EPA RRP rule for landlords and property managers

Does it apply to landlords?

Yes. EPA lists residential rental property owners and managers among the firms that need certification, along with general contractors and trades like painters, plumbers, carpenters and electricians. It includes sole proprietorships and in-house maintenance staff. EPA: RRP for contractors · EPA RRP rules

If your company does the work itself, it must be a Lead-Safe Certified Firm. If not, hire only Lead-Safe Certified firms for maintenance, repair or painting that could disturb lead-based paint. EPA: RRP for property managers

What work is covered

In general, any activity that disturbs paint in pre-1978 housing: remodeling, repair and maintenance, electrical work, plumbing, painting prep, carpentry and window replacement. EPA

What is not covered

• Minor repair and maintenance that disturbs 6 square feet or less of paint per room inside, or 20 square feet or less outside. Window replacement and demolition of painted surfaces are always covered, whatever the size.
• Housing built in 1978 or later
• Zero-bedroom units and elderly or disability housing, unless a child under 6 lives or is expected to live there
• Housing or components declared lead-free by a certified inspector or risk assessor, or components a certified renovator tests as lead-free with an EPA-recognized test kit or lab paint-chip analysis

EPA

Do I have to test the paint first?

No, testing is not required. But unless you have documentation that the paint is not lead-based, the RRP requirements apply. EPA

Working in hallways or lobbies? Common-area renovation notice rules.

Contractor or in-house crew? RRP records checklist (free).

How to get certified

Individuals become certified renovators by taking training from an EPA-accredited provider; firms apply to EPA online and pay a fee. Renovators who take online refresher training are certified for 3 years; hands-on training gives 5 years. EPA RRP rules · EPA firm certification

Plan your turnover work Tools for property managers

Does the EPA RRP rule apply to landlords?

Yes. EPA lists residential rental property owners and managers among the firms that must be certified when they are paid to do work that disturbs paint in pre-1978 housing. Otherwise, hire only Lead-Safe Certified firms (EPA).

What is the RRP minor repair exemption?

Work that disturbs 6 square feet or less of paint per room inside, or 20 square feet or less outside, is not covered. Window replacement and demolition of painted surfaces are always covered (EPA).

Do I need to test paint before a repair in a pre-1978 rental?

Testing is not required, but unless you have documentation that the paint is not lead-based, the RRP rule applies (EPA).

Want a quick answer for your building? Try the free lead paint rule lookup. It takes about 2 minutes.