During our webinar last week, we posed a question to the audience about RRP recordkeeping and if they were adding notes (narratives) to their RRP forms.
Although quite unscientific, our quick online survey showed 40% of the audience was not adding notes to their RRP forms.
It's no surprise, as many contractors have commented to us there is no emphasis put on this aspect of RRP work in the training classes they took to obtain Lead-Safe certification. It is one reason why we focused our last webinar on this subject and featured a spokesperson from the EPA to provide some solid guidelines. (If you missed the webinar, you can download it from our website under the "features" tab).
Why is this so important? Because it is perhaps the only way you can document and show you followed proper procedures if you are ever questioned on your compliance.
According to our featured speaker, Marc Edmonds from the EPA, you should be adding narration to your forms to make sure the compliant work you performed is communicated clearly to anyone reading the forms. You can see why it is not enough to merely check off a box on a form. He especially pointed out the steps of lead-testing and cleaning verification as areas where narration was particularly needed for proper recordkeeping.
When testing for the presence of lead paint, Edmonds emphasized that you need to record the manufacture and model of the test kit you used, a description of the room components you tested (including the locations), and the results.
He pointed out that narration does not need to be lengthy, but it should be written so an individual who was not there during the testing can easily understand what was done. For example, noting that testing was done "on the north and east walls and the north window sill" provides a better description than "we tested walls and windows." He suggested perhaps a few sentences per room to provide a good picture of what areas were tested, but added that short, descriptive phrases were fine, as well.
Edmonds also discussed some pointers on recording the cleaning verification phase such as making sure you record how many wet and dry cloths were used during verification.