Short answer: If you pay someone to disturb paint in a home built before 1978, the EPA's RRP rule requires an EPA-certified firm using trained renovators and lead-safe practices. In Michigan, EPA runs the program. The homeowner exemption doesn't cover rentals or flips. Detroit's rental inspection now checks for deteriorated paint and bare soil.
Does the EPA RRP rule apply to my job?
- Built before 1978? The rule covers homes, child-care facilities and preschools built before 1978.
- Paid work that disturbs paint? EPA says anyone paid to do work that disturbs painted surfaces must be certified and their employees trained.
- Landlords and flippers: EPA's own page says the homeowner exemption does not apply if you rent all or part of your home, or buy, renovate and sell homes for profit.
- Michigan: Michigan is not on EPA's list of states with their own authorized RRP program, so EPA certifies firms here. (Our reading of EPA's list.)
Detroit rentals: what changed in 2024
| Before the 2024 ordinance | Now | |
|---|---|---|
| Lead check for a Certificate of Compliance | Lead inspection/risk assessment and clearance for every rental | Visual standard in the 15-point inspection: "No deteriorated paint or bare soil" |
| If paint or soil fails | Part of the lead clearance process | City guidance: consult a lead-safe certified professional |
| If a child is lead-poisoned | Covered by the clearance regime | The City requires a lead inspection and risk assessment at the owner's expense |
The City's July 2024 announcement explained the change: under the old rule, most rentals were never inspected for lead safety. Source details below.
What lead-safe work looks like
- Before work starts, residents get EPA's Renovate Right pamphlet.
- The work area is contained with plastic sheeting and warning signs.
- Dust is controlled: no open-flame burning, no high-speed sanding or grinding without HEPA controls.
- Cleanup uses HEPA vacuums and wet wiping, followed by cleaning verification.
How do I find a certified firm?
EPA's lead-based paint professional locator lists certified renovation firms. Ask any painter for their firm certification before work starts on a pre-1978 home. For our painting jobs on pre-1978 homes, we use lead-safe (EPA RRP) certified painters. See painting.
Sources
- U.S. EPA: Lead Renovation, Repair and Painting Program
- U.S. EPA: How can I find a certified renovation firm in my area?
- City of Detroit: Rental Ordinance 15-point Inspection Checklist (PDF, Apr 2025)
- City of Detroit: New Detroit Rental Ordinance, August Update (PDF, Aug 2025)
- City of Detroit: Mayor Duggan and Council Member Mary Waters propose changes to the rental ordinance (July 2024)
- City of Detroit: Final Rental Ordinance as passed 10/29/24 (PDF)
This guide is general information, not legal advice. Rules change, so check the official sources above before you rely on them.
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