Did you know? Most RRP fines from the EPA are due to improper paperwork and not following the basic guidelines? Failure to comply could result in fines of up to the statutory maximum of $37,500 per violation per day.
This is the #1 violation. You must keep all records for all work you have performed, records for all certified workers and proof they were certified during the job, proof they were the ones on the job, proof of compliance, and post-renovation cleaning verifications. Take pictures, get signatures, document, document, document!2. Failure to comply with work practice standards.
This is very specific information that covers a wide-range of work practices. Including, but not limited to:
* Use of machines designed to remove paint or other surface
coatings through high speed operation without a HEPA
* Failure to contain waste from renovation activities.
* Failure to contain work area, including windows and doors.
* Failure to contain lead dust.
3. Failure to comply with training requirements.
You must obtain a training course completion certificate.4. Failure to provide the lead hazard information pamphlet, Renovate Right, to the property owner.
Document this! Obtain a signature, take a picture of yourself delivering it to each address, email a copy, and retain this documentation for 3 years.
5. Failure to obtain firm certification.
These are simple applications to the EPA and State.
6. Failure to ensure trained individuals performed the renovation.
7. Failure to post signs.
You must post signs clearly defining the work area and warning occupants not to enter prior to beginning work. Take a picture!
And remember, RRP compliance is an inexpensive solution to an expensive problem.
If you are a contractor or have employees who work on pre-1978 homes and have not taken the RRP certification class or need a refresher course: