EPA Lead Based Paint Rule Change
Property Management Company and Employee Certification
QUESTIONS AND ANSWERS
Q: What action did the EPA take in April 2022 regarding PMCs and RRP projects?
A: The EPA issued an advisory requiring PMCs and their employees involved in RRP activities, including hiring third-party contractors, to be certified under the RRP Rule. This applies to renovations in residential housing built before 1978.
Q: Who is affected by the EPA's new advisory?
A: The advisory affects PMCs that perform, offer to perform, or claim to perform renovations in pre-1978 residential housing, which includes PMCs hiring third-party contractors for such work.
Q: What must PMCs do to comply with the RRP Rule according to the EPA advisory?
A: To comply, PMCs must obtain RRP certification from the EPA for themselves and ensure that all employees and any third-party renovation contractors conducting lead-based paint activities are also certified.
Q: Why has the EPA mandated individual certification for PMC employees involved in RRP activities?
A: The mandate aims to ensure that individuals directly involved in RRP activities, including preparatory and supervisory tasks, are knowledgeable about safe lead handling practices, thereby reducing the risk of lead exposure to the public.
Q: How can PMCs, their employees and contractors get certified?
A: PMCs, their employees and contractors can apply for certification by visiting the EPA's "Get Certified" webpage at: https://www.epa.gov/lead/getcertified. The site provides details on the certification process, requirements, and additional resources to assist in compliance.
Q: What is the significance of the certification requirement for PMCs and their contractors?
A: The certification requirement underscores the EPA's commitment to public health, particularly protecting children from the hazards of lead exposure. It ensures that those involved in RRP projects are trained in lead-safe practices, thereby minimizing the risk of lead contamination.
Q: What are the potential consequences for PMCs not complying with the EPA's certification requirement?
A: While the advisory does not detail specific penalties, non-compliance with EPA regulations typically results in legal and financial repercussions. PMCs could face fines, legal action, and reputational damage for failing to meet the certification requirements.
Q: Where can PMCs find more information about the RRP Rule and certification process?
A: PMCs can find comprehensive information about the RRP Rule and the certification process on the EPA's website, specifically the "Get Certified" section accessible at https://www.epa.gov/lead/getcertified. This resource includes application procedures, training, and compliance guidelines.
Q: When should a PMC disclose lead based paint information to a prospective tenant of pre-1978 housing?
A: The PMC must provide prospective tenants of housing built pre-1978 the EPA-approved lead-based paint pamphlet and any known information concerning lead-based paint and/or lead based paint hazards prior to renting to the tenant. These disclosures must be made prior to any monies changing hands or a lease being signed.
