RRP Forms: What's Required, What's Not

If I told you there are arguably 20-25 forms that might be used to keep records of an RRP job, it might make your eyes glaze over. But, set in a logical sequence, it actually becomes an easy-to-follow process of six steps.

Step One: Education
The basic requirements of pre-education is to deliver lead-paint information to the tenants/owners in the form of:

  1. "Renovate Right" Brochure to owners of Target Housing
  2. Written notice to each affected unit in Multi-Unit Target Housing or posted informational signs
  3. A notice to parents/guardians which includes the "Renovate Right" brochure, or posting signs in child-occupied facilities

In addition, any changes in scope must be delivered before work, and a signed and dated statement of steps performed to notify tenants and/or parents and guardians.

Required Forms:

    • Written Receipt for "Renovate Right" brochure, signed and dated
    • Tenant/parent notification
    • Tenant/parent notification receipt
    • Notice of changes to scope, locations and dates (for multi-unit RRP)
    • Statement of steps performed (for multi-unit RRP)
    • Self-certification form - This certifies the attempt to notify tenant/parent or posting signs and "Renovate Right" brochures in common area.

Step Two: Testing­
The basic RRP requirements call for written documentation of the manufacturer /model of the EPA-recognized test kits used, description and location of components tested, and the testing results.  If a Lead Inspector or Risk Assessor is used, their name, certification number, and results of their testing is required along with a copy of their report.

Required Forms:

  • Test Kit Form with manufacturer/model test kit information
  • Test Result Form showing results for all areas tested

Optional forms:

  • Test Permission Form from occupant to perform the test
  • RRP Surcharge Form to be used to get separate cost approval

Step Three: Pre-RRP Setup
Worker training records are the most common forms for this step, but there are other records that will document your work.  It is during this step that a layout of the job is done, materials are selected, decisions are made about how containment will be handled, (containment or collection, etc.), and other preparation such as posting signs, marking off the area with tape, covering ducts, floors, windows, and vents, etc.

Required Forms:

  • Worker Training Record (for each worker) – This documents workers' lead safe training, application of these practices on the site, and the proper use of all safety equipment and personal protection equipment (if required).

OSHA Required Forms (as applicable):

  • Worker Training Record re: proper use of all safety equipment and personal protection equipment.
  • Respirator Training Records
  • MSDS (Material Safety Data Sheet) documenting the presence of lead
  • Dust Air Content Record and other worker documents if levels exceed PEL (Personal Exposure Levels)

Optional Forms:

  • RRP Exterior Containment Layout
  • RRP Interior Containment Layout

(Shows how the job will be laid out and the containment materials needed and deployed.)

Step Four: RRP Procedures
This step addresses the job specific duties designed to limit dust creation, contain the dust, collect the debris and dispose of the waste. These procedures also direct workers to clean themselves of lead dust each time they leave the work area, and to wash their faces and hands at the end of each shift. It includes vacuuming their work clothes if they don’t wear disposable personal protection, and changing the sheets on the tack pad(s). Daily RRP Procedures require frequent cleaning (even vacuuming) of the work area to limit the buildup, tracking and spreading of the generated dust. It includes bagging and disposing of waste at frequent intervals in the proper onsite storage.

Required Forms

  • Daily Procedure Form - A simple check-off sheet documenting the daily procedures with identification of the work area (room, side of the house, or the like), number of bags and what debris.
  • Worker Sign-out sheet - This is a check-box acknowledgement of the workers' personal cleaning procedures at breaks and at the end of the shift

Step Five: Post RRP Cleanup
When the renovation is complete, the work area needs to cleaned of paint debris and chips. Plastic sheeting is misted, folded properly and bagged. Work areas are vacuumed to two-feet outside the work area. Walls, floors, and carpets are HEPA vacuumed or wiped with damp cloth. If there are uncarpeted floors, they are mopped using two-bucket system that keeps the wash water separate from the rinse water.

Required Forms:

  • Post Renovation Interior Cleanup Form - A simple form, summarizing what clean-up activities are to be completed and a description area for each area to "check-off" completion and provide appropriate narration.
  • Post Renovation Exterior Cleanup Form – Same as above but might include water disposal confirmation and soil cleanup, as well as shrubbery protection or containment removal (if used).

Step Six: Cleaning Verification
Once the RRP work is finished, and the debris is removed, meticulous cleanup is required to be done to assure the area is clean in compliance with RRP. There are a dozen steps, starting with visual inspection, including vacuuming, wiping and ending with cleaning verification or clearance sampling.

Required Forms:

  • Cleaning Verification Form – This can be a simple check box record of the 12 steps for the work area(s), room by room. It confirms use of the clearance comparison card or, in the case of exterior RRP, visual inspection.  The certified renovator and the certified firm verify on this form that the area is clean according to the EPA RRP guidelines.
  • Dust Sampling Records – These records would be supplied by the Dust Sampling Technician, or Lead Inspector with photographs, paper documentation of the sampling and a copy of the Lab report.

Final Report for Permanent Business and Customer Records
The EPA RRP Rule requires that all records be kept for three years, and that a copy of all records documenting the work from initial test to final clearance be given to the homeowner (single family target housing) or to the owner/management company (multi-family target housing, or child occupied facility).

You can use a Job Folder/Repository where all the documents can reside in a single place, either in a file cabinet in the Certified Firm’s place of business (OSHA requires documents to be kept 30 years), or in an off-site record repository such as cloud computing or other software/internet based location accessible by the company, the owner/occupant and the EPA.

It is also important that you use a final form, summarizing all the work completed.  This final form has your signature and the customer’s signature as a final "sign-off" to satisfy not only the EPA, but for your liabilities and insurance requirements.

The Customer Final Completion Form is a paper-based, 4 page document that contains all the required procedures in a check box format that confirms that each has been done as required. These check box statements are in the EPA RRP required narration. The form will contain an area that reconfirms the responsibilities and contains the signature(s) of the contractor and the customer in acceptance that the work was satisfactorily completed as promised and required.

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Editor's Note:  Have questions or need guidance on RRP forms and checklists?  The American Window and Door Institute (AWDI) offers a book, "RRP Business Manual for Certified Firms," that contains information and guidance about RRP forms, or contact John Jervis at AWDI, info@awdi.com.