December 17, 2025
The National Association of Residential Property Managers (NARPM) continues to advocate for property managers in response to the EPA's 2022 withdrawal of key guidance related to lead certification under the Renovation, Repair, and Painting (RRP) Rule. In December 2025, NARPM leadership met directly with EPA senior officials—building on an earlier meeting with program staff—to press for the reinstatement of prior "Safe Harbor" guidance that exempted property management companies (PMCs) from certification when they hired properly certified contractors.
Historically, under the RRP rule established in 2010, PMCs were not required to obtain certification if they did not perform renovation work themselves and instead hired licensed, EPA-certified contractors. This position was reinforced through EPA FAQs published in 2018. However, in 2022, the EPA withdrew two critical FAQs, effectively expanding certification requirements to include PMCs even when they only manage or oversee work performed by certified vendors.
As a result, PMCs may now be required to obtain certification for activities such as soliciting contractor bids, applying for permits, granting property access, overseeing work, communicating with tenants, verifying completion, and paying contractors—even when they are not performing renovation work themselves.
NARPM argues this interpretation places an unnecessary regulatory burden on property managers and creates an inconsistency: property owners managing their own properties are not required to be certified when hiring licensed contractors, yet PMCs acting as the owner's agent may be. NARPM maintains that responsibility for RRP compliance should remain with the contractors performing the work, not the PMCs who hire them.
NARPM has committed to continuing its efforts—both administratively and legislatively—to restore common-sense guidance that distinguishes between doing the work and managing certified professionals, and to reverse the expanded interpretation now applied by the EPA.
