Where a certified renovator performs paint chip sampling or uses an EPA-recognized lead test kit following the lead test kit manufacturer’s instructions, tests each component affected by the renovation, and determines that the components are free of paint or other surface coatings that contain lead at regulated levels, the renovation can be performed by a non-certified firm and without regard to the work practice standards or record-keeping requirements of the RRP Rule. See 40 CFR 745.82(a)(2).

However, the certified renovator and firm performing the testing are still subject to the recordkeeping requirements of 745.86(b)(1)(ii) and (iii), and 745.86(a) and (c). Specifically, the certified renovator must prepare a record that states the brand of lead test kit used or the name and address of the EPA-recognized laboratory performing the paint chip analysis, a description of the components tested including their location, and results of the tests. The certified renovator’s firm must retain a copy of this record for three years. EPA further recommends that the firm actually performing the renovation also retain a copy of these records to demonstrate that compliance with the RRP Rule was not required.

Question Number: 23002-18220

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