CONTRACTOR CHAT: Record-keeping - Coping With and Sounding Off

Now that we've been working with RRP for a while, I think we all may have ideas of how we could streamline some requirements to make our lives a bit easier. When it comes to record-keeping, that seems to be one of the most difficult areas to wrap our arms around.  I found the EPA checklist was a start, but it still didn't quite give me the guidance I needed. Here’s a great source -  LeadCheck provides a packet for job organization, and follow-through with records.  It includes: 1. Pre-Renovation Education and Notification 2. LeadCheck Test Kit documentation Form 3. Non-Certified Workers Training Form 4. Lead Safe Work Practices Check List 5. Cleaning Verification Form What's neat about this on-line resource is you can download it and have a handy nine-page packet for each job that easily organizes all your documentation.  It also gives you a visual cue for which documents need to be provided to the owner. But let's talk about the opportunity to provide feedback to the EPA about how to reduce the paperwork with RRP.  Last week we wrote about how you can submit your comments about the RRP paperwork for consideration. Here's my thoughts: When it comes to real-world use of these forms and how to streamline documentation, the first thing that comes to mind is releasing contractors from the new requirement that indicates "narration," or adding extra notes to fully explain how compliance has been fulfilled, is necessary. (See Federal Register, May  6, 2010) I find this extra step to be extremely burdensome and time consuming.  The other area I find unnecessary is keeping the proof of valid certification on-site.  It just adds an additional item on our checklist of job items.  I would say further that requiring certified staff to carry cards for proof is unnecessary too—if the job is visited by an official, couldn’t that be verified by other means?  The point, again, is to risk the hazards of lead dust—not to make it unbelievably complicated and bureaucratic. Actually keeping a wipe-down as proof of the job coming out clean?  That’s really going too far, isn’t it?  We welcome other ideas on where record-keeping could be trimmed and encourage you to submit your thoughts to the EPA before the deadline of March 28, 2011.