RRP and Record Keeping: What you NEED to know but were never told.

by WOHe

The RRP training (6 hours class, and 2 hours hands-on) is jam-packed and a little daunting to those new to all of this. And after actually doing the work, we all find out that the training class falls short of actually showing how comprehensive the process needs to be before the work, during the work and during cleanup. No one is really prepared after the class. But what is most worrisome is the insufficient explanation of the record-keeping and documentation process as required by the EPA.

Failure to follow RRP can get you into trouble, if you are caught. That risk goes away ostensibly after the job is done. But, poor record keeping follows you for the three-year requirement to keep them on file, and as long as the statute of limitations exists in your jurisdiction regarding consumer liability lawsuits for lead poisoning. The plain truth is that record keeping may be more important for the Certified Firm and Certified Renovator than the efficacy of actual work being done; and that’s not to diminish the responsibilities to follow RRP to the letter.

In talking with remodelers and renovators engaged in RRP, they all seem to be confused about record keeping in one way or another. To quote 40 CFR 745, Part F; §1b: “Recordkeeping for Renovation Firms”:

This final rule also requires firms performing renovations to retain documentation of compliance with the work practices and other requirements of the rule. Specifically, the firm must document 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 this final rule, and that the certified renovator performed the post-renovation cleaning verification. This documentation must include a copy of the certified renovator’s training certificate.

Finally, the documentation must include a certification by the certified renovator that the work practices were followed with narration as applicable. The certification must include the specific information listed in § 745.86(b)(7). The firm must keep this information for 3 years after the completion of the renovation.

To be sure, there are plenty of sample forms available, the EPA includes some samples in their manuals, and the training firms and industry business software suppliers are promoting their sets of forms. However most, if not all, are incorrect, or at best incomplete. Why? The phrase in 40 CFR 745: …with narration as applicable.

Just checking off on a form that you cleaned an area, or that you disposed of debris, or that you provided the “Renovate Right” brochure, etc., is not valid. There are specific sentences and paragraphs describing these functions in 745.86 that should be part of the description needing the check mark. Doing so creates forms that state that you did exactly what RRP required – specifically.

For example, to document that the work area has been contained, the check-off list provided by the EPA in their training manuals and on their site has a space to check off that the “Work area (was) contained to prevent spread of dust and debris.” The assumption is if that is checked off, the record is proper. No it isn’t.

The proper way to do it with narration is more like: “Work area (was) isolated to prevent dust and debris leaving, including plastic sheeting to confine area, tack mats to preventing tracking, (and) dual entry sheeting for (the) vertical entry way” – which is word-for-word what is in 745, i.e., narration.

Proper record keeping is the most important function of a certified Firm and the Certified renovator because it will accomplish four useful and important goals:

1. Comply with the record keeping provision of RRP.

2. Other than the EPA looking over your shoulder while the work is done, it will be the most accurate and unassailable proof that the RRP Rule was followed to the letter – providing the most effective insulation from fines and other regulatory action.

3. Creating properly worded pre-renovation, renovation, and post renovation forms can be used as worker training forms and cheat sheets (think Clip Notes).

4. Get the homeowner to sign/initial the narration containing form and you will have the strongest prevention of future liability claims available, and possibly the document that can lower or eliminate additional liability insurance.

(For pdf sets of recommended forms, contact ( www.CertifiedRenovatorSupply.com).

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