US EPA RRP Update to Property Management Company FAQs

Tuesday , 8, March 2022 Comments Off on US EPA RRP Update to Property Management Company FAQs
On March 21, 2022, EPA will withdraw 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, found 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 have enforceable obligations under the RRP rule and, for example, would not need to ensure that lead-safe work practices were followed.

What does this mean for you?
The EPA will now assess compliance of Property Management Companies as it would for any other entity. This rule requires that no firm may perform, offer, or claim to perform renovations in target housing or child-occupied facilities without certification from EPA, unless an exception applies. This rule also requires that a certified renovator who is trained in lead-safe work practices must direct and perform the renovation, along with any other individuals trained in accordance with 40 CFR §§ 745.90(b)(2) and 745.81(a)(3).

On November 4, 2021, EPA published a notice in the Federal Register announcing its intention to withdraw the two FQs and their previously published answers. To read the Federal Register Notice published on November 4, 2021, please visit:
https://www.federalregister.gov/documents/2021/11/04/2021-24010/withdrawal-of-two-answers-to-frequent-questions-about-property-management-companies-and-the-toxic  
On January 21, 2022, EPA announced that it would proceed with the withdrawal of the FQs. The memorandum announcing that action is available at:

https://www.regulations.gov/document/EPA-HQ-OECA-2021-0763-0010 
Become EPA Lead-Safe Certified Today NATEC International Inc., is an accredited EPA training provider for EPA Lead-Safe Certification for Renovators. We offer a variety of in-person, virtual and online training options to help you become certified. Click the links below to see our EPA Lead training options.

Southern California Lead Training Courses

Sacramento, California Lead Training Courses

Oakland, California Lead Training Courses

Online EPA RRP Refresher Training