We’ll stay focused on pre 1978 housing but remember this also pertains, at least in part, to child occupied facilities. First let’s clarify what the EPA considers to be “renovation”.
If the surface to be painted is not disturbed by sanding, scraping or other activities that may cause dust, the work is not considered to be renovation. However, if painting projects involve surface preparation that disturbs paint, such as sanding & scraping, then it is considered renovation.
Here’s an abbreviated list of what you must do prior to renovation:
- Distribute EPA’s lead pamphlet to occupants/residents
- For multifamily common areas: distribute pamphlet to tenants or post informational signs about the pending work where they can be seen and contain dates, nature and location of work and be accompanied by pamphlet and/or instructions on access to it.
- Utilize a lead based paint certified provider for the work
So what’s the big deal? Penalties can go as high as $37,500.00 per violation, per day. For a sobering check, visit this link: - https://www.epa.gov/enforcement/fy2016-enforcement-actions-lead-renovation-repair-and-painting-rule-rrp
FPM Properties has not one but two MPMs (Master Property Manager) and well over 50+ years combined experience on the team and extensive history managing properties in Riverside, Avondale, San Marco, St. Nicholas, Atlantic and Neptune Beaches (just to name a few) which have high concentrations of pre 1978 homes. If you own or are considering purchasing such an investment property and don’t want to deal with all this, you should contact us!