If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers.
All renovation firms involved in a project share the responsibility for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. That does not mean that all of the firms involved in a project must retain a copy of the records. The records may be held by only one of the firms. However, firms that choose not to hold copies of the records, but rather to rely on other contractors involved in the renovation (e.g., subcontractors) to do that, must be able to access the records and make them available in a timely manner when requested by the EPA.