All owners and managers must complete Essential Maintenance Practices (EMP) in rental housing built prior to 1978 to reduce the risk of lead poisoning in resident children. Vermont law requires submission of an annual Compliance Statement to the Vermont Department of Health by owners and managers.

The Vermont Department of Health has enforced EMP and assessed fees to those that are out of compliance. To help ensure our rental properties comply with EMP, VHFA confirms Compliance Statements have been submitted while performing onsite physical inspections and file reviews. Please be prepared to show evidence of compliance.

How to comply with Essential Maintenance Practices

  • Complete approved EMP training
  • Annually submit Compliance Statement(s) to the Vermont Department of Health
  • Conduct visually inspection for deteriorated paint annually and at unit turnover
  • Advise tenants through a posted flyer to promptly report deteriorated paint
  • Repair deteriorated paint within 30 days using safe practices
  • Remove visible paint chips from property exterior
  • Use lead safe work practices any time more than 1 square foot of paint is disturbed
  • Install window well inserts where appropriate
  • Conduct specialized cleaning at unit turnover and after any work
  • Provide tenants with information about lead paint, including completed Compliance Statements

The EPA's Renovation, Repair and Painting Rule applies to any activity that disturbs more than 6 square feet of paint on interior surfaces, or more than 20 square feet on exterior surfaces.


  • Properties built after January 1, 1978
  • Properties determined to be lead-free by a licensed lead paint inspector
  • 0-bedroom dwellings including studios, efficiencies, dormitories, boarding houses, etc.
  • Projects reserved for the exclusive use of the elderly or persons with disabilities, unless the household includes a child six years of age or younger.
  • Hotels, motels and other lodging rented for 30 days or less.
  • Renting a single room located within a larger dwelling (i.e. boarder).

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