Renovation, Repair and Painting (RRP) Regulations
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 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 expands 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.
On August 23, EPA’s Office of Enforcement and Compliance Assurance issued a Consolidated Enforcement Response and Penalty Policy for the RRP rule. The document provides information on the factors federal enforcement officials will take into account in assessing civil administrative penalties for violations of various provisions of the RRP rule. .
EPA is in the process of amending the rules in a series of rulemakings as a result of a lawsuit brought against it by the Sierra Club. For more information on the latest rulemakings and other developments, see NMHC's Guidance.
Final Regulations and Guidance Materials
Amendments to the Rules
Third-party Guidance, Advisories, and Resources
NMHC Compliance Guidance