“Caveat emptor.” Buyer beware. Property managers who hire contractors and maintenance professionals to work on residential properties (and some commercial properties) built before 1978 should heed this warning, given the recent tightening and enforcement of federal regulations regarding lead-based paint.
In January 2025, the Environmental Protection Agency tightened its standards under the “Renovation, Repair and Painting (RRP) Rule” to protect individuals from hazards posed by lead-based paint, but delayed enforcement of penalties until Jan. 12, 2026, one year after the rule change took effect. Property managers who engage in renovation and repair of residential properties on behalf of the owner and fail to comply with the updated standard could face costly lawsuits, project shutdowns, future insurance denial and fines of up to $40,000 per violation.
Read more: Lead-Based Paint Topic
“The vast majority of small property managers are not tracking EPA updates, and levied fines can be business-killers,” says Troy Garrett, CEO of the National Association of Residential Property Managers. “The EPA does not communicate with practitioners or investors about rule changes. Without a clear understanding of the rules, non-compliance can drive both small investors and property managers out of the market,” says Garrett.
The RRP Rule also applies to pre-1978 commercial properties where children are routinely present, such as schools, daycare centers and healthcare facilities. Although lead-based paint was banned for consumer use in the U.S. in 1978, it remains in millions of structures.
Lead poisoning cases have significantly declined since the 1970s; however, exposure via old pipes, paint and ceramics is still considered especially dangerous for children under age 5, according to the Centers for Disease Control. Even very low blood lead levels have been shown to reduce a child’s IQ and academic performance.
Significantly Lower Dust-Lead Hazard and Clearance Levels
The rule change lowers the dust-lead hazard standards to “any reportable level” as analyzed by an EPA-recognized laboratory. Additionally, it lowers post-abatement dust-lead clearance levels to between 50% and 75% of the previous levels for floors, window sills and troughs. The most common source of lead exposure in the body is inhaling or ingesting microscopic dust, often associated with property renovations and repairs.
Renovation and repair work that disturbs more than 6 square feet of lead paint (think window replacement, interior remodeling or surface preparation for painting) must be performed by a Lead-Safe Certified firm, with at least one worker on the job site who is Renovator-Certified by the EPA or an EPA-authorized program. The fee for most firms is $300 every five years, equivalent to a cost of $60 per year.
The EPA estimates that renovator-certified training, which is also valid for five years, costs $562 per person trained, including tuition, value of time for the eight hours the renovator is in class, travel and lunch.
The certification requirement applies to property managers who maintain in-house contractors. Firms that outsource renovation, repair and painting are responsible for confirming whether a contractor is Lead-Safe Certified and should ask to see a copy of the EPA training certificate.
NARPM advises its members to contact their state EPA office to understand how officials will enforce the new regulations in their state. “Some offices work to help property managers do the right thing to care for the health and safety of tenants, while others are more aggressive or even predatory in nature about compliance,” says Garrett.
The EPA has authorized 16 states to operate their own training and certification programs. If you manage property in multiple states, you may need to pursue multiple certifications.
Resources for Property Managers
Information for property managers, including compliance requirements, how to become a Lead-Safe Certified firm, and a searchable database to locate or confirm a certified contractor, is available at the EPA’s RRP webpage. Or contact the National Lead Information Center (800-424-LEAD).
