The RRP Rule requires delivery of the “Renovate Right” pamphlet to the owner and occupants of target housing. My firm was hired to perform a renovation in a pre-1978 apartment building. Is delivery of the pamphlet to the property manager sufficient for purposes of delivery to the owner of the building?

Answer: Yes. Property managers are acting in the capacity of agents for the building owners. For this reason, a property manager may receive, and acknowledge receipt of, the lead hazard pamphlet on behalf of the owner. In situations where property managers or their employees are performing the renovations themselves, they are acting both as a “firm performing the renovation” and as agents for the owner. Documents in the possession of an agent are also deemed to be in the possession of the person or entity represented by the agent. Thus, no separate action is required to satisfy the requirement to deliver the “Renovate Right” pamphlet to the owner.

Question Number: 23002-32356

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