Lead EPA Record Keeping Rule

By Robert Robillard on Dealing With Dust


New Lead EPA Rule – Contractors will also need to keep the necessary records:

The new EPA Rule (40 CFR Part 745), commonly referred to as Renovation, Repair and Painting, went into effect on April 22nd, 2010.

If you’re a homeowner having work performed on your home please read this.

The new rule from the EPA (40 CFR Part 745) states that any contractor/renovator who disturbs more than six (6) square feet of painted surface must follow lead safe practices. Renovations affected by the new rule include activities such as sanding, cutting drywall, demolition, etc. Under the new rule, a contractor will need to become a certified renovator, taking a training course from an accredited training provider. Once they are certified, they will need to only work for a certified firm, whether their own company, a property management firm, or another contracting company.

Lead EPA Record Keeping Rule for Contractors:

1.Make sure you get certified with he EPA.

you need to be certified to work or or hire others to do work on homes, schools, or child care facilities built in or prior to 1978, then you need to be.

Contractors will need to be certified renovators, and the companies who hire them (either the employing contracting company, or a company like a property management firm) will need to be a certified firm.

2.To become a certified renovator, you need to take a course (usually one day, around $150 – $450) from a certified training provider. I took mine at my local lumber yard.

3.To become a certified firm, you will need to fill out this form and pay a $300 fee.

4. Purchase HEPA Vacuums, Plastic Sheeting, and cleaning supplies and have these on hand when needed.

5. Train all non certified workers on proper procedures, and the certified renovators will need to prepare how to handle the questions raised by the residents (either homeowners, tenants, employees, etc)

6. Increase and improve on your record keeping . Record keeping is crucial with their EPA and you will need to consider what records you need to maintain, and how you will maintain them.

Necessary records:

  •  Copy of the Certified Firm and Certified Renovator(s) certifications
  •  Non-certified worker training documentation
  •  Designation of Certified Renovator to the job.
  •  Information on and results of use of EPA-recognized test kits provided by Certified
  •  Renovator who acted as a representative on 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 .
  •  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 Certified Renovator by the EPA RRP Rule

EPA’s sample record keeping checklist

Disclosure to the residents

HEPA Vacuum review

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About the author

Robert Robillard

Carpenter / Remodeler / Editor

Rob Robillard is “The Concord Carpenter” Rob is a builder, general contractor, carpenter, woodworker, and editor of Concord Carpenter and ToolBoxBuzz As a General Contractor and carpenter, Rob owns and operates Concord Carpenter LLC. A full-service remodeling and construction company. Rob is a recognized leader in home building best practices and a source for how-to information for building professionals. On this website, Rob covers all aspects of home construction, building science, home improvement, woodworking, remodeling, and some of the best product and tool reviews. Rob is in charge of our Tool and Product Review series - Concord Carpenter Videos where we post all of our tool reviews and video tutorials. Rob approaches remodeling and building construction with a pragmatic and problem-solving approach. He enjoys using his knowledge and experience to help and educate building professionals as well as DIYers on best practices in the construction and remodeling industry. He's a strong advocate for "raising the bar" in the construction trades and promoting the trades to youth. #BeAMentor #Green2Great Craftsmanship, quality, and pride guide his journey on this channel The Concord Carpenter's motto: "Well done is better than well said!" : Read more about Rob

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