Tuesday, April 16, 2013

EPA Compliance Series Part 2: Paperwork for RRP Job Site

Renovate Right Pamphlet for Lead Safe Renovations

This is the second installment of our RRP Compliance Series, as we take an in-depth look at the most important parts of performing of a lead-safe renovation job in compliance with the Environmental Protection Agency's (EPA) Renovation Repair & Painting (RRP) Rule.

Recently, I attended a Healthy Housing Conference in Philadelphia and had the chance to hear the EPA discuss enforcement of the RRP Rule firsthand. They admitted it is difficult to catch a Renovation Firm in the act of being non-compliant, considering most renovations, repairs, and painting projects do not last longer than a couple days, if that. What is not difficult for the EPA, however, is auditing renovation firms for their paperwork. Keep in mind, every time you complete a renovation project under the RRP Rule, you must keep the required records for 3 years.

As we cover in our lead-safe renovator training courses, here are the six documents needed for every RRP project:

1. Your Certificates: Individual and Firm: If you haven't filed your company (firm) with the EPA, but yet you are still working in pre-1978 residential homes, you are breaking the RRP Rule and are considered to be non-compliant, which carries a maximum fine of $37,500 per violation, per day! You can process your firm application online OR send in a hard copy application, which you can access here: EPA Firm Application. Your choice! Keep in mind, the EPA asks that you give them 90 days to process your firm application, but it has been taking much less time recently, according to our past students.

2. Renovate Right Pamphlet: Handing out the EPA's pre-renovation education pamphlet is one of your main responsibilities as an EPA Lead Renovator. The purpose of this pamphlet is educating your client about the potential risks that arise when a disturbance of lead-paint is created through renovations, repairs, or prep-work for painting. You can find this pamphlet many places, like Green Education Services' on-line store,  in your RRP manual in Appendix # 3, or from the EPA's website.

3. Proof of Renovate Right Pamphlet Receipt: Now that you handed out the Renovate Right pamphlet prior to beginning your RRP Project, maintain this proof with either your customer's signature or by sending the pamphlet by certified mail. Also, if you purchase the pamphlets from our store, we include carbon copy disclosure forms that the tenant can sign. You can review the ins-and-outs of this process in Module # 3 of your manual, but in regards to when the Renovate Right pamphlet should be handed out, there are three time-frames that you must know:
  • Do not hand out the pamphlet more than 60 days before beginning the renovation 
  • You may distribute the pamphlet by certified mail, as long as you do not mail it less than 7 days before beginning the renovation 
  • You must distribute the Renovate Right pamphlet at least 24 hours before the job begins, and if you miss the 7 day window with certified mail, you must obtain the owner’s written acknowledgement when you physically hand it to them 

4. Test Kit Results: If you are working in a pre-1978 residential home, the EPA wants you to show proof that you ran a test for lead-based paint prior to beginning your work. Your other option is to presume that lead-based paint is present and to use Lead Safe Work Practices based on the age of the home. You can find the Test Kit Results forms in Appendix # 6 of your RRP manual.

5. Training Non-Certified Workers: There needs to be at least one EPA Certified Renovator on each RRP Project, and that person can provide on-the-job training to the other workers. The Steps Guide, which you will use to train these workers, can be found in Appendix # 5 of your manual. The Non-Certified Worker training documents you will fill out after this training can be found in Appendix # 6. You can also review all of the RRP Hands-On Activities so you are up to speed with lead-safe work practices, which is essential to being compliant with the RRP Rule.

6. Post-Renovation Report (Record-Keeping Checklist): When your RRP Project is completed, you need to fill out this Post-Renovation Report which sums up exactly what you did during your renovation work. This form can be found in Module # 6 of your RRP manual, or on the EPA website here. Please note, the last thing that you will check off before you sign this post-renovation document is this: I certify under penalty of law that the above information is true and complete, so make sure your RRP documentation is!

If you have any further questions about the required documentation for RRP Projects, you can call our office at 1-800-355-1751, and we will be glad to assist you!

Author: Gregory Jaskowiak, Certified Lead Renovator, is the Programs Manager and In-House Instructor at Green Education Services, specializing in lead paint safety training.