Resource — Michigan
Michigan Lead Law — plain-English guide
The federal floor (Title X disclosure, EPA RRP), the Michigan liability layer (PA 434), and the per-county enforcement reality. Written for general contractors, landlords, and real-estate agents working pre-1978 housing in southeast Michigan. Last reviewed May 8, 2026.
By Andrae Washington, JD · EPA RRP Certified Lead Renovator · R-I-99273-26-01409
Need the work done?
ECT runs the EPA piece for $550.
One transaction at booking. The GC keeps the job; we own the lead-safe documentation chain end-to-end.
1. The federal floor
Two federal regulatory regimes apply to every pre-1978 housing transaction or renovation in Michigan. They stack independently — failing one does not relieve the other.
Title X / Section 1018 — Disclosure Rule
Codified at 24 CFR Part 35 and 40 CFR Part 745 Subpart F. Applies to every sale and every lease of housing built before 1978 (excluding zero-bedroom dwellings, foreclosure sales, and certain short-term leases). Sellers, lessors, and their real-estate agents are individually liable. Four obligations:
- Disclose any known lead-based paint or hazards in writing before the contract is signed.
- Provide the EPA pamphlet "Protect Your Family from Lead in Your Home."
- Include EPA's prescribed Lead Warning Statement in the contract or lease.
- Give purchasers (not lessees) a 10-day window to inspect for lead, with the right to waive it in writing.
EPA RRP — Renovation, Repair, and Painting Rule
Codified at 40 CFR Part 745 Subpart E. Applies whenever a renovation in pre-1978 housing or a child-occupied facility disturbs more than 6 square feet of interior painted surface or 20 square feet of exterior, or includes window replacement or demolition (regardless of square footage). Three requirements:
- The firm performing the work must hold an EPA Lead-Safe Certified Firm credential. ECT is NAT-F334542-1 (certified for purposes of TSCA § 402).
- An EPA Certified Renovator must be assigned to the job and on-site or available by phone. ECT's Certified Renovator is Andrae Washington — R-I-99273-26-01409.
- The work must follow EPA work-practice standards: pre-renovation education (Renovate Right pamphlet), containment, prohibited practices avoided, cleaning verification using the standard card test, and three-year recordkeeping per 40 CFR 745.86.
Civil penalties under TSCA § 16 reach up to $47,357 per violation per day at the current inflation-adjusted maximum. Common violations: failing to deliver the pamphlet; using prohibited practices like open-flame burning, high-speed sanding without HEPA shroud, or power-washing exterior painted surfaces; failing to perform cleaning verification.
2. Michigan state law
Michigan does not run its own state-administered RRP program. EPA Region 5 enforces 40 CFR Part 745 directly. What Michigan adds is a liability vector federal disclosure law does not provide.
MCL 333.5475a — Public Act 434 of 1998
Michigan Public Health Code section. The plain-English version: if a landlord knowingly rents a unit with a lead hazard to a family with a child whose blood-lead level is elevated (EBLL), that's a civil violation. Repeat or knowing offenses can escalate to criminal exposure. Local public-health departments (Wayne County Health, Washtenaw County Public Health, Ingham County Health, etc.) have independent inspection authority on EBLL referrals.
PA 434 is why every Michigan landlord with pre-1978 stock should care about lead disclosure even when they're not actively renovating. EBLL findings are typically referred by primary-care providers; the county Health Department inspects the unit, orders repairs on a short timeline, and can refer for prosecution if the owner is uncooperative or has a history of violations.
Practical takeaway: a Michigan landlord can satisfy Title X disclosure on paper and still be exposed under PA 434 if they fail to disclose a known hazard or fail to remediate a cited one. The two regimes work together.
3. Local rules by county
Below is the per-county enforcement reality for ECT's service area. Each county page goes deeper into local health-department contacts, top pre-1978 ZIPs, and any city-level rental-cert programs that stack on top of federal and state law.
Washtenaw County
Ann Arbor · Ypsilanti · Saline · Dexter…
Washtenaw is referral-driven: Public Health acts on elevated blood-lead level (EBLL) findings from primary care providers, then orders the landlord to remediate.
Read the Washtenaw guide →
Wayne County
Detroit · Dearborn · Westland · Livonia…
Wayne County is the densest pre-1978 market in Michigan (≈ 285k units).
Read the Wayne guide →
Ingham County
Lansing · East Lansing · Mason · Williamston…
Ingham is grant-friendly territory: state-capital workforce housing creates a stable rental market with funded rehab opportunities for landlords doing lead-safe work.
Read the Ingham guide →
Jackson County
Jackson · Vandercook Lake
Jackson's pre-1978 housing concentrates downtown.
Read the Jackson guide →
Lenawee County
Adrian · Tecumseh · Hudson
Lenawee is small and underserved — fewer total firms competing for pre-1978 renovation work.
Read the Lenawee guide →
4. Who's responsible for what
One job, three potentially-liable parties. The right framing on paper protects all of them.
| Party | Owns | Exposed to |
|---|---|---|
| Landlord / seller | Title X disclosure on every sale or lease; PA 434 obligation to remediate cited hazards. | Federal civil penalty for non-disclosure; Michigan civil or criminal exposure under PA 434 on EBLL findings. |
| General contractor | Hiring an EPA Lead-Safe Certified Firm for any RRP-triggered portion; ensuring Renovate Right pamphlet is delivered; keeping records. | EPA civil penalty if the firm hired isn't actually certified or if work-practice violations occur on the job. |
| EPA Lead-Safe Certified Firm (ECT) | Containment, certified-renovator on-site, lead-safe work practices, cleaning verification card test, three-year recordkeeping. We run the federal documentation chain end-to-end. | EPA civil penalty for any work-practice violation on a job we performed; firm-certification suspension or revocation. |
ECT operates as the certified firm for the GC's job. The GC keeps the customer relationship and the project; we narrow the GC's federal risk surface to procurement (hire a certified firm) and recordkeeping (we deliver the records).
5. Recordkeeping minimums
EPA RRP requires three years of retention from the date the renovation was completed (40 CFR 745.86). The records include: the signed Renovate Right acknowledgment, certified renovator name and credential, dates and location of work, containment and cleaning verification documentation, and any additional documentation produced under the rule.
ECT's customer-facing retention promise is 39 months — three years (the federal floor) plus a 90-day grace window. The compliance packet PDF is delivered within 24 hours of job completion and the underlying Drive folder stays accessible to the GC for the full 39 months. After that the folder is automatically locked; we keep an internal copy through the statute-of-limitations window.
Title X disclosure records (the signed Lead Warning Statement + disclosure form) must also be kept for three years from the date of the sale or lease. That's the landlord's or seller's obligation, not ECT's — but ECT's compliance packet for renovation work feeds into the same retention story for the property.
FAQ
Common questions GCs and landlords ask before booking. If yours isn't here, call (734) 274-9091.
When does federal EPA RRP apply to my renovation in Michigan?
If the home (or child-occupied facility) was built before 1978 and the renovation will disturb more than six square feet of interior painted surface or more than twenty square feet of exterior painted surface — or includes window replacement or demolition — EPA's Renovation, Repair, and Painting Rule (40 CFR Part 745 Subpart E) applies. The work must be performed by an EPA Lead-Safe Certified Firm using EPA Certified Renovators and lead-safe work practices. Civil penalties run up to $47,357 per violation per day per the inflation-adjusted EPA enforcement schedule.
Does Michigan have its own RRP program separate from federal EPA?
No. Michigan does not administer its own state RRP program — federal EPA Region 5 enforces 40 CFR Part 745 directly in Michigan. There is no Michigan analog to Philadelphia's Chapter 6-800 lead-safe certification mandate for rental units. The federal rules are the floor; Michigan adds liability on top via PA 434 / MCL 333.5475a (see below).
What does Michigan's PA 434 / MCL 333.5475a actually do?
It makes it a civil violation — and for repeat or knowing offenses, a criminal one — for a landlord to knowingly rent a unit with a lead hazard to a family with a child whose blood-lead level is elevated (EBLL). Local public health departments (Wayne, Washtenaw, Ingham, etc.) have inspection authority. PA 434 is the enforcement teeth that federal Title X disclosure does not provide. It applies regardless of whether your renovation triggers federal RRP.
What is the Title X disclosure obligation when I sell or lease a pre-1978 home?
Title X / Section 1018 (24 CFR Part 35 + 40 CFR Part 745 Subpart F) requires four things on every sale and every lease of pre-1978 housing: (1) disclose any known lead-based paint or hazards in writing, (2) provide the EPA 'Protect Your Family from Lead in Your Home' pamphlet, (3) include the Lead Warning Statement in the sale contract or lease, (4) give buyers a 10-day window to inspect for lead. Sellers, lessors, and their agents are all individually liable. Records must be kept for at least three years.
What is the Renovate Right pamphlet and when does it have to change hands?
Renovate Right is the EPA-required pre-renovation pamphlet a contractor must deliver to occupants before any RRP-triggered work begins. The contractor (or, more typically, the EPA Lead-Safe Certified Firm performing the lead-impact piece — that's ECT for the GCs we work with) collects a signed acknowledgment from the occupant. The acknowledgment goes into the compliance packet kept for at least three years per 40 CFR 745.86.
Does my city or county add rules on top of federal and Michigan state law?
Often, yes — and it varies. Detroit BSEED runs a Certificate of Compliance program for rentals; Ann Arbor inspects rentals every 30 months for habitability (deteriorated paint is a code item but lead is not specifically tested); Ypsilanti runs its own rental cert program. Outside those, lead-paint enforcement is largely referral-driven on EBLL findings via the county health department. See the per-county pages below for specifics.
How long do RRP records have to be retained?
EPA requires three years from the date the renovation was completed (40 CFR 745.86). ECT keeps your job folder accessible for 39 months — three years plus a 90-day grace window so you have time to download and migrate your copy before automatic lock.
Who is liable when something goes wrong — the GC, the certified firm, or both?
Both, depending on the violation. The Firm Certification covers the firm doing the lead-impact piece (ECT). The Certified Renovator on-site is individually credentialed (Andrae). The GC is liable for hiring an uncertified firm, for failure to deliver the Renovate Right pamphlet if they retain that obligation, and under MCL 333.5475a for landlord-side EBLL exposure. ECT operates the federal documentation chain end-to-end so the GC's risk surface narrows to procurement (hire a certified firm) and payment (pay the GC's own portion).
Need the lead-impact piece handled?
ECT is the EPA Lead-Safe Certified Firm. $550 flat, captured at booking, packet delivered within 24 hours of job completion.
Not legal advice
Andrae Washington, JD (EPA RRP Certified Lead Renovator R-I-99273-26-01409) authored this post. Andrae Washington holds a JD, but ECT is not a law firm and does not practice law. This page is general guidance current as of May 8, 2026, not legal advice for your specific situation. For decisions that turn on the facts of your sale, lease, renovation, or rental dispute, consult a licensed Michigan attorney.
For lead-paint questions, EPA-required pamphlets, certified-firm verification, or to report a suspected violation, call EPA's National Lead Information Center at 1-800-424-LEAD (5323).