Exterior lead paint

[Lori Edelman]

I bought a duplex in Saginaw, MI and out of an abundance of caution (tenant safety is my utmost priority) , I conducted a lead test which showed that some window frame paint samples inside the house had lead paint. My now former property manager agreed to encapsulate “all windows” as part of getting the home rent ready. 

Fast forward over a year later and I have switched to a better property manager. When issuing a new lease to the current tenants we disclosed the lead test and encapsulation. Apparently my old property manager didn’t properly disclose because now the tenants are worried about the exterior window frames and want them encapsulated because the paint on them is chipping. 

In the absence of any lead testing or report on the exterior windows, what do I do? Do I get a test for lead on the exterior windows or just go ahead and encapsulate them? Am I even required to do any encapsulation or remediation on exterior lead paint? Do I ask my former property manager for the $750 that it will cost to encapsulate the exterior windows since they failed to “encapsulate all windows” or identify/address them? I’ve already spent a small fortune and a lot of time and effort fixing all of the former PM’s mistakes so this is just icing on the cake. My new PM is concerned that the tenants will conduct a lead test on exterior windows paint themselves if we don’t but I wonder if we wait until if/when they do so. They have two disabled kids in their 20s and are claiming that this is why exterior lead remediation is so important.