RRP Forms: What's Required, What's Not
Organizing RRP Forms by Steps Provides Logical Process
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:
- "Renovate Right" Brochure to owners of Target Housing
- Written notice to each affected unit in Multi-Unit Target Housing or posted informational signs
- 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
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