---
title: New EPA RRP Requirements Take Affect on July 6th, 2010
description: There has been a lot of confusion regarding the recent announcements delays amendments and proposed amendments related to the EPA RRP Rule
image: https://www.shawnmccadden.com/hs-fs/file-15739107-jpg/images/confused_contractor-wr.jpg
---

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# Welcome to RRPedia Your Interactive Resource for EPA RRP Information

## ![RRPedia logo](https://www.shawnmccadden.com/hs-fs/file-1549005086-jpg/images/RRPedia_Logosmall_-wr-1.jpg)Looking for accurate information about the EPA RRP rule?

RRPedia has been created by Shawn McCadden to help remodelers and others affected by the New EPA Renovation Repair and Painting Rule. 

## Please read *[RRPedia Use and Contribution Information](https://www.shawnmccadden.com/using-and-contributing-to-rrpedia-/) *before using or contributing to RRPedia.

 

---

# You Can Browse For RRP Topics By Using The Tags List To The Right

## [New EPA RRP Requirements Take Affect on July 6th, 2010](https://www.shawnmccadden.com/rrpedia/bid/42791/New-EPA-RRP-Requirements-Take-Affect-on-July-6th-2010)

Posted by [Shawn McCadden](https://www.shawnmccadden.com/rrpedia/author/shawn-mccadden) on Fri, Jul 02, 2010 @ 08:56 AM

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![Confused remodeler](https://www.shawnmccadden.com/hs-fs/file-15739107-jpg/images/confused_contractor-wr.jpg)

 

#### There has been a lot of confusion regarding the recent announcements, delays, amendments and proposed amendments related to the EPA RRP Rule.  Many of these are explained and clarified in several articles that can be found here on this RRPedia page under the tag heading of ["EPA RRP Rule Updates"](https://www.shawnmccadden.com/rrpedia/?Tag=EPA+RRP+Rule+Updates) found in the blue box on the right side of this web page. 

#### For additional RRPedia postings and updates, be sure to subscribe to this page to receive e-mail notifications of new postings as they happen.

#### This article is intended to remind you of a variety of new considerations that take effect on July 6th, 2010 due to the [Amendment to the Opt-out and Recordkeeping Provisions](https://www.shawnmccadden.com/Default.aspx?app=LeadgenDownload&shortpath=docs%2fEPA+Amendment+to+the+Opt-out+and+recording+keeping+provisions.pdf) in the Renovation, Repair, and Painting Program [RIN 2070-AJ55]. 

#### Below are considerations you should be aware of and be prepared for.  I have also provided some suggestions to help you. None of this information should be considered as all inclusive and or as legal advice.  I recommend you qualify and seek additional legal advice about this information from qualified legal counsel.  Contractors should also have any documentation they use to comply with the RRP Rule reviewed by legal counsel prior to use.

#### For clarification, the [June 18, 2010 memo](https://www.shawnmccadden.com/Default.aspx?app=LeadgenDownload&shortpath=docs%2fJune+18+2010+Memo+-EPA+delay+in+enforcement+of+RRP+certifications.pdf) delaying enforcement of certain certification requirements does not have any effect on these new considerations:

 

#### 1. As of July 6th, the home owner opt-out provision will no longer be available for use on RRP covered renovations.

- **a. Even if the contract for the work was signed prior to July 6th and/or the project has already been started, the RRP Rule work practices and documentation requirements must be followed starting July 6th**
- **b. If, before midnight on July 5th, you can complete any work or demolition that disturbs painted surfaces on projects where you already had a signed opt-out from the homeowner, I suggest you do so to avoid the additional costs to comply and/or the risks associated with operating in violation of the RRP Rule. **
- **c. As I have stated in other articles here on RRPedia, a signed opt-out would still not relieve you from potential liability should the work you do and/or how you do it causes lead contamination and/or lead poisoning. **
- **![Cleaning verification card](https://www.shawnmccadden.com/hs-fs/file-15742244-jpg/images/cvc-wr.jpg)d. As an extra level of protection for you, your business, your employees, your customer and/or the occupants of the space you are renovating; if you plan to use the strategy suggested in item "1b" above, I suggest you still do the post renovation cleaning and cleaning verification procedure as required under the RRP Rule before restarting work again on July 6th.**
- **e. Beginning July 6th, 2010, as long as the work you do does not disturb any painted surfaces, you can precede using traditional work practices.**
- **f. To avoid any confusion, I also recommend you remove the opt-out information from whatever pre-renovation form you use to document delivery of the Renovate Right pamphlet. **

** ** 

**![File drawer](https://www.shawnmccadden.com/hs-fs/file-15756552-jpg/images/file_drawer-wr.jpg?width=143&height=139&name=file_drawer-wr.jpg)**

** ** 

** ** 

#### 2. There are also new requirements regarding documentation. Beginning July 6th, 2010, when the final invoice for the renovation is delivered, or within 30 days of the completion of the renovation, whichever is earlier, the renovation firm must provide information demonstrating compliance with the training and work practice requirements of the RRP rule to the owner of the building being renovated and, if different, to the occupants of the renovated housing or the operator of the child-occupied facility.

- **a. For renovations in common areas of target housing, the renovation firm must provide the occupants of the affected housing units instructions on how to review or obtain this information from the renovation firm at no charge to the occupant. These instructions must be included in the notice provided to each affected unit or on signs posted in common areas. Similar requirements apply for renovations in child-occupied facilities. **
- **b. The renovation firm is also required to provide interested parents or guardians of children using the child-occupied facility instructions on how to review or obtain a copy of these records at no cost to the parents or guardians. This could be accomplished by mailing or hand delivering these instructions, or by including them on the signs posted. **
- **c. Renovation firms must provide training and work practice information to owners and occupants. The information should be provided in a short, easily read checklist or other form. EPA's ["Sample Renovation Recordkeeping Checklist''](https://www.shawnmccadden.com/Default.aspx?app=LeadgenDownload&shortpath=docs%2fFUTURE+SAMPLE+RENOVATION+RECORDKEEPING+CHECKLIST.pdf) may be used for this purpose, but firms may develop their own forms or checklists so long as they include all of the required information. **

**![EPA Approved Lead Test Kit](https://www.shawnmccadden.com/hs-fs/file-15771224-jpg/images/lead_test_kit_gray_background-wr.jpg)**

- **d. The specific information that is required to be provided are training and work practice compliance information, as well as identifying information on the manufacturer and model of the test kits used, if any, a description of the components that were tested including their locations, and the test kit results. **
- **e. The checklist or form must include documentation that a certified renovator was assigned to the project, that the certified renovator provided on-the-job training for workers used on the project, that the certified renovator performed or directed workers who performed the tasks required by the RRP rule, and that the certified renovator performed the post-renovation cleaning verification. **
- **f. This documentation must include a certification by the certified renovator that the work practices were followed, with narration as applicable. **
- **g. EPA is not requiring that the renovation firm automatically provide a copy of the certified renovator's training certificate, which must be maintained in the firm's records as an attachment to the checklist or other form.**

#### **If you are looking for forms and signage to help you with comply with the EPA RRP rule, I recommend you check out what [The Lead Paint Forms Store ](https://kwikbinder.infusionsoft.com/go/LAK/SMcCadden/)has to offer.**

 Topics: [EPA RRP Rule Updates](https://www.shawnmccadden.com/rrpedia/topic/epa-rrp-rule-updates), [Documentation Considerations](https://www.shawnmccadden.com/rrpedia/topic/documentation-considerations), [Work Practices](https://www.shawnmccadden.com/rrpedia/topic/work-practices), [Amendments](https://www.shawnmccadden.com/rrpedia/topic/amendments), [Enforcement and Inspections](https://www.shawnmccadden.com/rrpedia/topic/enforcement-and-inspections)

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### Still Using a Yellow Pad for Your Estimating?

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### I just wanted to say thank you for your efforts to keep us informed. 

*"Thank you again for the hundreth time for keeping a vigil on this business nightmare. Your site is one of the best resources we have to stay on level ground"* 

**Christian Peter**

 

*"I am quite impressed with all the confusion out there at Shawn McCadden’s clear and concise voice that continues to help contractors and those involved in this industry truly understand the rule. His efforts should be applauded."* 

**Christopher Wagner, LBPFiles**

 

*"RRPedia is an accurate and contractor friendly interpretation of the very complex and confusing EPA RRP rule"*

* *

*"Thanks for taking the time to write the blog.  It's about the only place one can go to get some serious info on this dreadful subject"*

 

*"I would like to begin by thanking Shawn for all of his postings and education that he has been sharing with the remodeling industry. He has personally been extremely helpful in guiding me through various interpretations of the RRP rule, his advice and knowledge are priceless."*

**Michael A. Mahoney***  
*

### Suggest or Contribute a RRPedia Topic

### Want a Simple Summary of the EPA RRP?

#### Shawn McCadden has created an EPA RRP Summary for Remodelers.

*"Hi Shawn, **Nice RRP write up on the website.   I've already forwarded a link to it to a number of local builder types."*  

#### [Click here to go to the summary.](https://www.shawnmccadden.com/epa-rrp-summary-for-remodelers-by-shawn-mccadden/)  You can also download it if you want your own copy.

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