As of April 2010, owners of market‐rate properties built before 1978 will have to comply with EPA lead safety regulations that govern common renovation and repair activities. (Age‐restricted properties, properties with no children occupying them and properties that have been certified to be free of lead‐based paint by a state inspector are exempt from the RRP regulations.)
Under the regulations, if renovation or repair work undertaken on a covered property disturbs more than six square feet of surface area for interior work or 20 square feet for exterior work, the work must be carried out by a trained and certified renovator.
In addition, residents must be notified and provided with a copy of an EPA pamphlet, Renovate Right: Important Lead Hazard Information for Families, Child Care Providers, and Schools. (This is a different pamphlet than the EPA's Protect Your Family pamphlet that owners are required to provide to residents at the time of lease signing.) There are also recordkeeping requirements imposed on owners or the third‐party contractors they hire to undertake work covered by the regulations.
Importantly, the RRP rules expand existing Lead Safe Housing (LSH) rules that has imposed comparable—but not identical—compliance obligations on pre‐1978 properties that receive federal assistance, including Section 8 vouchers. Under the RRP rules, federally assisted properties must comply with the more stringent elements of both the LSH and RRP regulations.
NAA/NMHC has developed this White Paper outlining property owners' compliance obligations and clarifying important issues for federally assisted properties that must comply with both the RRP and LSH rules. It also outlines a number of unanswered questions posed to the regulatory agencies by NAA/NMHC.
View full document*
*Member login required