Lead-Safe Renovation in Older Houston Rental Properties
Many rental homes and apartment buildings in the Houston area were built before lead-based paint was banned for residential use. When painted surfaces in older housing are sanded, scraped, cut or demolished, they can release lead dust that is harmful, especially to young children and pregnant women. Federal rules govern how renovation, repair and painting work is done in that older housing.
For owners and property managers, the rules affect make-ready turns, unit renovations, window replacements and exterior painting. This guide explains the basics. It is general information, not legal advice; talk with your attorney about how the rules apply to your properties.
Which properties are affected
The EPA's Renovation, Repair and Painting (RRP) program applies to work that disturbs painted surfaces in housing and child-occupied facilities built before 1978. That includes many single-family rentals, duplexes and older apartment communities. If you do not know when a building was built, the appraisal district record from HCAD is a common starting point.
Some housing is exempt, and some small jobs may fall below the rule's thresholds. EPA's RRP rule page explains the details. Do not assume an exemption applies without checking.
Who can do the work
Under the RRP rule, firms that perform covered renovation work for pay in pre-1978 housing must be certified by EPA, and the work must be directed by a trained renovator who follows lead-safe work practices. EPA's information for contractors describes these requirements. Property management companies whose own maintenance staff do covered work are also affected, so review in-house practices too.
Disclosure duties
Separate from renovation rules, federal law requires landlords and sellers of most pre-1978 housing to disclose known lead-based paint and hazards and give tenants or buyers an EPA pamphlet before a lease or sale. EPA explains the lead disclosure rule and its forms. RRP also includes requirements to give occupants information before renovation begins.
What lead-safe work looks like
Lead-safe practices aim to contain dust, keep it from spreading, and clean it up thoroughly. A typical job includes:
- Setup: Closing off the work area, covering floors and furniture with plastic, and posting warning signs.
- Limited methods: Avoiding high-dust methods such as open-flame burning or power sanding without proper controls.
- Containment: Keeping dust inside the work area and protecting HVAC openings.
- Cleanup: Using HEPA vacuums and wet wiping, then checking the area before it is reopened.
- Waste handling: Bagging and disposing of debris properly.
- Records: Keeping documentation of the work and the practices used.
EPA's lead program page offers more detail on lead hazards and safe practices.
Where lead rules show up in rental work
Make-ready turns
Scraping and repainting trim, patching walls, replacing doors and sanding cabinets can all disturb old paint. Build lead-safe steps into the make-ready scope for older units instead of treating them as a surprise. Our make-ready scope of work guide covers how to structure turn scopes.
Window and door replacement
Removing old windows and doors often disturbs painted frames and trim. Plan for containment and cleanup as part of the replacement scope.
Exterior painting
Scraping and power washing older siding and trim can spread paint chips into soil and walkways. Our guide to multifamily exterior painting and siding repair covers planning exterior work at apartment communities.
Full unit renovations
Demolition of walls, cabinets and flooring in older units can disturb painted surfaces. Our guide to apartment unit renovation covers renovation scopes more broadly.
Plan for vacant and occupied units
Lead-safe work is easiest in vacant units, where containment does not interfere with daily life. For occupied units:
- Give residents written notice and the required information before work starts.
- Plan how residents will avoid the work area during the job.
- Protect belongings that cannot be moved.
- Schedule cleanup and verification before residents return to the area.
Other hazards in older buildings
Older buildings can also contain asbestos in flooring, ceilings, joint compound and pipe insulation. Asbestos has its own federal and state rules. Our guide to asbestos surveys before renovation explains why testing comes first. Mold and moisture problems are also common in older rentals; see our guide to mold remediation coordination.
Budget and schedule impacts
Lead-safe practices add setup, containment and cleanup steps. Plan for this in scopes and schedules rather than discovering it mid-project. When comparing bids, make sure every contractor has included lead-safe work where it is required, so you are comparing the same scope.
How a typical lead-safe project unfolds
A lead-safe renovation usually begins during planning, when the owner or manager confirms the property's construction date and reviews any past lead testing. If paint will be disturbed and the building predates the federal cutoff, the team plans lead-safe work practices from the start rather than treating them as an add-on.
Residents receive the required information before work begins. The contractor then sets up containment, covering floors and furnishings, sealing off the work area and posting warning signs. Work proceeds using lead-safe methods that limit dust, such as wet scraping and careful removal of components.
When the work is done, crews clean the area thoroughly and perform cleaning verification as required. Owners should keep records of the firm's certification, resident notices and cleaning verification. Those records help with resident questions, insurance, future renovations and any later sale of the property.
Questions to ask contractors
- Is your firm EPA-certified for RRP work, and who will serve as the trained renovator?
- How will you set up containment in vacant and occupied units?
- What cleanup and verification steps will you follow?
- What records will you provide when the work is done?
- How will you handle exterior work near soil, gardens and play areas?
Common mistakes to avoid
- Assuming the rule does not apply: Check the building's age before starting work.
- Overlooking in-house staff: Maintenance teams doing covered work need to follow the rules too.
- Skipping disclosure: Leasing older units without required disclosure creates risk.
- Poor cleanup: Dust left behind defeats the purpose of the rules.
- Missing records: Documentation matters if questions come up later.
Quick checklist
- Building age confirmed
- RRP applicability reviewed
- Certified firm and trained renovator confirmed
- Disclosure forms and pamphlets in place for leases
- Lead-safe steps built into scopes
- Resident notices prepared for occupied units
- Asbestos and other hazards considered
- Records kept after each job
Planning make-ready, painting or renovation work at older rental properties? BPC Development LLC provides free on-site estimates in Houston, TX. Call (281) 301-4737.