On March 21, 2022, EPA withdrew two FQs (23002-13650 and 23002-18348) concerning property management companies (PMCs) and their compliance responsibilities under the Toxic Substances Control Act (TSCA) RRP rule at: https://www.epa.gov/lead/answers-frequent-questions-about-epas-lead-renovation-repair-and-painting-rrp-rule. These FQs provided that a PMC that did not use its own employees to do RRP work would not be regulated by the RRP rule and would not need to ensure that lead-safe work practices were followed.
The EPA will now review compliance of Property Management Companies (PMC) as it would for any other organization. This rule says that no firm may perform, offer, or claim to perform renovations in target housing or child-occupied facilities without certification from EPA, there are exceptions, carefully read the rules below. A certified renovator who is trained in lead-safe work practices (RRP) must manage and do the renovation, everyone else on the job must be RRP trained by a school that is approved under the rules of 40 CFR §§ 745.90(b)(2) and 745.81(a)(3).
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