Property Management Companies & Changes to EPA's RPP Rule
April 11, 2022 | Texas REALTORS® Staff
The Environmental Protection Agency’s 2008 Lead-Based Paint Renovation, Repair, and Painting (RRP) Rule requires specific training and certification when performing certain work with pre-1978 housing and child-occupied facilities built before 1978.
Does Your Property Management Company Need Certification?
If your property management company performs any activity that disturbs paint in pre-1978 housing and child-occupied facilities built before 1978, it is performing a regulated renovation requiring certification, including remodeling and repair/maintenance, electrical work, plumbing, painting preparation, carpentry, and window replacement. That part of the rule has not changed. However, the EPA broadened the rule to also require certification for these administrative actions:
- 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 the contractors.
Firm Certification vs Individual Certification
If your company is subcontracting the renovation work that disturbs paint in pre-1978 housing and child-occupied facilities built before 1978 to other firms, your firm needs only to complete the firm certification. However, you are still responsible for ensuring the renovating firm that is selected for the renovations is certified and has at least one certified renovator on staff.
To become a certified firm, submit a short application and fee of $300 to the EPA. The firm certifications are good for five years. Go to epa.gov and click Apply Now to get started. First search for your firm to make sure it doesn’t have a current or pending certification. Then you can begin an application to certify a new firm using the link provided at the bottom of the Results page.
If your company engages in any of the regulated renovation or demolition work that disturbs paint in pre-1978 housing and child-occupied facilities built before 1978—not just the administrative actions included in the bulleted list above—your property management company employees may need to obtain individual certification as certified renovators.
They can complete the renovator certification by taking a one-day course in addition to the firm certification. The certified renovators are responsible for on-the-job training of individuals who will participate in the renovations. Such training must be documented, and the documents must be retained. Find an RRP training class or provider in your area at epa.gov.
Get More Information
The National Lead Information Center provides a hotline for more information on becoming certified 8 a.m. to 6 p.m. Eastern Monday through Friday at 800-424-5323.
Penalties for a failure to maintain required documents can reach $40,576 per violation, per day and “knowing violations” can result in criminal penalties of up to $50,000 per violation per day, or imprisonment for not more than one year, or both, in addition to or in lieu of civil penalties.
