EPA Adds New Record-Keeping Requirements to Lead Rule

April 27, 2010

In addition to eliminating the opt-out provision, the Environmental Protection Agency has changed the record-keeping requirements associated with its new lead paint rule, according to the National Association of the Remodeling Industry.

NARI sent out an alert today noting that companies doing work covered under the Remodeling, Repair and Painting Rule must give copies of their records within 30 days of the final invoice or completion of the project to the homeowner or resident.  The records to be turned over must demonstrate compliance with the training and work practices of the RRP rule—basically the checklist and the results of any testing, it is explained. 

While the RRP rules took effect on April 22, the changes to record-keeping requirements and the elimination of the opt-out provision take effect 60 days after the final rules are entered into the federal register.

The NARI alert says that EPA also issued a guidance letter to its regional staff saying that no enforcement action should be taken against firms that have applied for firm certification before April 22 and are just waiting for their paperwork. These applications are expected to be processed by June. EPA says it will still enforce rules about work practices and training requirements for these firms.

"This letter makes no mention of firms that apply after April 22 for firm certification, so they are telling their enforcement people to go to work and begin enforcement," NARI states.