We have heard concerns from our members regarding changes to the EPA’s lead-safe certification requirements for property managers. We hope this blog will help guide you through the process to get your firm certified.
What has changed?
Recently, the EPA modified how it plans to interpret the Lead Renovation, Repair, and Painting Rule, which is often abbreviated as the RRP Rule. The RRP Rule sets out training, certification, and requirements, among other things, for firms who perform, offer, or claim to perform renovations, repair, and painting in homes or facilities built prior to 1978.
The EPA’s changes to the RRP Rule occurred through the notice and comment process when the EPA sought to remove two FAQs that applied to property management firms. In essence, the two FAQs indicated that a property management firm did NOT need to be lead-safe certified if it hired a contractor who was lead-safe certified. The FAQs also indicated that liability, if the process was followed properly, would shift to the hired contractor and not to the property management firm.
These two FAQs have now been removed. This means that if you are a property management firm and you offer to provide landlords with property management services that include maintenance, repair, painting, renovations, or other activities that disturb painted surfaces and may be subject to the RRP Rule, the property management firm needs to now be lead-safe certified. This also includes firms who only solicit bids from third-party contractors who are certified.
Both the property management firm and the contractor performing the repair, renovation, or maintenance need to be lead-safe certified. The property management firm cannot shift liability any longer to the contractor.
How do I get my firm certified?
The first place to start is the EPA’s website. The direct web address is www.epa.gov/lead/getcertified. From this page, you should see an apply now button. The next step will be to enter the information for your firm to see if the firm is already registered and/or certified with the EPA. If the firm does not appear, then you can create an account and begin an application. The fee is $300, and the EPA is supposed to process the application within 90 days.
Additionally, the EPA states the RRP Rule requires the following: 1. Each firm to be certified, 2. Each firm needs to have at least one certified renovator, and 3. The remainder of employees involved in renovation activities also need to be certified renovators or be trained on the job by a certified renovator. EPA’s website provides a link to find RRP renovator training in your area. The web address with that link is www.epa.gov/lead/renovation-repair-and-painting-program-renovator-training.
The course to become a certified renovator is an 8-hour training, which includes 2 hours of hands-on learning. When you finish the course, you should receive a completion certificate, which will serve as your certification credential. The certification lasts for five years. Renewal requires a 4-hour refresher training course, and every other renewal requires a 4-hour refresher training with hands-on learning.
In summary, if you are a property management firm that manages properties that fall within the RRP rule, and you offer property management services that include maintenance, repair, painting, renovations, or other activities that disturb painted surfaces, then you need to get lead-safe certified. Even if you don’t do renovation work yourself and contract with a third party to do the work, your firm needs to get certified if you offer this kind of work to your landlords.