Painting a Two- or Three-Family House in MA: Tenants, Lead & Timing

Painting a two- or three-family house in Massachusetts takes more planning than a single-family job because other people live in it. If the building was built before 1978, the contractor must give the owner and an adult in each affected unit the EPA's Renovate Right pamphlet before paint-disturbing work begins, post or deliver notices for common areas, and work lead-safe. On top of that, you have to schedule around tenants, phase the exterior, and put access, parking and pets in writing.

Why multi-family painting is different

A "triple-decker" or side-by-side two-family is one building with several households, and those households work, sleep, park and raise kids on different schedules. The paint job itself is much like any other exterior: scrape, prep, prime, caulk, two finish coats. What changes is everything around the work:

• More people to inform. Every unit where paint will be disturbed, and every unit that shares a common area being worked on, has rights to information.
• Shared access points. Front porches, back stairs, shared hallways and driveways are often the only way in and out for a unit. You can't just block them for a week.
• Older buildings. A large share of Massachusetts multi-family housing is old. In Worcester, for example, about 77% of homes were built before 1980, according to the US Census Bureau's American Community Survey (2023). Pre-1978 paint brings federal and state lead rules into play.
• Owner vs. tenant expectations. The owner is paying and makes the decisions, but the tenants live with the noise, ladders and dust. A job goes smoothly when both sides know the plan.

The lead-safe rules that apply to the painting work

Federal RRP rule, run by the state in Massachusetts

The EPA's Renovation, Repair and Painting (RRP) rule covers paid work that disturbs painted surfaces in housing built before 1978. Massachusetts is one of the states authorized by the EPA to run its own program. Here it is administered by the Department of Labor Standards under 454 CMR 22.00. According to mass.gov's guidance for homeowners, paid work in pre-1978 housing that disturbs more than 6 square feet of painted surface per room inside, or more than 20 square feet outside, must be done by a licensed lead-safe renovation contractor. Scraping and sanding the exterior of a whole house is far over that threshold.

Pre-renovation education: the Renovate Right pamphlet

Under the federal rule (40 CFR 745.84), no more than 60 days before work begins, the firm doing the work must:

• give the owner the Renovate Right pamphlet and get a written acknowledgment that they received it;
• if the owner doesn't live in the unit being worked on, give the pamphlet to an adult occupant of that unit and get a written acknowledgment. If nobody will sign, the firm can instead certify in writing that it delivered the pamphlet.

In an owner-occupied two-family, that means the owner signs for their own unit and an adult tenant signs for the rental unit. In a three-family where the owner lives elsewhere, the firm needs a signed acknowledgment or a delivery certification for each occupied unit where work happens.

Common areas: hallways, stairs, porches

Shared spaces in a multi-family building are "common areas." For work there, EPA's guidance for renters says the firm must either hand renovation notices to tenants or post informational signs. The notice describes what work is planned and where, the expected start and end dates, and how occupants can get the pamphlet for free. EPA publishes a sample renovation notice that many firms use. The owner also gets the pamphlet for common-area work. Under 40 CFR 745.84(b), if the firm gave written notices and the scope, location or dates then change, it must send updated written notice before starting the additional work.

What lead-safe work looks like on site

For tenants, lead-safe practice shows up as plastic sheeting on the ground around the house, warning signs, closed windows near the work area, and daily cleanup of paint chips. Ask your contractor how they will contain debris near shared entrances and play areas, and how the site will be left at the end of each day.

Painting is not deleading: the Massachusetts Lead Law

This is where owners often get confused, so it's worth being precise. The Massachusetts Lead Law is a separate rule from RRP. In general terms, when a child under 6 lives in a home built before 1978, the owner is responsible for having lead hazards corrected, either through full deleading or through interim control (a temporary step that must later be followed by full compliance). The law also bars landlords from refusing to rent to families with young children because of lead paint.

Key distinctions:

• A lead-safe painting job is not deleading. Repainting a house, even carefully and by a licensed lead-safe renovation contractor, does not produce a Letter of Compliance.
• Deleading is its own trade. High-risk deleading work has to be done by a licensed deleader. Some lower-risk tasks can be done by owners or their agents only after specific training and a lead inspection. A painting contractor's RRP license does not cover deleading.
• Compliance starts with an inspection. A licensed lead inspector or risk assessor determines what must be corrected. The Department of Public Health's Childhood Lead Poisoning Prevention Program administers the compliance side.
• Tenant notification is separate, too. Before renting pre-1978 housing, Massachusetts landlords must give new tenants the Tenant Lead Law Notification and Certification form, along with any lead inspection report or letter of compliance they have. This is part of renting the unit, not part of the paint job.

If a child under 6 lives in the building and you don't have a current letter of compliance, talk to a licensed lead inspector before you plan an exterior repaint. It may make sense to coordinate the deleading and the painting so you don't pay twice to prep the same trim. When the details are unclear, the mass.gov Lead Law pages and your local board of health are the right place to ask.

Staging on porches and back stairs

Stacked porches and exterior back stairs are the signature of Massachusetts multi-family housing, and they are the hardest part of the job to schedule. They are often a unit's second exit, so treat them with care:

• Never block a required exit without a plan. Agree in advance on which stair stays open each day. When a stair must be closed for painting or drying, tell the affected unit and give them a time window.
• Paint stairs in halves or in sequence. Doing every other tread, or one side of the handrail at a time, keeps a stair usable while coatings dry.
• Stage ladders and planks so they don't cross doorways. Staging on upper porches may need to be anchored away from sliding doors and windows that tenants use for air.
• Inspect before you paint. Soft decking, loose balusters or rotted stringers are a safety issue, not a cosmetic one. Structural repairs to porches and stairs can require a permit and a licensed builder. Check with your town's building department before anyone touches the framing.

How to phase the exterior work

Most two- and three-family exteriors are done one elevation at a time. A typical sequence looks like this:

1. Walkthrough and notices. Owner, contractor and ideally a tenant from each unit walk the building. Pamphlets and acknowledgments are handled, and common-area notices go up.
2. Carpentry and repairs first. Rotted trim, sills and clapboards get fixed before painting so tenants aren't disturbed twice.
3. One side at a time. Contain, scrape, prep, prime and paint one elevation before moving on. That limits how many windows are affected at once.
4. Porches and stairs last, in sections. This keeps exits usable for most of the job.
5. Final cleanup and walkthrough. Check the ground, porches and window sills for debris, and confirm with each unit that screens, air conditioners and outdoor items are back in place.

Weather matters here. Exterior paint needs dry surfaces and temperatures within the manufacturer's range, so leave room in your tenant notices for rain delays rather than promising exact dates.

Scheduling around tenants

Tenants cooperate more when they hear about the job early. Tell them a few weeks ahead, then confirm dates once the schedule is firm and the weather looks cooperative.

Interior common areas

Painting a shared front hall or stairwell is usually a smaller job, but it affects everyone's way in. Pick low-odor, quick-drying coatings, paint handrails and stair treads in sections, and schedule work for hours when most tenants are out. In a pre-1978 building, the same lead-safe rules apply inside: containment, no open-flame burning or power sanding without HEPA dust controls, and thorough cleanup at the end of each day. The common-area notice or signs apply even if the work is only in the hallway.

What landlords should put in writing

A clear written agreement protects the owner, the tenants and the contractor. Before the job starts, make sure you have:

• A written contract with the contractor that describes the scope (which elevations, porches, stairs, common areas), the prep and product, the schedule, and the payment terms. If you live in the building, it is an owner-occupied home with one to four units, and Massachusetts home improvement contractor rules generally apply: the contractor should be registered, and the contract should be in writing. Even when the owner lives elsewhere, get the same level of detail in writing.
• Proof of lead-safe renovation licensing for pre-1978 buildings, plus the pamphlet acknowledgments or delivery certifications for each unit, and copies of common-area notices.
• A tenant notice with dates, work hours, which exits stay open, parking changes, what tenants need to move, and who to call.
• Your lead paperwork, kept separately: tenant lead law notification forms, any inspection reports, and any letter of compliance or interim control.
• A change log. A short record of schedule changes and updated notices, in case questions come up later.

How A&M Painter Inc. handles multi-family jobs

A&M Painter Inc. is a family-owned painting contractor based in Hudson, working since 2020 across central and eastern Massachusetts. We are a registered home improvement contractor (HIC #207214) and a lead-safe (RRP) certified firm, and we plan multi-family exteriors elevation by elevation with notices handled up front. We don't do deleading or structural framing; when a job needs those, we say so and point you to a licensed professional. If you own a two- or three-family, we'll walk the building and give you a free written estimate.