EPA RRP records for contractors: what to keep on every pre-1978 job

1. Before work: the pamphlet

No more than 60 days before work, give the owner EPA’s Renovate Right pamphlet and get a written acknowledgment — or get a certificate of mailing at least 7 days before work. If the owner doesn’t live in the unit, also give it to an adult occupant and get their acknowledgment, or sign a certification of attempted delivery. Common areas need written notice to each affected unit or posted signs, plus a signed statement of what you did (745.84).

2. If you tested for lead

Keep the test kit manufacturer and model, the components tested, locations and results, or the paint chip lab results (745.86(b)(1)). Results below 1.0 mg/cm² or 0.5% by weight mean the component isn’t regulated lead-based paint (745.82).

3. The certified renovator’s job record

Proof a certified renovator was assigned (with a copy of their training certificate) and their signed certification that workers were trained (topics per worker), signs were posted, the work area was contained, waste was contained, the area was cleaned, and cleaning verification was done — including how many wet and dry cloths were used (745.86(b)(6)).

4. After work: give the owner and occupant a copy

At the final invoice or within 30 days of completion — whichever is earlier — give the owner (and the adult occupant, if different) the compliance information. EPA’s “Sample Renovation Recordkeeping Checklist” or a similar form is allowed (745.86(c)).

5. Keep your certifications current

Firm certification lasts 5 years; apply to recertify at least 90 days before it expires to be timely (745.89). Renovators must refresh before their certification expires and keep copies of their certificates on site (745.90).

Before work (no more than 60 days before)

• ☐ Gave the owner EPA’s Renovate Right pamphlet and got a signed acknowledgment, or a certificate of mailing at least 7 days before work (745.84(a)).
• ☐ If the owner doesn’t live there: also gave the pamphlet to an adult occupant and got a signed acknowledgment — or a signed certification of attempted delivery (address, delivery date and method, who delivered it, why no signature).
• ☐ Common areas: written notice to every affected unit or posted signs, plus a signed, dated statement of the steps taken.
• ☐ If you tested: test kit maker and model, components tested, locations and results — or paint chip lab results (NLLAP-recognized lab).

During the job

• ☐ A certified renovator was assigned; a copy of their training certificate is in the job file (745.86(b)(6)).
• ☐ On-the-job training for each worker, with the topics listed per worker.
• ☐ Warning signs posted at entrances to the work area.
• ☐ Containment as required (objects, HVAC, windows/doors, floor or ground covering) and waste contained on-site and in transport.

After the job

• ☐ Cleaning done; the certified renovator performed cleaning verification, with the number of wet and dry cloths recorded (or a dust clearance report).
• ☐ Compliance info given to the owner and adult occupant at final invoice or within 30 days of completion, whichever is earlier (745.86(c)).
• ☐ Whole job file kept for 3 years after the job is completed.

Print this checklist Download PDF

Free, no email needed. Our summary of 40 CFR 745.84–745.86, not an official EPA form.