EPA RRP Rule: Value in using time cards to demonstrate RRP compliance

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Contractors who have made the decision to embrace the new EPA RRP Rule requirements can gain two benefits from creating a system to track time required to perform EPA RRP-related tasks.

First, to price a job, it's important to understand the difference (as measured by employee labor hours) between replacing a window on an RRP Rule job compared with replacing a similar window on a non-RRP Rule job. For example, requiring workers to log time spent on RRP-specific activities such as setup (including taping), removal, and cleanup (including disposal and testing) will provide valuable information for estimating and pricing purposes,

Second, collecting information on time spent on RRP Rule-related tasks can help prove that the right personnel were present at the right time on an RRP targeted project. Other than running a webcam at the jobsite (a potential can of worms!), what better way to prove that your certified renovator was present to supervise during designated times than by providing an auditor with time-based reports designed to demonstrate your compliance?

The challenge will be to set up your time tracking system so it's easy to use and (more importantly) will easily generate the reports that will support you in the face of an audit. The EPA isn't going to hang out at your jobsite; if they go after you, they'll get you in your office. The more detailed and compelling the reports you provide, the more competent and professional you'll look. The more professional you look, the less likely they'll be to nitpick.

Note:  This information was contributed by Melanie Hodgdon of Business Systems Management.