EMailing of Renovate Right is Acceptable

Dec. 28, 2010 -

Wondering if there is an easier way to distribute the "Renovate Right" booklet? If your customer has email, you can email a .pdf of the "Renovate Right" brochure if you follow certain guidelines.

According to the EPA, the distribution of the "lead information pamphlet via email is an acceptable means of distributing [it] as long as the requirements of the Electronic Signatures in Global and National Commerce Act are met."

In its explanation, the EPA notes:

The distribution of the lead information pamphlet (40 CFR § 745.83) via e-mail is an acceptable means of distributing the pamphlet as long as the requirements of the Electronic Signatures in Global and National Commerce Act ("Act")  (15 U.S.C. § 7001 et seq.) are met.  The Act requires that the recipient of the pamphlet, among other things, consents electronically to email delivery and in a manner that demonstrates that the recipient can access the information in the form it will be provided.  In addition, the recipient must be allowed to withdraw this consent and be informed of the procedures for withdrawing consent. Further, the recipient must be provided with a statement of the hardware and software requirements for accessing and retaining the pamphlet.

To comply with the Act's requirement of your customer "consenting" to obtain the information electronically, you can email a brief note asking to send the required brochure electronically and for the customer to confirm they have the appropriate Adobe Acrobat software or similar program to open the .pdf document.

In that note, you can explain that you can send a copy in the mail, if they prefer a hard copy. This can act as verification that the customer consents to receiving the document electronically, and they have the proper software to read it, as well as verifying you have offered an alternative means to provide the document.

An electronic signature is defined as a "symbol" attached to or logically associated with a record.  Perhaps the best execution would be a graphic file of the person's signature (.jpg, .pdf, .tif).

Following these guidelines, it would be appropriate to email the "Renovate Right" brochure to your customer, then request the signed last page of the brochure be returned to you one of two ways. 

First, your customer can electronically sign (place a graphic file of his/her signature) on the last page of the "Renovate Right" booklet and email it back to you.  Or, the customer can print off the last page of the booklet, sign it, and fax it to you with a signature.

Make sure you keep all copies of paperwork and documentation for every RRP job you complete.

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