My firm performs renovations in large apartment complexes that often consist of several separate buildings. If a renovation is to be performed in a common area in one building, are we required to provide pre-renovation education to all tenants in all buildings?

When renovations are to be performed in common areas of multi-unit target housing, the RRP Rule requires that the firm notify in writing both the owner of the building and each “affected unit.” See 745.84(b)(1) and (2). Common areas are those portions of a property generally accessible to residents/users, and can exist on both the interior and exterior of the building.

Generally, the exterior of a building in a multi-building complex is likely to be accessible to all residents/users in all buildings. Therefore, if a renovation is to be performed on an exterior common area, all units would probably be “affected units” and require notification. Conversely, the interior of a building is likely only to be accessible to the residents/users of that particular building. If a renovation is to be performed in an interior common area of one building in a multi-building complex, then only the units located in that building would be “affected” and require notification.

Firms may choose to comply with this requirement by mailing or hand delivering the “Renovate Right” pamphlet and information to each “affected unit,” or by posting informational signs while the renovation is ongoing describing the general nature and location of the renovation and anticipated completion date. For additional information on these options, visit https://www.epa.gov/lead/small-entity-compliance-guide-renovate-right-epas-lead-based-paint-renovation-repair-and-0. As a practical matter, when “affected units” are difficult to determine, it may be easier or more efficient for firms to meet the pre-renovation education requirements by posting informational signs in the appropriate locations.

Question Number: 23002-19756

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