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Your Interactive Resource for EPA RRP Information

RRPedia logoLooking 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 before using or contributing to RRPedia.


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

Most Children Poisoned By Lead During Renovations Poisoned By Their Parents

Posted by Shawn McCadden on Wed, Oct 27, 2010 @ 07:00 AM

Study shows that the majority of children poisoned by lead during renovations were poisoned by their own parents doing the work.

Causes of lead poisoningAccording to Medscape Today, investigations conducted during 2006-2007 in New York state (excluding New York City) for 972 children with Blood Lead Levels (BLLs) ≥20 µg/dL, RRP activities were identified as the probable source of lead exposure in 139 (14%) of the 972 children. Resident owners or tenants performed 66% of the RRP work that was determined to have caused the poisoning, which often included sanding and scraping (42%), removal of painted materials or structures (29%), and other activities (29%) that can release particles of lead-based paint. Although this study only included one state, we can probably assume other states with older housing would likely have similar findings.

From this information we can deduct the following. 86% or 836 of the poisoned children were poisoned by exposure to lead in some way other than RRP activities. Also, of the children proven to be poisoned by RRP activities, 92 were poisoned by their own parents doing the renovation work, leaving a total of 47 children poisoned by RRP activities performed by someone other than their parents. The study did not specify who these others were. It is likely that most would be renovation companies, but a good number could also have been landlords or property developers doing their own work.

DIY RRP WorkAlthough I agree renovators should be required to work lead-safe, I suggest that the RRP rule falls way too short in preventing lead poisoning. Allowing home owners and tenants to do RRP work without the knowledge and proper training required should be considered a travesty. Without understanding how lead poisoning happens and how to perform the work in a lead-safe manner, these parents are often unknowingly poisoning their children.

Sadly, many children are also poisoned by dads and moms who do RRP work for a living. Read this blog for a true story about a contractor who, while attending the required certified renovator training, panicked when he discovered he might be poisoning his own children. I wonder how many of the 972 children in the study mentioned above might have been poisoned by hugging their daddy when he got home from work. I know this happened at my home when I was working in the field. The good news is that the story is evidence that education can make a difference when it comes to preventing lead poisoning.

Topics: Legal Considerations, Health Effects of Lead, Info for Landlords, Work Practices

Abatement vs. Renovation: Know the Difference

Posted by Shawn McCadden on Thu, Oct 14, 2010 @ 08:00 AM

Abatements vs. Renovations What's the Difference?

Difference between abatement and renovationRenovators doing RRP work definitely need to know the difference between renovations and abatement.   Unless specifically licenced to do so, renovators are not allowed to do abatement work.  Renovators would be wise to make sure property owners know the difference as well.  Employees should also be clear on the difference between renovations vs abatement, so as not to misrepresent the work they are doing when discussing a remodeling project with clients and prospects.

Abatements vs Renovations

Abatement means an activity designed to permanently eliminate lead paint hazards. Abatement includes any of the following:

  • The removal of lead paint and lead-contaminated dust; the permanent enclosure (barrier) or encapsulation (special paint coating) of lead paint; the replacement of lead-painted surfaces or fixtures; the removal or covering of lead-contaminated soil; and any preparation, cleanup, disposal, and post-abatement clearance testing associated with these activities.
  • A project for which there is a contract indicating that a company will be performing work on a housing unit, day care center, preschool, or kindergarten that is designed to permanently remove lead paint hazards.
  • -A project resulting in the permanent removal of lead paint hazards, conducted by a certified abatement company.
  • What is abatement?A project resulting in the permanent removal of lead paint hazards, conducted by a company who, through its name or promotional literature, represents, or advertises to be in the business of performing lead paint activities.
  • A project resulting in the permanent removal of lead paint hazards that is conducted in response to a state or local government lead abatement order, as in the case of a lead poisoned child.

Abatements are generally performed in three circumstances:

  • In response to a child with an elevated blood lead level
  • In housing receiving HUD financial assistance
  • State and local laws and regulations may require abatements in certain situations associated with rental housing.

RRP ManualAbatements are not covered by the RRP rule.

Renovations are performed for many reasons, most having nothing to do with lead-based paint. Renovations involve activities designed to update, maintain, or modify all or part of a building. Renovations are covered by the RRP rule.



Other terms and definitions:

Painting and Coatings terms and definitions

Glossary and Definitions of EPA RRP Terms

Topics: Sales Considerations, Definitions, Info for Landlords, EPA RRP for Dummies

MA RRP Assessment Form Introduced By CLPPP

Posted by Shawn McCadden on Tue, Oct 12, 2010 @ 06:02 PM

MA RRP Assessment Form Introduced By CLPPP

Recently Massachusetts Releases MA RRP Assessment formMassachusetts, one of the states delegated by EPA to administer and enforce the RRP rule, released a new form and protocol to be used by Massachusetts licensed lead inspectors when doing testing for lead prior to a RRP project.   Although under the Massachusetts and EPA RRP rules a certified renovator can use EPA approved test kits to do this testing, as an alternative some home owners and renovators may elect to have the testing done by a lead testing professional.  The following article was written by John MacIsaac of ASAP Environmental.  John is a leader in the lead inspection industry and currently serves as President of the New England Chapter of (LEHA), The Lead and Environmental Hazards Association.



John MacIsaac

John’s Article:

As of September 2010, CLPPP (Childhood Lead Poison Prevention Program) has produced a new report for RRP inspections.  It is called the Renovation Repair and Painting Assessment Report.  This new MA RRP inspection form will be used when licensed MA lead inspectors are testing surfaces that will be impacted during renovation of properties built prior to 1978.  The information on this report will definitively say which surfaces are positive or negative for lead based paint based on findings from an XRF analyzer or sodium sulfide solution purchased by the inspector from the state of MA.  If the surfaces tested negative for lead paint then the contractor is not required to follow the RRP protocol.  If the surfaces are positive for lead based paint the contractors are required to follow the RRP protocol for set up, containment, and clean up.

There has been a MA Lead Determination report in place since before the current lead law was enacted.  This report has been primarily used for testing for lead based paint as part of home sales.  It was also used for RRP inspections prior to the release of the RRP Assessment report.  The RRP Assessment report as well as the Lead Determination report cannot be used for deleading purposes.  In order to perform deleading activities for compliance with the MA lead law you will need a Full Comprehensive Initial Inspection and/or Risk Assessment.  Certified firms and the Lead Safe Renovators who work for them are not licensed to do deleading activities for compliance in MA unless they take an additional 4 hour deleading training course.  Since April 22, 2010 we have seen a number of deleading jobs for compliance that have had unauthorized contractors perform the deleading activities.  As a result of this the owners of these properties are getting letters of Unauthorized Deleading which does not remove them from liability from the lead law and they are also not eligible for  available tax credits of up to $1,500 from the state.


XRF Testing with XRF Gun 

It is important that property owners make the decision on whether or not they will or will not have testing done either by a licensed lead inspector or a lead safe renovator.  The property owners are required to disclose all findings, from a licensed lead inspector’s Lead Check EPA Approved test kit used for testing for leadRRP Assessment report or from a Lead Safe Renovator who has used an EPA approved lead based paint test kit to test surfaces for lead, to all tenants or potential buyers.


Note:  This information was provided by John MacIsaac of ASAP Environmental, Inc.

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 has to offer.

Topics: RRP in MA, Definitions, Compliance Options, Info for Landlords, MA RRP Updates, Lead Test Kits and Testing

Jury Awards Nearly $21M in Baltimore Lead Paint Case.

Posted by Shawn McCadden on Thu, Oct 07, 2010 @ 10:49 AM

Jury Awards Nearly $21M in Baltimore Lead Paint Case.

Lead Paint law suit award

If you have been concerned about the legal risks and liabilities due to the RRP rule your concerns may be well founded.  Although very brief and lacking details, this Associated Press article from the Washington Examiner is probably very bad news for renovation contractors and landlords:


Associated Press
10/06/10 10:50 PM EDT

BALTIMORE — A Baltimore City jury has awarded a 23-year-old woman nearly $21 million after finding she suffered lead poisoning while living in an apartment owned and maintained by the Housing Authority of Baltimore City.

Attorney Brian Brown says the $825,000 in economic damages and $20 million in non-economic damages awarded Wednesday is one of the largest he has ever seen, but it will likely be reduced because of the state's $350,000 cap on non-economic damages.

Baltimore Circuit Court Judge Alfred Nance will determine, within the cap, how much Marie Carter will get in non-economic damages.

The case was based on circumstantial evidence because the property had been demolished before it could be tested for lead paint. Brown says Carter's IQ was diminished by 10 points, to 89, which is below average.


Information from: The Daily Record of Baltimore,

Read more about this from Dolan Media including comments from the lawyers involved in the case

There are some interesting comments on the Baltimore Sun web site

Topics: Effects of the RRP Rule, Legal Considerations, Health Effects of Lead, Info for Landlords

RI RRP regulations differ from the EPA Rule in a few key ways

Posted by Shawn McCadden on Tue, Sep 28, 2010 @ 08:00 AM

Rhode Island RRP Rule

Rhode IslandRhode Island has been operating a Lead-Safe Remodeler/Renovator Program since 2001 and has licensed over 1,500 Lead-Safe Remodeler/Renovators. In 2010, the Environmental Protection Agency (EPA) created its own Lead-Safe Remodeler/Renovator Program, known as the Lead-Based Paint Renovation, Repair, and Painting Rule. Rhode Island was the first New England state granted authority by EPA to continue its state Remodeler/Renovator program. 

The following information is from the RI Department of Health web site:

Regulated People and Activities

RI DOH LogoRhode Island's RRP Rule applies to contractors, landlords, property managers, homeowners, and anyone else who disturbs painted surfaces on pre-1978 homes or child care facilities. This includes general contractors as well as special trade contractors, such as painters, plumbers, carpenters, and electricians.

In general, the RI RRP Rule applies to any renovation, repair, or painting that disturbs six square feet or more of paint per room on the interior or 20 square feet or more of paint on the exterior of a pre-1978 house or child care facility. Examples of regulated activities include window replacement, remodeling, repair/maintenance, electrical work, plumbing, painting, carpentry, and any type of demolition.

Not all projects are regulated by the RRP Rule. The chart below details who can do what type of work:

Who can do the work chart 

Rhode Island's regulations differ from the federal RRP Rule in a few key ways
• Parents with children younger than six years of age must use a licensed Lead Hazard Control Firm.
• The Lead Hazard Control Firm must submit a Start Work Notification to the Department of Health at least three business days before beginning work.
• A licensed Lead-Safe Remodeler/Renovator must be on site at all times.
• When the work is complete, a clearance inspection by a Rhode Island Certified Environmental Lead Inspector or Technician is required. The clearance inspection must include dust wipe samples analyzed by an approved laboratory. Once acceptable dust levels are achieved, the inspector or technician will issue a Certification of Acceptable Clearance Status.

• Housing built after 1978 and any housing declared lead-free by a Rhode Island Certified Environmental Lead Inspector is generally exempt from Rhode Island's RRP Rule.
• Other exemptions include housing for elderly or disabled persons, studio apartments, and dormitories. These buildings are regulated if a child younger than six years old resides there, or is expected to reside there, for more than two weeks per year.


• Contractors, painters, and other workers must complete an eight-hour Lead-Safe Remodeler/Renovator training by a licensed training provider.

• Once training is complete, an individual can apply to be a licensed Lead-Safe Remodeler/Renovator.
• All Rhode Island licensed Lead-Safe Remodeler/Renovators must be affiliated with licensed Lead Hazard Control Firms.
• Individuals and firms must renew their licenses every five years after completing a four-hour refresher course. (Note: The fee for firms in RI is only $45.00!)


Start Work & Pre-Renovation Notification
• The firm must deliver a copy of the Rhode Island version of the Renovate Right pamphlet to property owners and tenants no more than 60 days and no less than seven days before work begins. 
• The firm must fill out the Pre-Renovation Education form at the back of the pamphlet, have it signed, and keep it for a minimum of three years.
• At least three business days before beginning a job, the firm must submit a Start Work Notification to the Department of Health. 

Lead-Safe Work Practices

While work is being performed, Lead-Safe Remodeler/Renovators and their workers must:

• Contain the work area to prevent dust and debris from escaping.
• Refrain from using work methods that generate large amounts of lead-contaminated dust.
• Dry sweeping, using heat guns at temperatures above 1100°F, open flame burning, and using flammable or methylene chloride paint strippers are prohibited.

Dust clearance testWhen work is complete, Lead-Safe Remodeler/Renovators and their workers must:

• Clean dust and debris using a HEPA vacuum and wet mops.
• Have a Certified Environmental Lead Inspector or Technician conduct a clearance inspection.
• Remove containment barriers upon notification that the dust wipes passed clearance.



Topics: RI Conciderations, Rhode Island RRP Rule, Notification Considerations, Info for Landlords, EPA RRP for Dummies, Work Practices, Work Practice Exclusions

Home Inspectors Will Help Spread The News About The EPA RRP Rule

Posted by Shawn McCadden on Fri, Sep 24, 2010 @ 08:04 AM

Home Inspectors Will Help Spread The News About The EPA RRP Rule

ASHI LogoIf home buyers aren’t aware of lead paint or the implications of buying a property that has or may have lead paint, a good home inspector may likely provide such knowledge. 

In April this year I did a presentation about lead and the new RRP Rule for the New England Chapter of the American Society of Home Inspectors (ASHI New England).  Ironically, the meeting was scheduled for Earth Day, the same day the RRP rule went into effect.  At this meeting I informed the inspectors not only about the required EPA RRP lead –safe work practices, but also about the health effects of lead and the required documentation that home owners should receive on completion of a renovation if the property was built prior to 1978.  The inspectors were quick to connect the dots between identifying recent renovations and suggesting to the buyer that they ask the seller for a copy of these documents.

In my experience, home inspectors, particularly ASHI members, are typically a very detailed and knowledgeable group of professionals who seek to constantly increase their knowledge.  In fact, to maintain their membership in ASHI, members are required to obtain continuing education credits.  Home inspectors separate themselves from their completion through their knowledge and expertise and use these advantages to better serve their clients.  Home buyers have home inspections performed prior to a purchase as a way to not only identify the condition of a home, but to also identify any health and or safety issues the home may have. Good home inspectors should have knowledge about the EPA RRP rule and will share this information with their clients.

ASHI Home InspectorHome inspectors will help cause compliance with the EPA RRP rule in a few ways.  First, they will likely make home buyers aware of the fact that if built before 1978, the home may likely contain lead paint.  The only way to verify if lead paint is present is to do a lead test.  Inspectors can suggest their clients ask the seller if the home has been tested and if it has to obtain a copy of the required lead inspection report.  Next, if the home does have lead, or it hasn’t been tested, inspectors should inform the buyers that any renovations to the home would need to be done using lead-safe work practices.  This will have two effects.  The first would be to let the buyer know that lead-safe work practices are required should they be planning any renovations after purchasing the home.  Second, and most critical, would be to verify that any recent renovations done at the home were done using lead-safe work practices and to verify this by making sure who ever did the work did it in compliance with the EPA RRP requirements.  Again, requesting a copy of the required documentation will be the best way a buyer can confirm how such renovations were completed.

Home Owner paintingAdditionally, if the work was done by the home owners themselves, or perhaps was done illegally by a non-complaint contractor, the only way to find out if the work may have contaminated the home with lead would be to have the home tested by a licensed lead inspector.   This is likely to create heartburn for both the seller and the realtors involved in the sale.  Federal disclosure rules about lead require that if a home is tested, the required lead test report must be disclosed to any buyer or anyone planning to rent or lease the property.  Failure to do so would result in serious legal liabilities for the seller and also for the realtor should the realtor be aware of the testing.  If the seller refuses to allow testing, the buyer may just walk away from the purchase and has the legal right to do so.  


As the above described scenarios take place during real estate transactions, I predict home owners, home buyers and realtors will all become more and more aware of the EPA RRP rule.  Each, and for their own reasons, will likely become frustrated and or disappointed.  All will share their frustration and disappointment with someone else.  Its only human nature to do so.  This will result in spreading the word about the EPA RRP rule and will contribute to the reporting of violations and the enforcement of the rule by either the EPA and or those states that have assumed administration and enforcement of the rule.

Topics: Effects of the RRP Rule, Legal Considerations, Shawn's Predictions, Info for Landlords, Lead Test Kits and Testing, Enforcement and Inspections

What States Have Taken Over The EPA RRP Rule?

Posted by Shawn McCadden on Thu, Sep 09, 2010 @ 10:38 AM

What States Have Taken Over Administration and Enforcement of The EPA RRP Rule?

Note:  This post was updated on 2/28/12 to reflect information available at that time.

The National Center for Health Housing (NCHH) maintains a list tracking the status of RRP for all 50 states to help renovators and training providers.  The list includes key links and highlights of rule status for each state as well as American Samoa, Guam, Puerto Rico, U.S Virgin Islands.

As of this post (updated on 2/28/12), the following states are either exploring adoption, are in process or are pending adoption of an RRP rule: District of Columbia,  Illinois, Michigan, Minnesota, Missouri, Tennessee, Virginia, California

The following information can be found at the EPA web site.  This information was current as of 2/28/12.  Click here to check the EPA web site for the most current information.

EPA RRP Certified Firm Logo

EPA Authorized State Programs

EPA has the authority to authorize states, tribes and territories to administer their own RRP program that would operate in lieu of the EPA RRP regulations. When a state, tribe or territory becomes authorized, contractors and training providers working in these areas and consumers living there should contact the appropriate state, tribal or territorial program office.

The following states have been authorized by EPA: Alabama, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oregon, Rhode Island, Utah, Washington, and Wisconsin.

Information for States and Tribes

EPA headquarters has developed guidance documents to assist states and tribes that are applying to EPA for authorization to manage their own lead renovation, repair and painting programs (PDF) (122 pp, 257K).



Topics: RRP Questions, EPA RRP Lead Rules, Authorized States, Info for Landlords, RRP for Dummies, Enforcement and Inspections

Property Values and Equity Will Drop as a Result of the EPA RRP Rule

Posted by Shawn McCadden on Tue, Sep 07, 2010 @ 01:26 PM

Property Values and Equity Will Drop as a Result of the EPA RRP Rule

Price reducedHome buyers, investors and realtors will likely drive awareness about lead and the new EPA RRP rule up.  But, at the same time, such awareness will drive the values of pre-1978 properties down.  If unaware of the additional considerations of risks, liability and costs related to the RRP, realtors will likely walk into a hornet’s nest. 


Some home buyers and investors use realtors acting as buyer brokers to assist them when purchasing property.  If making buying decisions based on property pricing and the costs related to bringing the properties they purchase up to par with their desires, these buyers will not be happy if they are blindsided by the RRP rule.  These buyers will also be very unhappy, and may consider legal options, if they feel their realtor should have advised them about such considerations during the buying process. 

No lead paintA buyer’s willingness to purchase a property that contains lead will definitely be effected as a result of the RRP rule.  First, once word gets out, the health risks of lead paint and related liabilities will cause many buyers to bypass any consideration of pre-1978 properties.  As the supply goes up, the prices of these properties will go down.  Also, investors won’t like the added costs of owning such properties, particularly if the value of those properties is less likely to increase over time as compared to properties without lead.   This too will lower property values to a point where the value of certain properties may only be in the land they sit on, less the cost to get rid of the original lead infused structure.

As a result of the RRP rule, I predict home sellers and realtors will get into uncomfortable negotiations with buyers, and as a result, even some challenging conversations between themselves.  Let’s just say the asking price for a pre-1978 property is $280.000.  I picture scenarios where a buyer will make two different offers for that property.  One offer will be close to the buyer’s asking price, say $270.000.   But, the offer will be conditional upon testing the home for lead to confirm no lead is present.  The second offer will be much lower, say $240.000.  The second offer will reflect the additional costs and risks the buyer feels they will be assuming if the home does have lead and or the seller isn’t willing to allow testing for lead.  In the negotiations, realtors will likely become the punching bag, as buyers and sellers typically never interact, but rather the realtor acts as the middleman.  If the seller is first finding out about lead and the RRP as a result of the offer, as mentioned above, that seller might not be happy with their realtor either.

Realtor LogoAs a side note, realtors as a whole are typically much more professional and proactive than contractors.  The majority of them are also dues paying members of one single, well funded and very powerful trade association that represents their interests.  I predict that once a good number of realtors catch wind of and understand how the RRP will affect their industry; their association will be working to modify the rule in their favor.  This might be of benefit to renovators, but just as easily, it might not.

Topics: Effects of the RRP Rule, Legal Considerations, Shawn's Predictions, Health Effects of Lead, Info for Landlords

Insurance Companies Rethinking Coverage Due to EPA RRP Rule

Posted by Shawn McCadden on Thu, Sep 02, 2010 @ 01:26 PM

Insurance Companies Will Be Rethinking Coverage and Premiums Due to EPA RRP Rule

RRP Insurance folderMany liability insurance policies do not cover lead poisoning or contamination.  Renovators should be sure they are working with an agent who is up on the EPA RRP rule and should sit down with their agent to review their coverage needs and options.  Tom Messier, with Mason and Mason Insurance, tells me that insurance companies are starting to become aware of the RRP rule.  Insurance is all about risk. The greater the risk, the higher the cost of insurance will be.


RRP LogoIncreased risk of liability due to lead awareness as well as the government mandated certification requirements are likely to affect a renovator’s ability to get a policy as well as the premium charged by carriers who offer coverage.  Tom told me he predicts that existing policies will not be renewed unless a renovator can show they are certified firms and use certified renovators to oversee the work their company performs.  He also predicts insurance carriers will start requiring the insured’s proof of compliance with the rule as well as proof of compliance and insurance coverage for the trade partners the insured renovator works with.  Tom stressed that this would be for both liability as well as workers compensation insurance coverages. He said that even if they are self-employed, insurance carriers will likely require all trade partners have their own workers compensation policies as a way to prevent injured or poisoned trade partners from claiming against the general contractor’s policy. 

Also Tom warns, just as many insurance companies now review the contracts contractors use with customers and trade partners before offering or renewing a policy, Tom predicts carriers will be asking to see completed copies of the required RRP documentation used by contractors.   I asked Tom what renovators should do to protect themselves and be sure they can maintain coverage going forward.  Tom’s response; “Document, document, document!!!” 

Apertment for rent signOne other area that will likely be of concern is lead coverage in policies for landlords who own pre-1978 properties.  Here too, compliance with RRP rules and documentation of work practices used for renovations and repairs will likely become required conditions of obtaining and keeping coverage.  The EPA RRP rule may also cause an increase in insurance coverage on properties built prior to 1978, for landlords and maybe even home owners.

Topics: Effects of the RRP Rule, Subcontractor Considerations, Shawn's Predictions, Insurance Considerations, Documentation Considerations, Info for Landlords, Firm Certification

RRP Renovation Checklist Must Be Given to Certain Parties

Posted by Shawn McCadden on Thu, Aug 26, 2010 @ 05:37 PM

The RRP Renovation Checklist Must Be Given to Certain Parties At The Completion Of Renovations

ChecklistBecause 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.

EPA Approved Lead Test Kit

  • 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.

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 has to offer.

Topics: EPA RRP Lead Rules, Documentation Considerations, Info for Landlords, EPA RRP for Dummies, Work Practices, Amendments