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February 2, 2022

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6 min read

New EPA Guidance: Property Management Companies Now Subject to the Lead Renovation, Repair and Painting Rule

EPA recently announced the Agency will more broadly interpret the applicability of the Toxic Substances Control Act’s (TSCA) Lead Renovation, Repair, and Painting (RRP) rule.  The RRP rule establishes training, certification, information distribution, and work practice requirements for firms who “perform, offer, or claim to perform” renovations, repair, and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978.  EPA intends to hold property management companies (PMCs) liable for retained contractors who renovate or repair the pre-1978 properties PMCs manage.  RRP rule liability can be significant.  PMCs should review their compliance programs and consider updates.

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About This Blog

Winston’s Environmental Law Update focuses on environmental legal, regulatory, and policy issues facing manufacturers, energy, retailers, real estate, and financial institutions. As the political, corporate, and regulatory responses to recent environmental initiatives evolve, it is our goal to help our clients understand the risks and opportunities these initiatives present and develop strategic responses that cut across multiple legal disciplines. The blog provides an avenue to bridge the gap between law and policy, compliance, and execution.

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