Philadelphia Lead Safe Law and newborns

[PJ M.]

Looking for come clarification on the Philadelphia Lead Safe requirement.  Everything I read online speaks of requiring the certification/exemption at lease turnover.  What if a couple has a child during the term of the lease and continues to live there with the lease auto-renewing?  Is no certification required since there is no turnover?

https://www.phila.gov/media/20181109120607/LandlordGuidance_2018.pdf

Here's the unique situation.  I have tenants that live in one of my properties that moved in prior to 12/21/12.  Yes, I've been lucky enough to have them there for almost a decade.  They recently had a baby.  As I am reading the law, I don't have to get the place inspected for a lead safe certification or file an exemption form since there hasn't been a turnover.  Anyone else have experience with this?  I'm pretty sure the place would pass a lead wipe test, just looking for opinions.  I like to err on the side of caution and this is one of those things where if I have to do nothing I'd rather just keep off the radar of the city.

[Kevin M.]

@Steve Babiak is right. Even if you don't have to do it by the letter of the law today, the new lead law will require you to do it sometime in the next few years anyway. 

Might as well get ahead of the curve in case for whatever reason you would need to go in front of a judge- OR more importantly, if your place does in fact pose a lead danger so you can do the right thing and address to take care of your little baby tenant!