Under the EPA RRP rules Certified Renovators and Certified Firms are required to have certain documents with them at certain times and must also create and store certain records related to the projects they work on that fall under the EPA RRP Rule.   Documents related to projects that fall under the RRP Rule must be stored and, in the case of an audit,  be available to the EPA for inspection for a period of three years.

Depending on the work performed, who sold it and who did the work, some or all of the following may be required:

• Copy of the Certified Firm and Certified Renovator(s) certifications
• Non certified worker training documentation
• Proof of notification and or pre-education of owners, tenants, and or the parents of children attending child occupied facilities.
• Designation of Certified Renovator to the job
• Information on and results of the use of EPA-recognized test kits provided by a Certified Renovator who acted as a representative on the Certified Firm at the job site and who conducted testing for the presence of lead-based paint on surfaces to be affected by the renovation
• Lead based paint inspection reports provided by a Certified Lead Inspector or Certified Lead Risk Assessor, if applicable
• Any other signed and dated documents form the owner(s) and/or residents regarding conduct of the renovation and requirements in the EPA RRP Rule
• All reports required from the Certified Firm and Certified Renovator by the EPA RRP Rule

Samples of several of these documents can be found in the EPA Publication titled: Small Entity Compliance Guide to Renovate Right

Rhode Island administers their own RRP program.  Here is an addition documentation consideration related to renovation record keeping for those operating in RI:

"A log book with consecutively numbered pages is maintained at each job site which contains the names, license numbers, and dates/times in and out for all Lead-Safe Remodeler/ Renovators gaining access to a containment area."

"Ensure that unlicensed workers trained pursuant to §14.4(b)(2) and all other persons who enter a containment area print and sign their names in the access log book documenting the date and time entering and leaving the containment area."

Click here to view or download the RI Regulations as a PDF

Note:  As of July 9, 2010, Massachusetts has also taken over enforcement and administration of the RRP rule.  Massachusetts has a similar log book requirement to the one described above for Rhode Island

Click here to view or download the MA Regulations as a PDF

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.

Question:

What is the "opt-out" provision of the Renovation, Repair, and Painting (RRP) Rule and when does it apply?

According to the Q&A area of the EPA's web site, before you can offer or do work on pre-1978 homes, you must be a Certified Firm (click here to see this Q&A).  So, even if the work practices are not required, or the owner decides to opt-out, offering services or working on target properties requires that the contractor offering the contract to a property owner be a certified firm.

According to the EPA web site:

"The RRP Rule published April 22, 2008, allows homeowners to 'opt out' of the requirement to hire a trained renovator who follows the RRP work practices if the homeowner certifies that (1) the renovation will occur in the owner's residence, (2) no child under age 6 or pregnant women resides there, (3) the housing is not a child-occupied facility, and (4) the owner acknowledges that the renovation firm will not be required to use the work practices contained in the RRP rule." 

NOTE: On April 23, 2010, the EPA announce that the opt-out provision would be phased out. The change in the rule regarding the opt-out will become effective on July 6th, 2010.  Click here for more on the opt-out posted at the EPA Web Site.

NOTE:  Rhode Island is one of many states and or tribal authorities that has been granted and or is seeking authorization by the EPA to administer the RRP program.  The opt-out provision is/will not be allowed in RI.  If you know of the status of the opt-out in RI and or other states, please contribute that information along with a source/link to confirm accuracy. 

Click here to view or download the RI Regulations as a PDF