Answering The Same Questions About Lead Based Paint – LBP
I can’t believe that 10 years after it went into effect many underwriters still don’t get it.
The following excerpt is copied from a 203(k) consultant’s work write up describing work that must be required of the borrower or homeowner during a renovation:
“RRP: Provide all required containment/cleanup/disposal by a licensed Paint Stabilization professional for Lead Based Paint – The building appears to be built before 1978 – Provide completed EPA required Containment and Cleanup Manifest”
From Our Sample Report Describing LBP Requirement
Regarding the licensing (Renovators), contractors working in buildings built before 1978 have been required to be licensed by the EPA since April 2010. If the contractor is not licensed then he needs to use someone who does have a license within his company.
Regarding the Manifest, that’s the document the contractor is required by law to fill out to chronicle that he did the proper containment and cleanup after the work was completed.
The documents must be kept in the place of business pending any EPA audit of his past projects. Know that the item is not a “requirement” of any lender.

Recently on television, Chip and Joanna Gaines were fined $40,000 for not filling out the paperwork for all the jobs they finished. Also, unless the house is sold by HUD there is no credit to the borrower.
As I mentioned above, the law requires containment and cleanup of work that may involve painted surfaces presumed to contain LBP, not identification of such contaminants.
In addition, a general contractor must have at least 1 licensed individual responsible for the entire project. If the license is issued to an entity, the entity will become the responsible party. In such cases, that entity may collect RRP licenses from the various subcontractors to keep on record.
It’s important your report outline only work described by EPA as “Containment & Cleanup” and in no way refer to “Abatement”, which is the removal of such substances by federally licensed individuals.
Contact me for 203(k) Consultant Training.