New RRP Amendment Requires Providing Documentation to Homeowners and/or Occupants
This final rule requires that, when the final invoice for the renovation is delivered, or within 30 days of the completion of the renovation, whichever is earlier, the renovation firm must provide information demonstrating compliance with the training and work practice requirements of the RRP rule to the owner of the building being renovated and, if different, to the occupants of the renovated housing or the operator of the child-occupied facility. The Sample Renovation Checklist, http://www.epa.gov/lead/pubs/samplechecklist.pdf can be used for this purpose.
For renovations in common areas of target housing, the renovation firm must provide the occupants of the affected housing units instructions on how to review or obtain this information from the renovation firm at no charge to the occupant. These instructions must be included in the notice provided to each affected unit under 40 CFR 745.84((2(i) or on the signs posted in the common areas under 40 CFR 745.84(b)(2)(ii).
Under this final rule, the renovation firm is required to provide interested parents or guardians of children using the child-occupied facility instructions on how to review or obtain a copy of these records at no cost to the parents or guardians. This could be accomplished by mailing or hand delivering these instructions, or by including them on the signs posted under 40 CFR 745.84(c)(2)(ii).
Andrea Goldman is a litigation attorney who focuses on construction and business law. Ms. Goldman has been a mediator since 1996 and is an arbitrator on the panels of the American Arbitration Association, Massachusetts Home Improvement Contractor Arbitration Program, National Arbitration Forum and the National Association of Securities Dealers, Inc. In addition, she is fluent in both Spanish and French and has helped international clients. Andrea Goldman can be reached at firstname.lastname@example.org. Follow me on Twitter @AndreaGoldman. Please contact Andrea to review your construction contracts and add lead-paint clauses, to help with resolving a dispute, or provide representation in the construction industry.