Why IRC Practices are Required in Vermont

Lead is a highly toxic metal that was commonly used in paint, stain and varnish in homes built before 1978. Dust from lead-based paint is the major source of lead poisoning among children. 

There is no safe level of lead in the body. Too much lead, or lead poisoning, can cause serious and permanent health problems for anyone. Babies, young children and pregnant people are at special risk. Lead poisoning can be prevented.

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To help prevent lead poisoning, Vermont law requires owners of rental housing and child care facilities built before 1978 to perform Inspection, Repair and Cleaning (IRC) Practices each year

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What are IRC Practices?

IRC Practices are required for rental housing and child care facilities built before 1978. Each year an IRC-certified person must:

  • Inspect for chipping and peeling paint or coatings, and pick up any paint chips from the grounds of the property.
  • Block access immediately to any areas that need paint repair.
  • Have repairs done by Lead-Safe RRPM licensed workers within 30 days of finding out about them.
  • Install window well inserts in all pre-1978 wooden sash windows.
  • Perform a specialized cleaning in common areas and when there is a new tenant.
  • Give the Protect Your Family from Lead in Your Home pamphlet to new tenants.
  • Post a notice in a prominent place in either a common area or in each unit that asks occupants to promptly report deteriorated paint to the owner of the building.
  • File an annual compliance statement after the work is completed.
  • Give a copy of the compliance statement within 10 days of filing it to:
    • Your tenants and insurance carrier, if you are a rental housing owner.
    • The Department for Children and Families, if you are a child care provider. 

Step-by-Step Guide: How to Comply with IRC Practices

Step 1: Become IRC Practices certified or hire someone who is

Only a certified person can perform IRC Practices on your property. We recommend that all rental property and child care owners or managers become certified. 

IRC Practices certification is valid for five years. You must retake the training after the expiration date on your previous training certification to renew your IRC certification.

How to become IRC Practices certified:

  • Take a Health Department-approved IRC Practices training online or in person. The training and test take about three hours to complete.
  • Pass the test with a score of 70% or higher.
  • Get your certificate via email within two weeks of the training date.

Once certified, you can perform the IRC Practices for your rental property or child care facility.

Sign up for a training

How to hire someone to perform IRC Practices:

  • Look for a Vermont-licensed Lead-Safe RRPM Firm.

Find a Lead-Safe RRPM Firm

Step 2: Perform IRC Practices each year
  • Inspect the painted and stained surfaces at the property, both inside and outside.
  • For any areas that need paint repair:
    • Immediately block access to the area.
    • Complete the repair within 30 days of finding out about it.
    • If the area is greater than 1 square foot per interior room or exterior side of a building, the repair can only be made by a Lead-Safe RRPM licensed worker. Find out what you need to do in Step 3.
  • Verify that all pre-1978 wooden sash windows with window wells or troughs have window well inserts.
  • Remove any visible paint chips on the ground outside the building.
  • Perform a specialized cleaning at tenant turnover and annually in common areas.
  • Prominently post a notice for building occupants in the common area or in each unit for them to report chipping or damaged paint.

If you are a landlord or property management company, you are also required to give your tenants this information before their lease starts:

Step 3: Make sure lead-safe repairs are made

If you find chipping or peeling paint or stain that is more than 1 square foot total per interior room or exterior side of the building, a Lead-Safe RRPM licensed worker must make the repairs.

  • If you hire a contractor, they must have the Vermont Lead-Safe Renovation, Repair, Painting and Maintenance (RRPM) Firm and Supervisor licenses. Find a contractor

  • If you are a landlord, you can do the work yourself if you have a Lead-Safe RRPM Firm – Landlord license or the RRPM Firm and Supervisor licenses. Find out how to get licensed

  • If you are a child care provider, you can apply for an Uncompensated Child Care Operator (UCCO) certificate to do repairs work at your facility only. Find out how to get certified

Step 4: File your annual IRC Practices Compliance Statement

After you have inspected your property and made any repairs, you need to file a compliance statement through the Health Department’s online system. Read the step-by-step instructions and frequently asked questions about how to file your compliance statement. 

If you are a rental housing owner, give a copy of the IRC Practices compliance statement to your tenants and insurance carrier. 

If you are a child care provider, post a copy in a visible location in your facility and give a copy to your insurance carrier.

Step 5: Stay in compliance

Vermont law requires you to perform IRC Practices and file a compliance statement each year. You may be fined if you do not file a compliance statement, or if you file a false statement. To avoid fines, make sure you are honest when you file your statement and file it on time. 

If you need more time to make repairs, you can request an extension

If you receive an IRC Practices enforcement notice, fill out the Response to Enforcement Notice Form.

FAQs for Landlords/Property Management Companies and Child Care Providers

I need to request an extension for my IRC Practices. What do I need to do?

If you need to make repairs and can’t meet the filing deadline, you must request an extension.

To request an extension, fill out the IRC Practices Filing Extension Request Form. Once the repair work is done, you can file your IRC Practices compliance statement. 

There are two types of extensions:

  • 30-day extension: for IRC Practices inspections, specialized cleaning, window well insert installation, interior repairs, and exterior repairs during the warmer months.
  • Up to six-month extension: for exterior repairs if you find deteriorated paint or stain during the winter. 

You must immediately block access to the deteriorated area (whether it is inside or outside) until repairs are made. The access must be blocked with a physical barrier, for example, putting up a fence around the area or stapling plastic over the area. Make sure you do not block access to exits needed for safety.

I’m doing renovation or repair work that will disturb lead-based paint. What do I need to do?

Only a Lead-Safe RRPM licensed person can do renovation, repair and painting work that will disturb an area greater than 1 square foot per room or exterior side of the building. The type of work that requires these licenses includes (but is not limited to) painting, carpentry, electrical, plumbing, weatherization and window replacement work. 

  • If you hire a contractor, they must have the Vermont Lead-Safe Renovation, Repair, Painting and Maintenance (RRPM) Firm and Supervisor licenses. Find a contractor

  • If you are a landlord, you can do the work yourself if you have a Lead-Safe RRPM Firm – Landlord license. Find out how to get licensed

  • If you are a child care provider, you can apply for an Uncompensated Child Care Operator (UCCO) certificate to perform work on your child care facility only. Find out how to get certified

What are lead-safe work practices? What types of work practices are prohibited?

Lead-Safe Work Practices 

  • Limiting access to work areas
  • Enclosing the work area with plastic sheeting
  • Wearing protective clothing
  • Using water to dampen painted surfaces or debris before disturbing them
  • Avoiding practices that create dust
  • Keeping lead dust in the work area
  • Cleaning up the area once work is done

Find more information on required lead-safe work practices.

Prohibited Practices

Under the law, the following practices are not allowed to be used:

  • Dry scraping or sanding
  • Use of power tools
  • Using chemical strippers
  • Open flame burning or torching
  • Heat guns operating above 1100°F
  • Hydroblasting or high pressure washing
  • Abrasive blasting or sandblasting
What should I do if I’ve sold my property or and longer rent it?

If you no longer rent your property, use it as a child care facility, or have since sold your property, please fill out the Change in IRC Practices Filing Status Form to ask to be exempt from filing. 

Is there any financial assistance available?

The Vermont Housing & Conservation Board’s Lead-Based Paint Program provides financial and technical assistance to income-eligible landlords and property owners to reduce the risk of lead poisoning caused by lead-based paint hazards. Call 802-828-5064 or 800-290-0527 or email [email protected].

If your property is in Burlington or Winooski, the Burlington Lead Program of the City of Burlington provides similar assistance. Call 802-865-LEAD (5323).

More Resources
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Lead Hazards and Lead Poisoning
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Document or PDF
Vermont Lead Poisoning Prevention Law
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