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.