--- title: "5 Things Your RRP Trainer Probably Forgot To Tell You: Guest Blog" description: I believe the RRP training materials leave out critical information contractors should know about how the EPA actually enforces its regulations. image: https://www.shawnmccadden.com/hs-fs/file-15768088-jpg/images/janetphoto-wr.jpg --- [![Shawn McCadden](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1539748069.jpg)](https://www.shawnmccadden.com/) # 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 ## [5 Things Your RRP Trainer Probably Forgot To Tell You: Guest Blog](https://www.shawnmccadden.com/rrpedia/bid/55415/5-Things-Your-RRP-Trainer-Probably-Forgot-To-Tell-You-Guest-Blog) Posted by [Shawn McCadden](https://www.shawnmccadden.com/rrpedia/author/shawn-mccadden) on Wed, Mar 16, 2011 @ 06:00 AM - [Tweet](https://twitter.com/share) ## 5 Things Your RRP Trainer Probably Forgot To Tell You ![Janet Kerley](https://www.shawnmccadden.com/hs-fs/file-15768088-jpg/images/janetphoto-wr.jpg?width=126&height=147&name=janetphoto-wr.jpg)   ### One Person’s Opinion: This is a guest blog submitted by Janet M. Kerley to express her opinion.  Janet M. Kerley, CHMM is the Lead Pb Trainer for the Santa Fe Community College Lead Training Program. In her spare time, she developed the smartphone app, [RRP Comply](http://rrpcomply.com/),  to assist contractors in stepping through the RRP requirements. If you would like to express your opinion or offer something of value for RRPedia visitors let me know.     ### 5 Things Your RRP Trainer Probably Forgot To Tell You ![EPA Logo](https://www.shawnmccadden.com/hs-fs/file-15754130-jpg/images/epa-logo.jpg?width=113&height=100&name=epa-logo.jpg)   The EPA (with HUD) developed the standardized Renovation, Repair and Painting Rule courses to train contractors on how to comply with the RRP Rule.  As an experienced environmental professional, I believe the training materials leave out some critical information that contractors should know about how the EPA actually enforces its regulations.  Here are some additional recommendations that I provide in my classes to assist contractors in preparing to meet the EPA: - Keep RRP documents and records separate from your project notes and financial records.    - Keep RRP documents and records readily available. - Document (take a photo, write a memo-to-file, get a signature, get copies of certificates, etc.) on all RRP requirements. - Pay attention to and stick to the established deadlines within the RRP. - Work closely with other contractors on the job to maintain consistency in all RRP recordkeeping. - Establish a clear pattern of compliance within your company and your subcontractors. While EPA inspectors might actually show up at your job site, the most probable scenario is they will show up at your office and ask to review your records for the previous three years.  Let me explain why I make the above recommendations. The EPA typically uses a variety of economic models [(ABEL, BEN, INDIPAY, MUNIPAY, PROJECT)](http://www.epa.gov/compliance/civil/econmodels/) to calculate fines and penalties for violators. Handing the EPA inspector your costs and profit information in your project file just makes their job easier.  If they find a violation, there is an established procedure for requesting company financial information during the enforcement process.   Since we are in the implementation phase of RRP, there are still many gray areas in the rule that will get resolved over the next three to five years.  Until then, keeping your project notes separate from the required recordkeeping prevents an inexperienced regulator from jumping on a misplaced word in your documents. ![RRP paperwork](https://www.shawnmccadden.com/hs-fs/file-15756552-jpg/images/file_drawer-wr.jpg?width=86&height=86&name=file_drawer-wr.jpg)The definition of ‘readily available’ varies widely. For example, OSHA allows up to 24 hours for businesses to produce some types of required records.  When the EPA inspector walks in and asks for your RRP documents, you should be able to open a file drawer, pull out a box, or hand them a CD with all of your records within a 15 to 30 minute time frame.  Otherwise, they pull out their ticket book and start writing violations. ![RRP Sign](https://www.shawnmccadden.com/hs-fs/file-16137373-jpg/images/warning_sign-wr.jpg?width=109&height=85&name=warning_sign-wr.jpg)EPA does not allow hearsay compliance. If it isn’t written down, it didn’t happen.  You can stand there and tell them that you used containment on every job.  But, a picture of your jobsites with you pointing to the warning sign outside your containment demonstrates compliance beyond any doubt. Pictures are worth a thousand words…and don’t forget to set your date and time stamp on your photo. EPA loves to catch us on the dates.  For example, contractors are required to provide the Lead Test Documents to the client within 30 days of completion of the project.  We have a training slide that says that but the provided form does not have a location to document receipt of the test results. I recommend you insert a line that says ‘Received By’ with a place for your client’s signature and date in the Client Information box on the Lead Test Documentation form.  Perform the test, hand it to your client to sign, and then make copies.   Arrange to meet with all other renovators, subcontractors, specialty craftsmen on the project to determine who is going to be the Assigned Renovator.  Coordinate with all companies on a LBP project before, during and after to make sure everyone’s documentation is correct and complete.  It only takes one bad apple for the EPA to dig into everybody’s apple crate. By keeping timely, correct, and proper documentation on your projects that fall under the RRP Rule requirements, you can establish a pattern of compliance.  If your recordkeeping is available, comprehensive to the rule’s requirements, and somewhat orderly, the EPA inspector will not be inclined to dig too deep to find minor non-conformances.     ![RRP Records](https://www.shawnmccadden.com/hs-fs/file-15766876-jpg/images/inspector_with_clip_bd-wr.jpg)     ### Remember: The LBP job is not done until the paperwork is complete.  It can be a very costly mistake.  Topics: [Guest Blogs](https://www.shawnmccadden.com/rrpedia/topic/guest-blogs), [Compliance Options](https://www.shawnmccadden.com/rrpedia/topic/compliance-options), [Documentation Considerations](https://www.shawnmccadden.com/rrpedia/topic/documentation-considerations), [Enforcement and Inspections](https://www.shawnmccadden.com/rrpedia/topic/enforcement-and-inspections) [![cs-ye-234x16](https://www.shawnmccadden.com/hs-fs/hub/81069/file-1553381212.gif)](http://www.copyscape.com/duplicate-content/) ### Subscribe to RRPedia by Email and get notified about new postings as soon as they happen! ### Are You Documenting Yor Crew's Compliance With The RRP Rule?  [![download free RRP checklist](https://no-cache.hubspot.com/cta/default/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e.png)](https://cta-redirect.hubspot.com/cta/redirect/81069/dd6aace9-6cb0-4ad2-a55a-09846d7f5b5e) ### Still Using a Yellow Pad for Your Estimating? 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[Worker Training (15)](https://www.shawnmccadden.com/rrpedia/topic/worker-training) ### 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. ### Add this widget to your Web page, blog, or social networking site. A widget is a CDC.gov application that displays the featured content directly on your web page. Click the buttons to see the next tip to prevent lead poisoning.