L.A. County Update: Rental Housing Habitability Program (RHHP)--Be Ready!

L.A. County Update: Rental Housing Habitability Program (RHHP)--Be Ready!

Inspections Are Coming for Unincorporated Los Angeles County Owners: How to Prepare and Pass on the First Visit

By Nathan Sewell, Building Inspector

[Editor’s Note: On April 23, 2024, the Los Angeles County Board of Supervisors enacted two ordinances, Chapter 8.53 and 8.55 of the Los Angeles County Code. These ordinances established a rental housing inspection program in the unincorporated areas of Los Angeles County. The name of the new program is the Rental Housing Habitability Program (RHHP). RHHP purportedly aims to ensure rental units meet habitability standards, support property values, and provide safe living conditions.]

If your property is in unincorporated Los Angeles County—East Los Angeles, Altadena, Lennox, Florence-Firestone, Hacienda Heights—you're now subject to the Rental Housing Habitability Program (RHHP), even if your mailing address says "Los Angeles" or "Pasadena." The boundaries are confusing—you can have a Los Angeles address and still be outside Los Angeles City limits. This new inspection program isn't the same as the City's Systematic Code Enforcement Program (SCEP). RHHP is the County's new inspection program covering nearly 100,000 rental units with a mandatory four-year inspection cycle. The RHHP was launched last November, and correction timelines are tighter than most property owners expect.

This article provides general information about building conditions and inspection procedures and is not legal advice. Property owners should consult qualified legal counsel regarding specific enforcement actions.

• Hot water below 110°F. Inspectors test water temperature at fixtures with thermometers. Water must reach at least 110°F. If most units fail, that's Unit Critical. I've walked countless older buildings where half the units barely hit 100 degrees, usually sediment buildup in the tank or a dying recirculation pump. This is one of the easiest violations to fix during your 30-day preparation window.

• Bathroom fans venting into attics. This surprises landlords every time. Every bathroom needs an operable window or a fan venting to the exterior—not into the attic crawlspace. I've inspected dozens of properties where 1970s-era fans dump humid air straight into the attic. That moisture causes mold and rots the roof deck. Automatic Unit Critical violation.

• Peeling paint in pre-1978 buildings. If your building was built before 1978, peeling paint isn't cosmetic—it's a potential lead hazard. Unit Critical if a child lives there or the paint shows "web" cracking. You need EPA-certified lead-safe work practices, not your regular handyman.

• Window safety issues. Every bedroom needs an operable window for emergency exit. Painted shut doesn't count—that's Unit Critical. Floor-to-ceiling windows on upper floors need fall prevention bars. I see this constantly in mid-century buildings. “No barrier? Premises Critical.”

• Live cockroach infestations. Unit Critical. But inspectors aren't just checking if you called an exterminator. They want evidence of Integrated Pest Management, which requires sealing entry points and fixing what attracts infestation.
• Structural damage. Roof leaks, sagging joists, and deteriorated stairs are Premises Critical. Inspectors refer these to Building and Safety, meaning you're dealing with two County departments. For buildings with 3+ units, damaged balconies can also trigger Senate Bill 721 (balcony and elevated exterior element) inspections. One problem often snowballs fast.

What Inspectors Actually Highlight

The County splits violations into "Unit Critical" (individual units) and "Premises Critical" (common areas). Unlike some inspection programs that sample rental units, RHHP inspectors evaluate every occupied unit and all common areas in your property.

Here's what gets cited most often:

Two Different Clocks.

About 30 days before inspection, owners will receive a Notice of Routine Inspection. You must post the notice within 24 hours and give tenants 24-hour entry notice. This 30-day window is your opportunity—walk your property and fix obvious problems before they become official record. I've seen landlords catch five- or six-Unit Critical violations during this window that would have otherwise been cited. Then, after the inspection, if violations are found, owners are given 21 days to correct them (not 30 like the City typically allows…just twenty-one days).

The Permit Trap is real.

Certain repairs—water heaters, major plumbing, structural work, electrical upgrades—require building permits. Here's the problem: permits often take three weeks just to process. And the 21-day compliance clock doesn't stop while you wait.

Property owners can request a 30-day extension, but extensions are discretionary and require "substantial progress." In my experience, "I called a contractor" doesn't meet that standard. The winning strategy? During the 30-day pre-inspection window, identify anything requiring a permit and file before the inspector arrives. Then you're just executing work and not racing against an impossible deadline. If you miss the correction deadline, then you will face re-inspection fees. Keep missing it? The County can refer your property to REAP—the Rent Escrow Account Program—where tenants pay rent into a County-managed account instead of to you.

 The Cooling Mandate Is Coming.

While not technically part of RHHP, LA County has passed a separate ordinance requiring rentals to maintain indoor temperatures at or below 82°F. This requirement will be evaluated during RHHP inspections starting in 2025 and fully enforced by 2027:

• September 12, 2025: Tenants gain the legal right to install portable air conditioning units. Landlords cannot prohibit safe installations.
• January 1, 2027: The cooling mandate takes full effect. Landlords must ensure rental units can maintain a maximum indoor air temperature of 82°F for all habitable rooms, except small owners (see below)
• January 1, 2032: Small owners (10 units or fewer) get extended time but must cool at least one room by 2027.

Here's my concern about older buildings: most built before 1980 were not wired for multiple air conditioning units running simultaneously. Starting this September, if five tenants install window units and your main panel starts tripping breakers every afternoon, that's an immediate electrical habitability violation. Assess your electrical capacity now—not in 2026 when it's an emergency.

The RHHP is funded by an $86-per-unit annual fee via property tax. You can pass through half the cost ($43 per year, about $3.58 per month) to your tenants. That's manageable. What's not manageable is failing inspection—re-inspection fees you can't pass through, potential REAP placement freezing your income, and expensive emergency repairs on compressed timelines. Landlords who are successful in passing on the first inspection are ones who treat the 30-day notice seriously. They walk properties, fix Unit Critical items, and often bring in an inspector for a pre-inspection audit to know exactly what the County will find before it goes on record.

About the Author

Nathan Sewell is a building inspector specializing in RHHP preparation inspections for rental properties in Los Angeles County. With expertise in building code compliance and building systems he helps property owners identify code violations and habitability issues before County inspections occur. For more information about RHHP preparation audits and compliance consulting, visit labuildinginspections.com or call (626) 214-5929.

Important Disclaimer: The information and materials provided during this presentation is for general information purposes only. Absolutely no legal or tax advice is being given during this presentation. Keep in mind that every situation is unique, and the laws, rules and regulations are subject to change at any time. So, before acting, be sure to obtain tax and/or legal advice from your licensed professional.