Winston’s Environmental Law Update
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February 2, 2022
|6 min read
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.