When we get to Module 3 in the EPA RRP class, we get right into what happens before you begin work. The whole point of that module is to get you asking the right questions so you can plan the job, and the very first question is a simple one: have you educated the owner and the people who live there?
This is the easiest part of the rule to get right. It is also the easiest part to skip because you are busy, the customer is in a hurry, and a pamphlet feels like paperwork. It is not paperwork. It is the one thing that proves you did your job before the first tool came out.
Three Scenarios, One Pamphlet
Every job you touch that falls under the rule is going to land in one of three buckets:
- Work inside a single-family house, an apartment, or a condo.
- Work in a common area of an apartment building or condo.
- Work in a child-occupied facility.
The Renovate Right pamphlet goes out on all three. What changes is who has to get it, how you get it to them, and how far ahead of the job you have to do it.
Scenario One: Single-Family House, Apartment, or Condo
Get a copy of the Renovate Right pamphlet to the owner, to the management company if there is one, and to whoever lives inside that individual unit. Not one of them. All of them.
On an EPA-regulated project, you can hand deliver the pamphlet the day the job starts, as long as it is in their hands before work begins. If you would rather mail it, send it certified mail seven days prior.
On a HUD-regulated project, the timeline stretches. HUD wants that pamphlet out fifteen days prior, whether you hand deliver it or send it certified mail.
That is the whole rule for scenario one. Owner, management company, resident. Seven days by certified mail on EPA jobs, fifteen days on HUD jobs, or hand deliver before you start. Meet those timelines.
Scenario Two: Common Areas
If you are working in a hallway, a stairwell, a lobby, or any shared space in a multifamily building, the owner and management company still get the pamphlet. But now you have a building full of people who are going to walk past your work area every day, and every one of them has a right to know what you are doing.
There is a template for this. It is a renovation notice, and we walk through filling it out in Module 7. You fill it out once, make a stack of copies, and slide one under the door of every affected unit. Then you post them where people are going to see them.
The notice tells residents that a free copy of the Renovate Right pamphlet is available if they want one. So carry copies. If somebody reaches out and asks for it, you hand it to them. That is the deal.
Scenario Three: Child-Occupied Facilities
This one is different, and I want you to slow down on it.
In a child-occupied facility, the pamphlet goes to the owner, the management company, and whoever actually runs the place. The renovation notices get posted at the front door where the kids get checked in and out, in the bathrooms, and at the water fountains. Anywhere a parent or a staff member is going to stand still for a second.
Then take it one step further. Scan that notice and ask whoever runs the facility to email it to the parents and guardians a few weeks before the job begins. If a parent does not want their kid in the building while you are working, they need enough time to make other arrangements.
Here is why I push this so hard. I have been doing this for a long time, and one thing I have picked up on is that people get a little crazy when it comes to their kids. I have watched two coaches nearly come to blows at a five-year-old basketball game with the score six to two. I have watched moms get into a fist fight at an eleven-year-old baseball game. I have watched four dads get thrown out of a girls’ select soccer tournament before it was over. None of those people were being asked to trust a stranger with lead dust around their children. You are.
Give them the pamphlet. Give them the notice. Give them time. You will never regret over-communicating with parents, and you will absolutely regret under-communicating with them.
One more thing on child-occupied facilities. I know everybody is busy right now. But if you are ever looking for an angle to win one of these jobs, offer to do the work at night, on the weekend, or over a holiday when the facility is empty and it will not affect their revenue. It may not be something you want to do today, but it is a card worth keeping in your pocket.
Prove It
Delivering the pamphlet is half the job. Documenting that you delivered it is the other half.
Get a signed acknowledgment from the owner and the occupant that they received Renovate Right. If you mailed it, keep the certificate of mailing. If you posted notices in a common area or a child-occupied facility, keep a copy of the notice and note where and when you posted it. That documentation goes in the job file with your test kit records and your certified renovator paperwork, and you hold onto all of it for three years. A copy goes to your customer within thirty days of finishing the job, or whenever you send your bill.
I say it in every class and I will say it here: if you did not document it, how are you going to prove you did it?
The Short Version
To properly plan a renovation under the rule, you have to do three things. Educate your owners and residents. Determine whether lead-based paint is present. And figure out which EPA and HUD requirements apply to the work you are about to do.
The Renovate Right pamphlet is the first of those three, and it is the cheapest insurance you will ever carry. Owner, management company, resident. Before you start. Seven days by mail on EPA work, fifteen days on HUD work. Notices under the doors and on the walls in common areas. Notices at the check-in door, the bathrooms, and the water fountains in a child-occupied facility, plus an email to the parents a few weeks ahead.
Then get it signed and put it in the file.
If it has been a while since your last RRP class, or you have new guys on the crew who have never seen the pamphlet, come see us. We run Initial and Refresher classes across more than thirty states, and this is one of the first things we cover.
