The RRP Renovation Checklist Must Be Given to Certain Parties At The Completion Of Renovations
Because of one of the EPA RRP amendments, there is a new requirement regarding documentation. As of the amendment that took effect on 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.
- 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.
- 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.
- 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'' 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.
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.
- 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.
- This documentation must include a certification by the certified renovator that the work practices were followed, with narration as applicable.
- 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.