built prior to 1978. Such renovations, repairs, and painting can create health and safety issues. The rule requires workers to be certified and trained in lead-safe work practices.

Who is subject to RRP?

Any renovation, repair, or painting (RRP) project that disturbs lead-based paint in homes, childcare facilities, and preschools built before 1978 must be performed by lead-safe certified contractors.

Generally, the RRP rule does not apply to homeowners doing RRP projects in their own homes. However, it does apply if you rent all or part of your home; operate a childcare center in your home; or if you buy, renovate, and sell homes for profit (i.e., a house flipper). (See https://www.epa.gov/lead/lead-renovation-repair-and-painting-program.)

Have there been any recent changes to the RRP Rule? How do the changes affect property management companies?

Yes. Until recently, many of the activities completed by property management companies relating to lead-based paint fell outside the RRP requirements. However, the EPA recently clarified that many administrative activities conducted by property management companies now fall within the regulations, thus triggering certification requirements for essentially all property management companies involved with lead-based paint activities.

Here are some common property management activities that would now require certification:

– Soliciting and evaluating contractor bids
– Applying for permits, as appropriate
– Granting contractors access to the property
– Overseeing contractor work on the property
– Informing tenants of renovation activity
– Verifying completion of renovation activity
– Remitting payment to contractors

What are the max penalties for a violation of the RRP rule?

Violations of RRP may result in the issuance of penalties up to $43,611 per violation.

How do I get certified if I’m a property manager?

If you need to get certified, begin the process at https://www.epa.gov/lead/getcertified.

For any questions regarding lead, lead hazards, their prevention, and certification, the National Lead Information Center provides a hotline at 800-424-5323. Hours are 8 a.m. to 6 p.m. Eastern, Monday through Friday.

Resource: EPA Lead Renovation, Repair and Painting Program