b'40 CFR 745, Part F; 1b: Record Keeping for Renovation Firms Perhaps the biggest regulation compliance task a For example, to document that the work area hasRenovator and Firm will face is the required docu- been contained, the check-off list provided by thementation. Because the EPA cant monitor every job, EPA in their training manuals and on their site has aand because the RRP Rule is less strict than OSHA space to check off that the Work area (was) con-or HUD, compliance fines will be the result of tained to prevent spread of dust and debris. improper education, and improper record keeping. The assumption is if that is checked off, the record While you should make every effort to comply with is proper. No it isnt. the RRP Lead Safe Practices on every job, attention The proper way to do it with narration is more like:to diligent record keeping will probably be the best Work area (was) isolated to prevent dust and way to protect your firm and yourself from fines. debris leaving, including plastic sheeting to confinearea, tack mats to preventing tracking, (and) dualThe specific information required to be provided areentry sheeting for (the) vertical entry waythe training and work practice compliance informa-word-for-word what is in 745, i.e., narration. tion, as well as identifying information on the manu-facturer and model of the test kits used, if any, a Proper record keeping is the most important description of the components that were tested function of a certified Firm and the Certifiedincluding their locations, and the test kit results. Renovator because it will accomplish four useful and important goals:This final rule also requires firms performing 1. Comply with the record keeping renovations to retain documentation of complianceprovision of RRP.with the work practices and other requirements 2. Other than the EPA looking over of the rule. your shoulder while the work is done, it will be The firm must document that a certified renovator the most accurate and unassailable proof that was assigned to the project, that the certifiedthe RRP Rule was followed to the letterprovidingrenovator provided on-the-job training for workers the most effective insulation from fines and otherused on the project, that the certified renovatorregulatory action.performed or directed workers who performed the 3. Creating properly worded tasks required by this final rule, and that thePre-renovation, Renovation, and Post-renovationrenovator performed the post-renovation cleaning forms can be used as worker training forms andverification. This documentation must include a copy cheat sheets (think Cliff Notes).of the certified renovators training certificate.4. Get the homeowner to sign/initial Finally, the documentation must include certification the narration containing form and you will have by the renovator that the work practices were fol- the strongest prevention of future liability claimslowed with narration as applicable. The certification available, and possibly the document that can must include the specific information listed inlower or eliminate additional liability insurance. 745.86(b)(7). The firm must keep this information The pages that follow are the forms you need. for 3 years after the completion of the renovation.Copy them. Laminate them for posting on the job.There are plenty of sample forms available. However Scan them into your computer. Make copies. Leavemost, if not all, are incorrect, or at best incomplete. copies with your customers. Make a set for yourWhy? The phrase in 40 CFR 745: with narration lawyer and your insurance broker. They need to as applicable. see how well organized and thorough you are.Just checking off on a form that you cleaned an Everything you need is in this book, and all thearea, or that you disposed of debris, or that you pro- forms are based on the statutes and examples vided the Renovate Right brochure, etc. is not valid.provided by EPA, OSHA and HUD. AWDI RRP Forms Kit 2002-2014 AWDI, LLC - All Rights Reserved'