The dividing line is not whether you own the building. It is whether the painting is work for compensation. If you live in the house and paint your own hallway, the federal renovation rule does not reach you. If the unit is rented, the rent is the compensation, and the same brush in the same hallway becomes regulated work under the EPA Renovation, Repair and Painting program. That is the piece most owners of pre-1978 Rochester rentals get wrong, because the homeowner exemption is written about the place you live, not the property you hold.

Who counts as a firm when the landlord is the one holding the brush?

Under the EPA RRP rule a landlord who performs covered work on a pre-1978 rental is acting as the renovation firm, so a single owner doing turnover painting in Rochester needs two separate things: certification for the business and renovator training for the person doing or directing the work. EPA describes both requirements for rental owners and property managers on its renovation program pages for property managers. One does not substitute for the other.

• Firm certification is an application you file with EPA for the entity that performs the work, which may be you as a sole proprietor or your LLC.
• Renovator certification comes from a course delivered by an EPA accredited training provider, and it is held by a person, not by the company.
• New York is not one of the states authorized to run its own program, so EPA certifies firms and accredits trainers here directly through the pages at epa.gov/lead.

The practical result for a small portfolio is that the owner usually becomes both: the certified firm on paper and the certified renovator on the job.

What work is small enough to skip certification?

EPA's rule exempts minor repair and maintenance that disturbs only a small area of painted surface, and the thresholds are square footage limits per room inside and per job outside, published on EPA's renovation, repair and painting rules page. Touching up a patched nail hole is not the same job as repainting a unit. Measure the painted surface you will actually disturb, including sanding and scraping, before you decide the exemption covers you.

Two cautions sit on top of those limits. Window replacement and demolition of painted surfaces are treated as covered work even when the area is small, and any job that uses a prohibited practice loses the exemption. EPA's rule bars open flame burning or torching of painted surfaces, uncontained power sanding, grinding or blasting, and high temperature heat guns above the limit set in the rule. Full repaints of a pre-1978 unit, including exterior scraping before paint, sit well outside minor maintenance.

How does the City of Rochester lead ordinance fit with the EPA rule?

Rochester has its own local lead-based paint ordinance in the City Code, enforced through the rental Certificate of Occupancy inspection rather than by EPA. City inspectors look for deteriorated paint on pre-1978 rental properties, and the remedy is repair work done with lead-safe methods, which puts the federal certification requirement and the local code enforcement requirement on the same job. Requirements differ by address and by the condition found, so ask the City of Rochester inspection and compliance staff what applies to your parcel before you schedule work.

The sequence matters for an owner who turns units over quickly. A failed inspection item on peeling paint can become a repair order with a deadline, and the repair itself is then regulated work. Being certified in advance keeps a code item from turning into a second problem.

What changes if you hire the work out or use an employee?

Hiring out does not remove the requirement, it moves it. Any painter, handyman or contractor you pay to disturb paint in a pre-1978 Rochester rental must be a lead-safe certified firm, and the person running the job site must be a certified renovator. You can verify a company through EPA's search for certified firms rather than taking a logo at face value.

Using your own employee is different again. If the work is done by someone on your payroll, your rental business is the firm performing the renovation, so the firm certification is yours to hold. Workers who are not certified renovators may do the hands-on work only when a certified renovator has trained and directs them, as set out in EPA's rules.

Getting certified before the next turnover

1. Confirm the build year for each property you own, using the Monroe County assessment record or the City of Rochester property record, since the rule turns on pre-1978 construction.
2. Book the initial renovator course with an EPA accredited training provider listed at epa.gov/lead, and keep the certificate the trainer issues.
3. File the firm certification application with EPA for the entity that performs the work, and check the current fee and processing time on EPA's firm certification application page before you plan around a date.
4. Buy the containment and cleanup supplies the rule expects, including plastic sheeting, tape, a HEPA vacuum and verification cloths.
5. Give occupants the required lead hazard information pamphlet before work starts, which EPA publishes as Renovate Right, and keep proof of delivery.
6. Document each job: containment, practices used, cleaning verification and the certified renovator who directed it, then retain the file for the period EPA's rules require.

Separately from any renovation, leasing a pre-1978 unit carries federal disclosure duties. EPA sets out the landlord side of that on its real estate disclosure page, and the disclosure travels with the lease, not with the paint can.

Why this shows up at the closing table

Lead paperwork follows the property. An owner selling a pre-1978 Rochester rental discloses known lead-based paint and hands over the reports and records they hold, and a buyer financing with FHA or VA will have an appraiser looking at paint condition. A clean file of certified work, dust wipe results and city inspection history is easier to sell than a stack of receipts from uncertified labor. The same file makes the next Certificate of Occupancy inspection shorter.

If you are weighing whether to keep doing turnover work yourself, refinance, or sell a pre-1978 rental in the city or the south and southeast suburbs, it helps to look at the numbers and the paperwork together. Schedule a conversation with Khem Kadariya to talk through what your property would bring on the market and what a buyer will ask to see.

Frequently asked questions

Do Rochester NY landlords need EPA lead-safe certification to repaint a pre-1978 rental themselves?

Yes. Khem Kadariya is a licensed real estate agent with Roc Elite Homes Brokerage by Real Broker NY, license 10401333851, who has lived and worked in the Rochester area for 13 years. EPA treats a landlord repainting a pre-1978 rental as work for compensation, so the owner needs firm certification and renovator training. Small repairs that stay under EPA's minor maintenance thresholds are exempt.

How do I check whether a Rochester painter is EPA lead-safe certified?

EPA publishes a searchable list of certified firms, and you can look up a company by name or by location through the agency's locate a certified firm tool at epa.gov/lead. Ask the firm for its EPA firm certification document and for the certified renovator's training certificate, then confirm both are current. A business card that says lead safe is not proof of certification.

Does a pre-1978 rental in Pittsford or Henrietta follow the same rules?

The federal Renovation, Repair and Painting rule applies to pre-1978 rental housing anywhere, so an owner doing paid work on a rental in Pittsford, Brighton, Henrietta or Honeoye Falls is covered the same way as one in the city. What does not follow you out of the city is the City of Rochester lead ordinance and its Certificate of Occupancy lead inspection, which applies to city addresses. For suburban rentals, the Monroe County Department of Public Health is the place to ask about local lead requirements and about your town's rental registration or inspection rules.

How long does EPA certification last, and what happens at renewal?

Both firm certification and individual renovator certification run for a set term and then must be renewed, with renovators taking a refresher course from an EPA accredited training provider before the certificate expires. If a renovator certificate lapses, the person has to retake training before supervising covered work again. Check the current term length, deadlines and fees on EPA's renovation, repair and painting pages at epa.gov/lead before you plan a turnover season.

Do I need lead disclosure paperwork if I never paint anything?

Yes. The federal lead disclosure requirements for pre-1978 housing apply when you lease a unit, regardless of whether any work is done, and they are separate from the renovation rule. You give the tenant the lead hazard information pamphlet, disclose known lead-based paint and any records or reports you hold, and attach the disclosure to the lease. EPA explains the landlord side of this on its real estate disclosure page.

What records does the EPA rule expect a landlord firm to keep?

A certified firm documents that a certified renovator directed the job, that the work area was contained, that prohibited practices were not used, and that cleaning verification was performed, along with proof that occupants received the required pamphlet. Keep the file for each unit and each job, not one folder for the building. EPA's renovation, repair and painting rules pages list the required records and the retention period.