NARPM Presses Forward for a Solution
by Tyler Craddock
Nearly everyone who has purchased a property built prior to 1978 will be familiar with the issues associated with lead paint. After all, in order to acquire that property, they had to review and sign a federally mandated lead-paint disclosure form prior to closing the transaction. These documents and associated fines and penalties associated with failing to disclose the possibility of lead paint presence and known hazards surrounding lead exposure are part of the U.S. Environmental Protection Agency (EPA)’s efforts to educate and protect residents living in properties built before this dangerous paint was outlawed.
These efforts are incredibly important. They keep residents safe and property owners protected. However, since their initial adoption, pressure on property owners, particularly landlords, to provide increasingly onerous levels of certification and remediation has skyrocketed.
Since 2022, the EPA has required in-house maintenance teams to be certified in lead paint remediation even if they do not handle such responsibilities. These certification requirements were even extended to property management companies whose sole responsibility related to lead paint remediation lay in hiring or paying a certified vendor equipped to perform the work and follow RRP (Renovation, Repair, and Painting) rules.
During 2022, the EPA further complicated matters by withdrawing two public questions on their website that seemed to clarify that vendors needed certification while property managers did not. Since that time, many property managers have faced the onus of getting certifications for lead remediation despite a lack of educational background in this area and the certification’s lack of relevance to their roles in managing properties.
Trying to Create a Productive Conversation
The National Association of Residential Property Managers (NARPM) fully supports the federally mandated disclosure requirements for lead-based paint as well as appropriate fines and penalties for noncompliance. NARPM also firmly believes in-house maintenance staff physically conducting repairs affected by lead-based paint in a property or handling remediation on a property should also be fully trained and certified.
No one wants individuals or companies directly involved in these processes “off the hook” when it comes to having the training and resources to protect themselves and everyone else living or working in the property. Those who fail in this responsibility are bad actors in our industry and should face the penalties and fines the EPA has set out.
However, legislation that requires inspection, abatement, or tenant relocation at the property owner’s expense and regulations that require excessive and difficult certifications for property managers involved solely in hiring experts or paying them are unfair to both property management companies and property owners. These actions increase responsibility, liability, and costs to the point that they could render rental housing uneconomical to own or operate.
NARPM is also concerned about the fate of older, pre-1978 properties should they become too difficult to operate as rental homes. To begin with, these properties tend to be on the more affordable end of the spectrum for tenants, making them attractive in a time when affordable housing is hard to come by.
These regulations are certainly affecting the cost of living in an older residential home in a negative way. Furthermore, should the task of property management on these properties become too expensive or onerous to tolerate, most investors will choose to release them from their portfolios or property management companies will be forced to exclude these older properties from their service offerings. This will likely result in those properties ultimately being allowed to deteriorate once they lack a professional property manager or to ultimately succumb to long-term vacancy and neglect. With the housing shortages currently affecting nearly every market in the United States, we cannot afford to make affordable, single-family residential homes harder to come by.
In December 2025, NARPM representatives met with EPA senior leadership to discuss the withdrawal of those two FAQs related to lead certification for property managers. To most people, the presence of a seemingly innocuous FAQ on a government website might not seem like a very big deal, but NARPM and the EPA both understand the gravity of these public questions and the statements that form their answers. NARPM worked and continues to strive to help EPA officials understand how important a role the “Safe Harbor” Guidance that existed prior to 2022 was to property management companies using certified renovators.
This was the second such meeting between NARPM and the EPA, and these types of changes take time to enact because even small adjustments can feel like wholesale changes politically. As NARPM continues to work with the EPA to reverse the damage the administration caused when it removed that guidance, we believe the process will help many significant actors in our government truly understand just how important and unique property managers truly are.
This is a question of helping the law catch up to reality, and NARPM is dedicated to making sure it happens.
Learn more about how NARPM works hard to make sure property management companies and the real estate industry have a strong advocate in policy at NARPM.org.
