Frequent Questions About Recordkeeping & Reporting Requirements Under the RRP Rule

If a certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?

The renovation firm is the entity responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The certified renovator is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards.

Certified renovators must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. Certified renovators are also responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned tasks. The renovation firm must keep records showing what training was provided to workers, but these records need not be available at the work site.

Question Number: 23002-18219

What records must a subcontractor keep?

If the certified renovator assigned to the project is assigned by the subcontractor, the certified renovator is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share the responsibility for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. That does not mean that all of the firms involved in a project must retain a copy of the records. The records may be held by only one of the firms. However, firms that choose not to hold copies of the records, but rather to rely on other contractors involved in the renovation (e.g., subcontractors) to do that, must be able to access the records and make them available in a timely manner when requested by the EPA.

Question Number: 23002-32219

I heard new recordkeeping requirements took effect in July 2010. What are they and when did my firm have to start complying with them?

Beginning July 6, 2010, when the final invoice for the renovation is delivered, or within 30 days of the completion of the renovation, whichever is earlier, the renovation firm must provide information demonstrating compliance with the training and work practice requirements of the RRP Rule to the owner of the building being renovated and, if different, to the occupants of the renovated housing or the operator of the child-occupied facility. For renovations in common areas of target housing, the renovation firm must provide the occupants of the affected housing units with instructions on how to review or obtain this information from the renovation firm at no charge to the occupant. These instructions must be included in the pre-renovation education notice provided to each affected unit or on the signs posted in the common areas. Similar requirements apply for renovations in child-occupied facilities. The renovation firm is required to provide interested parents or guardians of children using the child-occupied facility instructions on how to review or obtain a copy of these records at no cost to the parents or guardians. This could be accomplished by mailing or hand delivering these instructions, or by including them on the signs posted as part of pre-renovation education.

Question Number: 23002-18103

If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?

The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers.

All renovation firms involved in a project share the responsibility for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. That does not mean that all of the firms involved in a project must retain a copy of the records. The records may be held by only one of the firms. However, firms that choose not to hold copies of the records, but rather to rely on other contractors involved in the renovation (e.g., subcontractors) to do that, must be able to access the records and make them available in a timely manner when requested by the EPA.

Question Number: 23002-18287

Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?

Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The RRP Rule does not specify the format in which records must be kept.

Question Number: 23002-20760

Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?

Yes. The RRP Rule does not specify the format in which these documents must be kept, but they must be available at the work site. Documents are not available if they cannot be viewed. Certified renovators must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. Certified renovators are also responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned tasks. The renovation firm must keep records showing what training was provided to workers, but these records need not be available at the work site.

Question Number: 23002-20759

Frequent Questions About Recordkeeping & Reporting Requirements Under the RRP Rule

Other Frequent Questions About the RRP Rule

What records must a subcontractor keep?

I heard new recordkeeping requirements took effect in July 2010. What are they and when did my firm have to start complying with them?

If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?

Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?

Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?

Lead

Frequent Questions About Recordkeeping & Reporting Requirements Under the RRP Rule

Other Frequent Questions About the RRP Rule

Related Information

What records must a subcontractor keep?

I heard new recordkeeping requirements took effect in July 2010. What are they and when did my firm have to start complying with them?

If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?

Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?

Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?

Lead