Does a renovator need to attempt personal delivery of the lead information pamphlet to a tenant more than one time before utilizing the “self-certification of pamphlet delivery” option?

Answer: Personal delivery of the lead information pamphlet is preferable, wherever possible, because EPA believes that tenants will be more likely to read the information if it is handed directly to them. It also affords tenants an opportunity to raise concerns and ask questions about the renovation. EPA recognizes, however, that personal delivery will not always be a viable option, especially when a renovation needs to be commenced on short notice and an adult occupant of the apartment is not available. Thus, the RRP Rule permits the person delivering the pamphlet to “self-certify” the delivery (40 C.F.R. 745.84(a)(2)(i)). Although it is recommended that delivery be attempted on more than one occasion, a single good faith delivery attempt is acceptable for purposes of the RRP Rule.

NOTE: the self certification provisions apply only to pamphlet deliveries to rental units; renovators cannot self-certify a pamphlet delivery to the owner of the dwelling unit. Pamphlet deliveries to unit owners must be made directly to the owner, an agent of the owner, or via mailing.

Question Number: 23002-32361

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