I have a for-profit business where I purchase residential properties and renovate them. Is this type of renovation work on pre-1978 properties covered by the Lead Renovation, Repair, and Painting (RRP) Rule?

Yes. Individuals who buy, renovate and sell pre-1978 residential properties for a profit (i.e., house flippers) or lease pre-1978 residential properties (i.e., landlords), and do the renovation work themselves, are performing renovations for compensation and are therefore subject to all requirements under the RRP Rule.  You must be a trained and certified renovator in order to perform the work, and certified as a Lead-Safe Certified Firm.  See FQ 23002-18512 for more information related to landlords performing their own renovations in pre-1978 housing.

Similarly, businesses that buy, renovate and sell pre-1978 residential properties and use their own employees to do the renovation work are performing renovations for compensation and are subject to all requirements under the RRP Rule.  The business must be a Lead-Safe Certified Firm, and employ at least one certified renovator to perform the covered renovations.

However, individuals or businesses that buy, renovate and sell pre-1978 residential properties (i.e., flip houses) do not need to be certified if they hire an outside renovation firm to perform all the work. The outside renovation firm hired must be a Lead-Safe Certified Firm, perform the renovation using a trained and certified renovator, and is otherwise responsible for meeting all work practice and recordkeeping requirements.

Question Number: 23002-32412

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