NAA/NMHC recently sent a letter to the EPA Administrator regarding the Residential Lead-Based Paint Hazard Reduction Act. The letter, sent in conjunction with the National Leased Housing Association, seeks an immediate clarification regarding the assertion that housing and/or testing combinations that have been found to be lead-based paint free pursuant to 40 CFR 745.227(b) continue to meet the requirements of Subpart E – Residential Property Renovation.
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.
The rule actually establishes requirements for training renovators, other renovation workers, and dust sampling technicians; for certifying renovators, dust sampling technicians, and renovation firms; for accrediting providers of renovation and dust sampling technician training; for renovation work practices; and for recordkeeping.
NAA/NMHC Letter to EPA Administrator*
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