EPA RRP recordkeeping checklist, in plain English
Last reviewed 17 October 2026. This is a summary to help you stay organised, not legal advice. Always check the rule itself (40 CFR Part 745, Subpart E) and your state program.
Short answer: for every paid job that disturbs paint in a pre-1978 home, keep proof of pamphlet delivery, your lead determination, the certified renovator, work practices, worker training and cleaning verification, for 3 years after the job (40 CFR 745.84–86).
Who this applies to
If you are paid to renovate, repair or paint in a home or child-occupied facility (such as a daycare) built before 1978, and the work disturbs painted surfaces, the RRP rule applies unless an exemption fits. Your firm must be certified, and a certified renovator must be assigned to each job.
Fifteen states run their own program instead of EPA (as of Dec 2025): Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont, Washington and Wisconsin. Their rules may differ and may add forms or fees.
How long to keep records
3 years after the renovation is completed (40 CFR 745.86). If EPA asks, you must be able to produce them.
The checklist
- Pamphlet delivery (before work). Give the owner, and an adult occupant if different, the EPA Renovate Right pamphlet no more than 60 days before work starts. Keep a signed acknowledgment, or your self-certification if they refused or were unavailable, or a certificate of mailing (mail at least 7 days before work). Multi-unit common areas and child-occupied facilities have extra notice steps.
- Lead determination. Either presume lead-based paint is present, or keep the results: an EPA-recognized test kit used by a certified renovator, or a report from a certified inspector or risk assessor.
- Certified renovator assigned. Name and certificate number of the renovator, and your firm certification.
- Work practices. Records that the renovator performed or directed: warning signs, containment (interior plastic at least 6 ft beyond the work area; exterior at least 10 ft), closed and covered HVAC, and no prohibited practices (open-flame burning, heat guns at 1100°F or more, power sanding or grinding without a HEPA shroud and vacuum).
- On-the-job training of every uncertified worker on the job.
- Cleaning verification (or dust clearance testing): which surfaces were checked, results, and re-cleaning. If you use dust clearance testing, give the client the report within 30 days or with the final invoice, whichever is earlier.
- Exemptions. If RRP did not apply (for example minor repair of 6 ft² or less per room inside, or 20 ft² or less outside, with no window replacement and no prohibited practices), record why.
EPA publishes a free sample renovation recordkeeping checklist you can use on paper.
Frequently asked questions
How long do contractors have to keep EPA RRP records?
3 years after the renovation is completed (40 CFR 745.86), and you must produce them if EPA asks.
When must the Renovate Right pamphlet be delivered?
No more than 60 days before work starts. If you mail it, mail it at least 7 days before work begins and keep a certificate of mailing.
Which homes does the RRP rule cover?
Paid renovation, repair or painting that disturbs painted surfaces in homes or child-occupied facilities built before 1978, unless an exemption applies.
What counts as minor repair and maintenance under RRP?
Disturbing 6 square feet or less of paint per room inside, or 20 square feet or less outside, with no window replacement and no prohibited practices. Record why the job was exempt.
Which states run their own RRP program?
Fifteen (as of Dec 2025): Alabama, Delaware, Georgia, Iowa, Kansas, Massachusetts, Mississippi, North Carolina, Oklahoma, Oregon, Rhode Island, Utah, Vermont, Washington and Wisconsin.
Does EPA provide a recordkeeping form?
Yes. EPA publishes a free sample renovation recordkeeping checklist. You can use it on paper or keep the same records in an app.
Doing it on your phone
RRP Binder turns this list into a 6-step checklist on your iPhone: signatures on glass, timestamped and GPS-tagged photos, Spanish worker sheets, and one PDF packet per job, archived in the app. It is designed to work offline. See a sample packet or join the free beta.