Lead RRP pre-renovation information and recordkeeping study guide
Sections 745.84 and 745.86 of 40 CFR Part 745 Subpart E set out what the firm performing a renovation for compensation in target housing or a child-occupied facility must hand out before work starts, and what it must keep and pass on afterward. The rules differ for dwelling units, common areas of multi-unit target housing and child-occupied facilities, and emergency renovations are exempt from the information distribution requirements but not from the recordkeeping in 745.86(b)(6) and (b)(7). Target housing is defined in 40 CFR 745.103, which this guide does not quote. Your State or Tribe may run its own authorized program, so check its rules too. goraedu is not a training provider and does not certify renovators or firms. Every point links to the regulation and quotes its exact words.
Scope, emergencies and the pamphlet
The information distribution requirements of 745.84 do not apply to emergency renovations: renovation activities that were not planned but result from a sudden, unexpected event.
“The information distribution requirements in § 745.84 do not apply to emergency renovations, which are renovation activities that were not planned but result from a sudden, unexpected event”
Interim controls performed in response to an elevated blood lead level in a resident child are also emergency renovations.
“Interim controls performed in response to an elevated blood lead level in a resident child are also emergency renovations.”
Emergency renovations are not exempt from the cleaning requirements of 745.85(a)(5), the cleaning verification requirements of 745.85(b), or the recordkeeping requirements of 745.86(b)(6) and (b)(7).
“Emergency renovations are not exempt from the cleaning requirements of § 745.85(a)(5), which must be performed by certified renovators or individuals trained in accordance with § 745.90(b)(2), the cleaning verification requirements of § 745.85(b), which must be performed by certified renovators, and the recordkeeping requirements of § 745.86(b)(6) and (b)(7).”
"Pamphlet" means the EPA pamphlet Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools, or any State or Tribal pamphlet approved by EPA under 40 CFR 745.326 that is developed for the same purpose.
“Pamphlet means the EPA pamphlet titled Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools developed under section 406(a) of TSCA for use in complying with section 406(b) of TSCA, or any State or Tribal pamphlet approved by EPA pursuant to 40 CFR 745.326 that is developed for the same purpose.”
The definition includes reproductions of the pamphlet when copied in full and without revision or deletion of material, except for the addition or revision of State or local sources of information.
“This includes reproductions of the pamphlet when copied in full and without revision or deletion of material from the pamphlet (except for the addition or revision of State or local sources of information).”
On or after December 22, 2008, renovators or firms performing renovations in States and Indian Tribal areas without an authorized program must provide owners and occupants the EPA pamphlet Renovate Right.
“On or after December 22, 2008, renovators or firms performing renovations in States and Indian Tribal areas without an authorized program must provide owners and occupants the following EPA pamphlet: Renovate Right: Important Lead Hazard Information for Families, Child Care Providers and Schools.”
Not covered here
The rest of the emergency renovation wording in 745.82(b) (an event that, if not immediately attended to, presents a safety or public health hazard or threatens equipment and/or property with significant damage) is not quoted point by point in this guide. The applicability exceptions in 745.82(a) and the renovation definition in 745.83 are not covered point by point. Target housing is defined in 40 CFR 745.103, which this guide does not quote. We only write what an official source states, so study these parts with your certifying program's materials.
Dwelling units in target housing
For a residential dwelling unit of target housing, the duty falls on the firm performing the renovation, and the window is no more than 60 days before renovation activities begin.
“No more than 60 days before beginning renovation activities in any residential dwelling unit of target housing, the firm performing the renovation must:”
The firm must provide the owner of the unit with the pamphlet and comply with one of the options listed in 745.84(a)(1).
“Provide the owner of the unit with the pamphlet, and comply with one of the following:”
One option is to obtain, from the owner, a written acknowledgment that the owner has received the pamphlet.
“Obtain, from the owner, a written acknowledgment that the owner has received the pamphlet.”
The other option is to obtain a certificate of mailing at least 7 days prior to the renovation.
“Obtain a certificate of mailing at least 7 days prior to the renovation.”
In addition, if the owner does not occupy the dwelling unit, the firm must provide an adult occupant of the unit with the pamphlet and comply with one of the options listed in 745.84(a)(2).
“In addition to the requirements in paragraph (a)(1) of this section, if the owner does not occupy the dwelling unit, provide an adult occupant of the unit with the pamphlet, and comply with one of the following:”
One option for the adult occupant is a written acknowledgment of receipt from that occupant, or a written certification that a pamphlet was delivered to the dwelling and that the firm has been unsuccessful in obtaining a written acknowledgment from an adult occupant.
“Obtain, from the adult occupant, a written acknowledgment that the occupant has received the pamphlet; or certify in writing that a pamphlet has been delivered to the dwelling and that the firm performing the renovation has been unsuccessful in obtaining a written acknowledgment from an adult occupant.”
A certification of attempted delivery must include the unit's address, the date and method of delivery, the names of the persons delivering the pamphlet, the reason for lack of acknowledgment, the signature of a firm representative and the date of signature.
“Such certification must include the address of the unit undergoing renovation, the date and method of delivery of the pamphlet, names of the persons delivering the pamphlet, reason for lack of acknowledgment (e.g., occupant refuses to sign, no adult occupant available), the signature of a representative of the firm performing the renovation, and the date of signature.”
Not covered here
The adult occupant's other option in 745.84(a)(2)(ii) is worded the same as the owner's: obtain a certificate of mailing at least 7 days prior to the renovation. We only write what an official source states, so study these parts with your certifying program's materials.
Common areas of multi-unit target housing
For common areas of multi-unit target housing, the firm performing the renovation must act no more than 60 days before beginning renovation activities.
“No more than 60 days before beginning renovation activities in common areas of multi-unit target housing, the firm performing the renovation must:”
The firm must provide the owner with the pamphlet and comply with one of the options in 745.84(b)(1).
“Provide the owner with the pamphlet, and comply with one of the following:”
The firm must also comply with one of the options in 745.84(b)(2). One option is to notify each affected unit in writing (or ensure written notification) and make the pamphlet available upon request prior to the start of renovation.
“Comply with one of the following. (i) Notify in writing, or ensure written notification of, each affected unit and make the pamphlet available upon request prior to the start of renovation.”
The written notice must describe the general nature and locations of the planned work, the expected starting and ending dates, and how the occupant can obtain the pamphlet and a copy of the records required by 745.86(c) and (d) at no cost.
“The notice shall describe the general nature and locations of the planned renovation activities; the expected starting and ending dates; and a statement of how the occupant can obtain the pamphlet and a copy of the records required by § 745.86(c) and (d), at no cost to the occupants”
The other option is to post informational signs while the renovation is ongoing, describing the general nature and locations of the work and the anticipated completion date, where they are likely to be seen by the occupants of all affected units.
“While the renovation is ongoing, post informational signs describing the general nature and locations of the renovation and the anticipated completion date. These signs must be posted in areas where they are likely to be seen by the occupants of all of the affected units.”
The signs must be accompanied by a posted copy of the pamphlet or information on how occupants can review or obtain a copy of it from the firm at no cost.
“The signs must be accompanied by a posted copy of the pamphlet or information on how interested occupants can review a copy of the pamphlet or obtain a copy from the renovation firm at no cost to occupants.”
The signs must also say how occupants can review or obtain, at no cost, a copy of the records required by 745.86(c) and (d).
“The signs must also include information on how interested occupants can review a copy of the records required by § 745.86(c) and (d) or obtain a copy from the renovation firm at no cost to the occupants.”
The firm must prepare, sign and date a statement describing the steps performed to notify all occupants and to provide the pamphlet.
“Prepare, sign, and date a statement describing the steps performed to notify all occupants of the intended renovation activities and to provide the pamphlet.”
If the scope, locations or expected dates change after the initial notification, and the firm gave written initial notification to each affected unit, it must give further written notification to owners and occupants with revised information.
“If the scope, locations, or expected starting and ending dates of the planned renovation activities change after the initial notification, and the firm provided written initial notification to each affected unit, the firm performing the renovation must provide further written notification to the owners and occupants providing revised information on the ongoing or planned activities.”
That subsequent notification must come before the firm starts work beyond what the original notice described.
“This subsequent notification must be provided before the firm performing the renovation initiates work beyond that which was described in the original notice.”
Not covered here
The owner's pamphlet duty for common areas (745.84(b)(1)) uses the same two options as for dwelling units: the owner's written acknowledgment or a certificate of mailing at least 7 days prior to the renovation. We only write what an official source states, so study these parts with your certifying program's materials.
Child-occupied facilities
A child-occupied facility is a building, or portion of a building, constructed prior to 1978, visited regularly by the same child under 6 on at least two different days within any week, with each day's visit lasting at least 3 hours, combined weekly visits at least 6 hours and combined annual visits at least 60 hours.
“Child-occupied facility means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, under 6 years of age, on at least two different days within any week (Sunday through Saturday period), provided that each day's visit lasts at least 3 hours and the combined weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.”
Child-occupied facilities may include day care centers, preschools and kindergarten classrooms, and may be located in target housing or in public or commercial buildings.
“Child-occupied facilities may include, but are not limited to, day care centers, preschools and kindergarten classrooms. Child-occupied facilities may be located in target housing or in public or commercial buildings.”
For common areas in public or commercial buildings that contain child-occupied facilities, the facility covers only common areas routinely used by children under 6 (such as restrooms and cafeterias); common areas they only pass through (such as hallways, stairways and garages) are not included.
“areas in public or commercial buildings that contain child-occupied facilities, the child-occupied facility encompasses only those common areas that are routinely used by children under age 6, such as restrooms and cafeterias. Common areas that children under age 6 only pass through, such as hallways, stairways, and garages are not included.”
For a child-occupied facility, the firm performing the renovation must act no more than 60 days before beginning renovation activities.
“No more than 60 days before beginning renovation activities in any child-occupied facility, the firm performing the renovation must:”
The firm must provide the owner of the building with the pamphlet and comply with one of the options in 745.84(c)(1)(i).
“Provide the owner of the building with the pamphlet, and comply with one of the following:”
If the child-occupied facility is not the owner of the building, the firm must also provide an adult representative of the facility with the pamphlet and comply with one of the options in 745.84(c)(1)(ii).
“If the child-occupied facility is not the owner of the building, provide an adult representative of the child-occupied facility with the pamphlet, and comply with one of the following:”
One option for the adult representative is a written acknowledgment of receipt from the representative, or a written certification that a pamphlet was delivered to the facility and that the firm has been unsuccessful in obtaining a written acknowledgment from an adult representative.
“Obtain, from the adult representative, a written acknowledgment that the adult representative has received the pamphlet; or certify in writing that a pamphlet has been delivered to the facility and that the firm performing the renovation has been unsuccessful in obtaining a written acknowledgment from an adult representative.”
Parents and guardians of children using the facility must get the pamphlet, a description of the general nature and locations of the renovation and the anticipated completion date, and information on how to review or obtain the 745.86(c) and (d) records at no cost, through one of the options in 745.84(c)(2).
“Provide the parents and guardians of children using the child-occupied facility with the pamphlet, information describing the general nature and locations of the renovation and the anticipated completion date, and information on how interested parents or guardians of children frequenting the child-occupied facility can review a copy of the records required by § 745.86(c) and (d) or obtain a copy from the renovation firm at no cost to the occupants by complying with one of the following:”
One option is to mail or hand-deliver the pamphlet and the renovation information to each parent or guardian of a child using the facility.
“Mail or hand-deliver the pamphlet and the renovation information to each parent or guardian of a child using the child-occupied facility.”
The renovation firm must prepare, sign and date a statement describing the steps performed to notify all parents and guardians and to provide the pamphlet.
“The renovation firm must prepare, sign, and date a statement describing the steps performed to notify all parents and guardians of the intended renovation activities and to provide the pamphlet.”
Not covered here
The owner's options in 745.84(c)(1)(i) and the adult representative's other option in (c)(1)(ii)(B) are worded as for dwelling units (the owner's written acknowledgment, or a certificate of mailing at least 7 days prior to the renovation). The other option for parents and guardians (745.84(c)(2)(ii)) is to post informational signs while the renovation is ongoing where parents or guardians can see them, with a posted copy of the pamphlet or information on how to review or obtain one, and information on how to review or obtain the 745.86(c) and (d) records, at no cost. The exterior limit of the definition for public or commercial buildings is not covered point by point. We only write what an official source states, so study these parts with your certifying program's materials.
Written acknowledgments
A written acknowledgment must record the owner's or occupant's name and acknowledge receipt of the pamphlet before the renovation starts, and give the unit's address, the signature of the owner or occupant as applicable, and the date of signature.
“Include a statement recording the owner or occupant's name and acknowledging receipt of the pamphlet prior to the start of renovation, the address of the unit undergoing renovation, the signature of the owner or occupant as applicable, and the date of signature.”
The acknowledgment must be either a separate sheet or part of any written contract or service agreement for the renovation.
“Be either a separate sheet or part of any written contract or service agreement for the renovation.”
It must be in the same language as the renovation contract or agreement or, for non-owner occupied target housing, the same language as the lease or rental agreement or the pamphlet.
“Be written in the same language as the text of the contract or agreement for the renovation or, in the case of non-owner occupied target housing, in the same language as the lease or rental agreement or the pamphlet.”
Records firms must keep
Firms performing renovations must retain all records necessary to demonstrate compliance with Subpart E for 3 years following completion of the renovation and, if requested, make them available to EPA.
“Firms performing renovations must retain and, if requested, make available to EPA all records necessary to demonstrate compliance with this subpart for a period of 3 years following completion of the renovation.”
The 3-year retention does not supersede longer obligations for the same documentation under other provisions, including applicable State or Tribal laws or regulations.
“This 3-year retention requirement does not supersede longer obligations required by other provisions for retaining the same documentation, including any applicable State or Tribal laws or regulations.”
Retained records include (where applicable) records or reports certifying a determination that lead-based paint was not present on the components affected, as described in 745.82(a).
“Records that must be retained pursuant to paragraph (a) of this section shall include (where applicable): (1) Records or reports certifying that a determination had been made that lead-based paint was not present on the components affected by the renovation, as described in § 745.82(a).”
Test kit records prepared by a certified renovator must identify the manufacturer and model of any kits used, describe the components tested and their locations, and give the result of each kit.
“Records prepared by a certified renovator after using EPA-recognized test kits, including an identification of the manufacturer and model of any test kits used, a description of the components that were tested including their locations, and the result of each test kit used.”
Retained records include signed and dated acknowledgments of receipt as described in 745.84(a)(1)(i), (a)(2)(i), (b)(1)(i), (c)(1)(i)(A) and (c)(1)(ii)(A).
“Signed and dated acknowledgments of receipt as described in § 745.84(a)(1)(i), (a)(2)(i), (b)(1)(i), (c)(1)(i)(A), and (c)(1)(ii)(A).”
Retained records include certificates of mailing.
“Certificates of mailing as described in § 745.84(a)(1)(ii), (a)(2)(ii), (b)(1)(ii), (c)(1)(i)(B), and (c)(1)(ii)(B).”
Retained records include records of notification activities for common area renovations and renovations in child-occupied facilities.
“Records of notification activities performed regarding common area renovations, as described in § 745.84(b)(3) and (b)(4), and renovations in child-occupied facilities, as described in § 745.84(c)(2).”
On or after July 6, 2010, renovations in target housing or child-occupied facilities must follow the 745.85 work practice standards and the associated recordkeeping in 745.86(b)(1) and (b)(6), unless the renovation qualifies for the exception in 745.82(a).
“On or after July 6, 2010, all renovations must be performed in accordance with the work practice standards in § 745.85 and the associated recordkeeping requirements in § 745.86(b)(1) and (b)(6) in target housing or child-occupied facilities, unless the renovation qualifies for the exception identified in § 745.82(a).”
Not covered here
The inspector and risk assessor reports in 745.86(b)(1)(i), the paint chip sample records in 745.86(b)(1)(iii) and the certifications of attempted delivery in 745.86(b)(3) are not covered point by point. We only write what an official source states, so study these parts with your certifying program's materials.
Documentation of work practice compliance
Retained records include documentation that a certified renovator was assigned to the project, provided on-the-job training for workers, performed or directed workers who performed all 745.85(a) tasks, and performed the 745.85(b) post-renovation cleaning verification.
“Documentation of compliance with the requirements of § 745.85, including documentation that a certified renovator was assigned to the project, that the certified renovator provided on-the-job training for workers used on the project, that the certified renovator performed or directed workers who performed all of the tasks described in § 745.85(a), and that the certified renovator performed the post-renovation cleaning verification described in § 745.85(b).”
If the firm was unable to comply with all requirements due to an emergency as defined in 745.82, it must document the nature of the emergency and the provisions that were not followed.
“If the renovation firm was unable to comply with all of the requirements of this rule due to an emergency as defined in § 745.82, the firm must document the nature of the emergency and the provisions of the rule that were not followed.”
The documentation must include a copy of the certified renovator's training certificate and a certification by the certified renovator assigned to the project covering the listed items.
“This documentation must include a copy of the certified renovator's training certificate, and a certification by the certified renovator assigned to the project that:”
The certified renovator certifies that training was provided to workers, with topics identified for each worker.
“Training was provided to workers (topics must be identified for each worker).”
The certified renovator certifies that waste was contained on-site and while being transported off-site.
“Waste was contained on-site and while being transported off-site.”
The certified renovator certifies that he or she performed the post-renovation cleaning verification, with the results briefly described, including the number of wet and dry cloths used.
“The certified renovator performed the post-renovation cleaning verification (the results of which must be briefly described, including the number of wet and dry cloths used).”
Not covered here
The warning sign item in 745.86(b)(6)(ii), the test kit and paint chip items in (b)(6)(iii) and (iv), and the full list of containment and cleaning items in (b)(6)(v) and (vii) are not set out point by point. We only write what an official source states, so study these parts with your certifying program's materials.
Providing records after the renovation
The renovation firm must provide compliance information when the final invoice is delivered or within 30 days of completion, whichever is earlier.
“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 pertaining to compliance with this subpart to the following persons:”
It goes to the owner of the building and, if different, an adult occupant of the residential dwelling (for a dwelling) or an adult representative of the child-occupied facility (for a child-occupied facility).
“The owner of the building; and, if different, (ii) An adult occupant of the residential dwelling, if the renovation took place within a residential dwelling, or an adult representative of the child-occupied facility, if the renovation took place within a child-occupied facility.”
For common areas of multi-unit target housing, firms must post the information or instructions on how to obtain a copy, in areas likely to be seen by the occupants of all affected units.
“When performing renovations in common areas of multi-unit target housing, renovation firms must post the information required by this subpart or instructions on how interested occupants can obtain a copy of this information. This information must be posted in areas where it is likely to be seen by the occupants of all of the affected units.”
The information may be provided on the "Sample Renovation Recordkeeping Checklist" or a similar form containing the 745.86(b)(1)(ii) test kit information and the 745.86(b)(6) training and work practice compliance information.
“The information required to be provided by paragraph (c) of this section may be provided by completing the sample form titled “Sample Renovation Recordkeeping Checklist” or a similar form containing the test kit information required by § 745.86(b)(1)(ii) and the training and work practice compliance information required by § 745.86(b)(6).”
If dust clearance sampling is performed in lieu of cleaning verification as permitted by 745.85(c), the firm must provide a copy of the dust sampling report on the same timing (final invoice or within 30 days of completion, whichever is earlier).
“If dust clearance sampling is performed in lieu of cleaning verification as permitted by § 745.85(c), the renovation firm must provide, when the final invoice for the renovation is delivered or within 30 days of the completion of the renovation, whichever is earlier, a copy of the dust sampling report to:”
Not covered here
For common areas of multi-unit target housing, 745.86(d)(3) requires firms to post the dust sampling reports or information on how interested occupants can obtain a copy, in areas where they are likely to be seen by the occupants of all affected units. We only write what an official source states, so study these parts with your certifying program's materials.
Sources
- eCFR: 40 CFR 745.82, Applicability (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.83, Definitions (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.81, Effective dates (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.84, Information distribution requirements (as of Nov 4, 2026)Checked November 6, 2026
- eCFR: 40 CFR 745.86, Recordkeeping and reporting requirements (as of Nov 4, 2026)Checked November 6, 2026
Other EPA Lead RRP study guides: Scope and definitions, Firm and renovator certification and training, Work practice standards, Cleaning verification and dust clearance, Lead hazard standards and abatement basics