Frequent Questions

Pre-Renovation Education

Can notices for multi-family housing common area renovations be delivered to the mailboxes of dwelling units, or only to the actual units themselves?
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?
EPA's pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools is currently not published in a Braille format. If working in target housing occupied by persons who are blind, how should a firm comply with the pre-renovation information distribution requirements?
How can a firm comply with the pre-renovation education requirements if the owner desires that the renovation begin immediately?
I am planning on sending the pamphlet via the United States Postal Service’s certificate of mailing delivery method to a tenant who occupies a unit scheduled to be renovated. Does the tenant’s name need to be addressed on the mailing, or is it acceptable to address the envelope to Attn: Tenant/Occupant?
I regularly perform renovations and repairs to common areas in a large apartment complex. Must I provide separate notice to the tenants for each one of these activities or is there any way to avoid such duplication?
If a firm completely blocks access to a common area for the duration of a renovation, does the renovator still have to provide notifications to all tenants?
If a project disturbs six square feet or less of interior surface or twenty square feet or less of exterior surface, is it necessary for a firm to comply with the pre-renovation education requirements, such as distributing the pamphlet?
If a renovation is to be performed on a common area in a pre-1978 building that contains a mix of studio apartments (0-bedroom dwellings) and apartments with 1 or more bedrooms, what pre-renovation education requirements would apply?
If a renovation is to be performed on a private balcony of a single unit in a multi-unit target housing building, does that activity trigger the common area notification requirements?
In a typical co-operative apartment building, occupants do not own the individual units; rather they “own” an undifferentiated share in the entire building and then “rent” back a specific unit from the co-operative corporation. Similarly, in a typical condominium building, owners of individual units jointly own the common areas of the building. For purposes of the pre-renovation education requirements, who are the “owners” in such situations?
Is an electronic version of the lead information pamphlet sent to the customer via e-mail an acceptable means of distributing the information?
May I use the pamphlet “Protect Your Family From Lead in Your Home” to meet my obligations for pre-renovation education under the RRP Rule?
Must notifications for common area renovations always be provided to every unit in a multifamily housing complex?
My firm is going to perform renovations in a school during the students' summer break. During the regular school year, the work area would fall under the definition of a child-occupied facility. However, no children under age 6 will be present during this multiple month break period. Do we still have to comply with the pre-renovation education requirements? If so, how should the information be distributed?
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?
The RRP Rule requires delivery of the “Renovate Right” pamphlet to the owner and occupants of target housing. My firm was hired to perform a renovation in a pre-1978 apartment building. Is delivery of the pamphlet to the property manager sufficient for purposes of delivery to the owner of the building?
Under the Pre-Renovation Education Rule, I have the option of using a certificate of mailing to notify the owner or occupant. What is the difference between a certificate of mailing and certified mail?
What are the pre-renovation education requirements for a vacant apartment?
When a unit is not occupied by its owner, 40 CFR 745.84(a)(2) states that the “Renovate Right” pamphlet must be provided to an adult occupant prior to beginning any covered renovation activities. What does EPA consider an “adult” for these purposes?
When multiple contractors are involved in a single renovation, must every contractor provide pre-renovation education? Can a certified firm assign its responsibility to a property management company?
When renovating a common area in an apartment building, must my firm provide pre-renovation education to all tenants?

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