Certified Renovator Responsibilities

Overview of Responsibilities

By now you know all construction and remodeling activities covered by the RRP rule must be directed by a Certified Lead Renovator. This is a designation received after completed a lead paint certification course. It is also often referred to as a contractor lead license. Now that we have that covered, the pressing question is, what exactly is this individual responsible for? The EPA has identified several different items that we will cover in detail. This list is displayed for your review in the Lead Renovator Student Manual developed as a joint effort between the EPA and HUD. We will highlight each listed responsibility and break them down to explain each in detail.

It is important to note that if the HUD rules apply to a project you are working, then there may be additional requirements beyond what is established by the EPA.

Direct Lead-Safe Work Practices

It is important for an individual assigned to a project covered by the RRP Rule to know and understand all required work practices. You might think that completing a certification class will provide you with all the information you need. It is true that it should. But 8-hours of lead training for contractors, especially when you’re not used to sitting for an entire day, can be a bit overwhelming. It is truly a lot of information and the only way to really grasp what is required is to review it a time or two before you start your project. After all, the fine the EPA can impose is up to $37,500 per infraction…and that’s per day as well.

So the bottom line here is you best know how to work safely with lead-based paint. You don’t want to second guess yourself in the field when you are leading others. My suggestion would be to have the manual at your fingertips. And if you can, have an electronic manual. As Renovators, you are not expected to know everything, but you should know where to get the information you need as you direct the work on your project. Having an electronic manual on your smart phone, tablet, or laptop will allow you the ability to search and find information quickly.

Train Non-Certified Renovators

Many companies choose to have all employees on the job site trained as certified renovators. It simply removes any liability of the training requirements for these types of projects. And, with training valid for 5 years, it makes sense to many companies. However, your companies can decide to train their own employees. The key words here are “their own employees”. You cannot training sub-contractors or others that are not employees of your company. Once training is provided, these employees are called non-certified renovators.

Training must be conducted by the Certified Renovator and training logs must be completed and maintained. The EPA has put together a relatively effective training manual call the Steps to Lead Safe Renovation, Repair, and Painting. Renovators should use this manual to provide training. If you decide you are going to provide training, I would suggest reviewing your initial training manual and the Steps guide to prepare. After all, it is important for an instructor to know the material before trying to teach it.

Maintain Certificates On-Site

You must maintain training certificates on-site at all times. Just like when you drive a car, you have your license with you. This is very much the same. This type of work requires very specific lead-safe training. If your job site is inspected, you must be able to prove that you and others on the job are properly training. There is no requirement to maintain hard copies of training although it is highly recommended. Per the rule, you are allowed to have electronic copies on your phone, computer or other electronic device.

Please note that you must maintain all lead renovator training certificates for each individual on site. Just what does this mean? The rule has been in effect for several years. Many people have taken the initial training course and have since re-certified with the lead paint refresher course. In cases for these individuals, you must have a copy of both certificates on site.

Inspect for Lead-Based Paint

As a Certified Renovator, you may be asked to test painted and coated surface for lead content. You can certainly presume all surfaces you will disturb have lead paint. If you choose this method, you can simply follow all required work practices. But you can also choose to test the surfaces to prove they do not contain lead paint. If you choose to test, you have two options available to you. The first is using an EPA-recognized test kit. Lead Check and D Lead are only two test kits approved for use. If you decide to use a test kit, be sure to follow the manufacturers recommendations and complete the Test Kit Documentation Form. A second method approved for certified individuals to use is paint chip sampling. Follow the Paint Chip Sample Collection Guide and complete the Paint Chip Sampling Form.

Be On-Site During Required Work Activity

You may be asking yourself, do I have to be on the job site at all times? The answer is no. The EPA has specified when you must be on site. As the responsible individual, you must be on site during setup and cleanup. Just what does this mean? Simply put, you must be on site to begin the project. You must be there to post signs and build the containment. Once the containment is completed and the actual work for which you were hired for is ready to be conducted, you are able to leave the job site. You must be available by phone or pager, yes I said pager, if you are away from the job site. The team you are leading must be able to get in touch with you in the event of an issue.

You must be back on the job site when the project is ready for cleanup. This is when the work your company was hire for has been completed and it’s time to clean up any lead paint dust and debris. The Certified Lead Renovator is required to direct the cleanup and all remaining tasks. After all, you are responsible for assuring a clean and safe space be given back to your client.

Maintain Containment Integrity

Being certified does come with many responsibilities, but this just may be the most critical. You must maintain an effective containment. Just what does this mean? It is simple. You must make sure lead contaminated dust from your work doesn’t get outside your work area and into areas not under construction. Think about it. Have you ever had clients occupy part of a house you are working in. You need to control your dust so it doesn’t get outside your work area.

You need to make certain your lead containment is constructed so it will stay in place. It is just made of plastic and tape so it can easily be ripped, punctured or fall down. Integrity is important, and the integrity of your containment must not be compromised. Another thing to consider is the type of work you are doing. If your containment is structurally sound, but you are seeing dust going beyond your containment, you must extend your containment or modify your work practices. After all, your containment should be a configuration that is meant to control the dust created from the work you are doing.

Conduct Visual Inspection

After the work is completed and cleanup has occurred, you are responsible to visually inspect the work area for any remaining dust or debris. Only the certified individual can make a determination that the cleanup has been properly completed.

Perform Cleaning Verification

After you have visually inspected the work area and found it to be free of dust, you need to verify that it is indeed clean. Again, individuals that are certified can perform the cleaning verification. Simply put, you will use a process to “verify” that the work you and your team did was adequate. It’s really the finishing touch on your project. It verifies that you have cleaned to the requirements set out in the rule. Once passed, you can feel confident that the work area is ready to be released back to the client for safe occupancy.

Prepare and Maintain Required Records

Last, and of course everyone’s favorite, documentation. Did you know The EPA requires you to maintain records for 3 years? Why so long you might be asking? Most inspections are complaint driven. Simply put, someone called the EPA to complain about something they feel went wrong during the project. The EPA may take months before they can investigate any claim brought against you. Therefore, they gave themselves 3 years to dig back into your records. Exciting news, right?

The bottom line is you are required to know what records are required to complete and maintain as part of your lead paint project. I would highly encourage you to view the recordkeeping section to identify the most common types of records required to be kept. I would also recommend you keep a job file together and maintained it in a secure location in the event you are ever asked for your paperwork. I’m guessing you may be getting a little worked up, but I wouldn’t get too worried. If you follow the rule and complete the required paperwork, you should have nothing to worry about.

Still have questions?

Call us any time at (763) 444-5323 and we’ll be happy to help!