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RRP Rule:  Recordkeeping Requirements


You are required to retain records of your proper implementation of the RRP Rule for each job on pre-1978 buildings.  You can find a sample forms to help ensure proper recordkeeping at the links below.  All documents must be retained for three years following the completion of a renovation.  The records that must be retained include:


  1. Records required to be on the job site:
    1. Copies of the certified renovator's initial and most recent refresher course completion certificates.
  2. Records required to be maintained for each job for a period of three years:
    1. Copies of the certified renovator's initial and most recent refresher course completion certificates.
    2. Non-certified worker training documentation.
    3. Designation of a certified renovator to the job.
    4. Information on and results of use of EPA-recognized test kits or paint chip samples by a certified renovator who represented the certified firm at the job site and who conducted testing for the presence of lead-based paint on surfaces affected by the renovation.  Paint testing is not required, but all the requirements of the renovation regulation will apply unless you have clear documentation that the existing paint is not lead-based.  Testing, if you choose to have it done, must be done on all surfaces affected by the work by the appropriate qualified professional.  If you use an EPA-recognized test kit, the testing must be done by a certified renovator.  If you use X-Ray Fluorescence instruments, the testing must be done by certified lead-based paint inspectors or risk assessors.  If you use paint chip sampling, testing must be done by a certified renovator, inspector or risk assessor.  For more information about lead test kits, see https://www.epa.gov/lead/lead-test-kits.  For more information about lead testing laboratories, see https://www.epa.gov/lead/national-lead-laboratory-accreditation-program-nllap.  Or call the National Lead Hotline at 1-800-424-LEAD (5323).  See a sample test kit documentation form at https://www.epa.gov/lead/test-kit-documentation-sample-form.
    5. Lead-based paint inspection reports provided by a certified lead inspector or certified lead risk assessor, if applicable.
    6. Proof of owner/occupant pre-renovation education.  This includes records relating to the distribution of the Renovate Right pamphlet.  See sample recordkeeping form at https://www.epa.gov/lead/sample-pre-renovation-form-confirmation-receipt-lead-pamphlet.  Also see a sample Renovation Notice for notifying tenants of renovations in common areas of multi-family housing at https://www.epa.gov/lead/renovation-notice-sample-form.
    7. Signed (certified) documentation of compliance with the training, sampling (see paragraph 4 above), education, and work practices requirements of the Lead-Based Paint Renovation, Repair, and Painting Program.  This documentation can be completed using a checklist and must also be provided to the building owner and occupants.  Within 30 days of job completion or at the time of the final invoice, whichever is earlier, you must give this information must to the owner and, if different, the adult occupant of the housing or adult representative of the child-occupied facility that was renovated.  If the renovation was in the common area of a multi-unit building, post the information or instructions on how to get the information where occupants are likely to see it.  You can find a sample checklist to help ensure proper recordkeeping of these requirements at https://www.epa.gov/lead/sample-renovation-recordkeeping-checklist
    8. Any other signed and dated documents from the owner(s) and/or residents regarding conduct of the renovation and requirements in the EPA RRP Rule.
    9. All reports required from the certified firm and the certified renovator by the EPA RRP Rule.

You can find the regulatory language for the RRP Rule recordkeeping requirements at 40CFR§745.86.  You can find the regulatory language for the RRP Rule lead test kit requirements at 40CFR§745.88.

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