I have a for-profit business where I purchase residential properties and renovate them. I initially try to rent the property, but if I can’t find tenants, then I try to sell the property. I pay for and perform all of the work myself, and keep all profits from the sale or lease. Is this type of renovation work on pre-1978 properties covered by the Renovation Repair and Painting (RRP) Rule?
Yes. Individuals who buy, renovate, and sell pre-1978 residential properties for a profit (i.e., house flippers) or lease pre-1978 residential properties (i.e., landlords), and do the renovation work themselves, are performing renovations for compensation and are therefore subject to all requirements under the RRP Rule. You must be a trained and certified renovator in order to perform the work, and certified as a lead-safe firm. See FQ #23002-18512 for more information related to landlords performing their own renovations in pre-1978 housing.
Similarly, businesses that buy, renovate, and sell pre-1978 residential properties and use their own employees to do the renovation work are performing renovations for compensation and are subject to all requirements under the RRP Rule. The business must be a lead-safe certified firm, and employ at least one certified renovator to perform the covered renovations.
However, individuals or businesses that buy, renovate, and sell pre-1978 residential properties (i.e., flip houses) do not need to be certified if they hire an outside renovation firm to perform all the work. The outside renovation firm hired must be a lead-safe certified firm, perform the renovation using a trained and certified renovator, and is otherwise responsible for meeting all work practice and recordkeeping requirements.