Recordkeeping
In this section, you will learn about records required for each job. •Records must be retained and made available to EPA, upon request, for 3 years following completion of renovation.
Language of the RRP Rule is: “Firms performing renovations must retain and, if requested, make available to EPA, all records necessary to demonstrate compliance…for a period of three years following completion of the renovation.”
HUD also has a 3-year record retention requirement for notices, evaluations, and clearance or abatement reports (24 CFR 35.175).
On-The-Job Records
The Certified Firm must designate (in writing) a Certified Renovator to be responsible for each renovation job in target housing or a child-occupied facility. This is the logical person to organize and maintain on-the-job records during the work. On the jobsite, the records should be kept in a safe, secure, clean and dry place. Once the project is complete, some records can be filed with other firm records while others may need to be moved to the next job site.
Records to be maintained on site include:
Copies of the Certified Renovator's initial and most recent refresher course completion certificates.
Copies of the Certified Renovator's initial and most recent refresher course completion certificates.
Non-certified worker training documentation.
Designation of a Certified Renovator to the job.
Information on and results of use of EPA-recognized test kits or paint chip samples by a Certified Renovator who acted as the representative of 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.
Proof of owner/occupant pre-renovation education
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.
All reports required from the Certified Firm and the Certified Renovator by the EPA RRP Rule.
Recordkeeping: Pre-Renovation Education Records
In Target Housing – Individual units: Must acquire either written proof of receipt by an adult occupant or proof of delivery/unsuccessful delivery of Renovate Right, or written proof of receipt of Renovate Right by owner or proof of mailing (if mailing, send 7 days prior to renovation).
In Target Housing - Common Areas (Two Options): Provide written notification to each affected unit and make Renovate Right pamphlet available on request; or keep copies or pictures of the signs and notices posted.
In Child-Occupied Facilities: Written proof of receipt of Renovate Right by owner or proof of mailing required (If mailing, send 7 days prior to renovation).
Maintain proof of receipt by owner or adult representative, or certify in writing that the Renovate Right pamphlet has been delivered to facility. Keep copies or pictures of the signs and notices posted.
In addition to the requirements above, maintain all records for pre-renovation education activities that contain information about the following:
When contacts with the owner and occupants were attempted.
Written proof of when contacts were made.
What notices were posted, and when and where they were posted.
Whether and when contact was made with the owner or adult representative of any child-occupied facility.
Renovate Right Booklet & Confirmation of Receipt of Renovate Right
Recordkeeping: Non-Certified Worker Training
The Certified Renovator who conducted the non-certified worker training must document the information taught to, and skill set proficiencies achieved by, each individual trainee. This training can be conducted in a classroom setting with simulated hands-on or on the job. Documentation may vary for each trainee as not all trainees may be assigned to conduct all lead-safe work practices and the training is only required to be task specific.
Worker’s name.
Description of lead safe work practices the worker is trained to perform.
Completed and signed skills evaluation checklists.
Date(s) of training.
Name and signature of the Certified Renovator who conducted the training.
Recordkeeping: Test Kit Reporting
If an EPA-recognized test kit is used to test surfaces in the work area, the firm must:
Submit a report to the person contracting for the work within 30 days after the end of the renovation, containing:
Manufacturer and model of the EPA-recognized test kit.
A description of the components tested.
The location of components tested.
Results of the testing.
Retain a copy of the test kit documentation form.
Each component to be renovated or impacted by renovation must be tested. If all surfaces are found to be free of lead-based paint, the RRP Rule does not apply. If a set of affected components make up an integrated whole (such as a stair tread or riser within a single staircase; or, a window casing, apron, stool, header or trough in a window case system), then only one of the individual components from that set needs to be tested.
When test kits are used, within 30 days of completing the renovation, the Certified Renovation firm must provide information on test kit manufacturers and models used for testing, a description of components tested including locations, and the results of testing, to the client who contracted for the renovation. Retain a copy of the test kit documentation form.
Recordkeeping: Paint Chip Sample Results Reporting
Paint chip sampling records must be maintained similarly to test kit results:
Submit a report to the person contracting for the work within 30 days after the end of the renovation, containing:
Description and location of the components tested
Dimensions of the area sampled, in cm and area in cm2
Laboratory analysis results
Retain a copy of lab results and client report
Certified renovators may collect paint chip samples from components to be affected by renovation instead of using test kits to test the paint. The samples must be sent to an entity recognized by the National Lead Laboratory Accreditation Program (NLLAP) for analysis. Prepare reports for clients and maintain records similar to that detailed for the test kit results. Submit a report within 30 days to the person contracting for the work detailed locations sampled, dimensions, and associated results. Retain copies of the laboratory results and the client report for 3 years.
Recordkeeping: Post-Renovation Reporting
Following a renovation, firms must document and share the following information:
Project information documenting compliance with renovation training, certification, and work practice requirements.
If performed, documentation of dust clearance sampling.
This information must be prepared, retained by the firm and shared with owners and occupants of housing and child-occupied facilities.
Documentation of project information (compliance with renovation training, certification, and work practice requirements). This can accomplished by completing the sample form titled “Sample Renovation Recordkeeping Checklist”, or a similar form. The project information documentation must also be distributed when the final invoice is delivered or within 30 days of the completion, whichever is earlier, to the following :
The owner of the building; and, if different,
An adult occupant, or an adult representative of the child-occupied facility.
If dust clearance sampling is performed the firm must provide, when the final invoice for the renovation is delivered or within 30 days of the completion of the renovation, whichever is earlier, a copy of the dust sampling report to:
The owner of the building; and, if different,
An adult occupant, or an adult representative of a child-occupied facility.
Note: When work is done in common areas of multi-unit housing, firms must post project information and dust sampling reports on how interested occupants of the housing being renovated can obtain a copy of the report. This information must be posted in areas where they are likely to be seen by all affected occupants.