Apartment firms are reminded that the Environmental Protection Agency’s (EPA) new lead-based paint Renovation, Repair and Painting (RRP) rule became effective April 22. Under the rule, a trained or certified renovator must carry out any renovation or repair work undertaken on pre-1978 properties that disturbs more than six square feet of surface area for interior work or 20 square feet for exterior work. Importantly, market-rate and affordable properties are required to comply with the regulations and become certified themselves in addition to employing certified workers.
NAA/NMHC have petitioned the EPA for a two-year compliance assistance period rather than immediate punitive sanctions. In making this request, NAA/NMHC cited the impediments along the path to progress including: variations between properties that do and do not receive federal assistance; confusion in regional EPA offices regarding enforcement of the RRP rule (and Title X in general); and inconsistencies in course materials.
NAA/NMHC have published a white paper to help firms understand compliance requirements. That guidance and our letter to the EPA are posted here.