How can a firm comply with the pre-renovation education requirements if the owner desires that the renovation begin immediately?
If the renovation is taking place in an owner-occupied dwelling unit, a firm must simply provide the owner with a copy of the pamphlet, and either (1) obtain, from the owner, a written acknowledgement that the owner has received the pamphlet, or (2) obtain a certificate of mailing at least seven days prior to the renovation.
If the owner does not occupy the dwelling unit (ex. the unit is leased), the firm must also provide an adult occupant with a copy of the pamphlet, and either (1) obtain from the adult occupant a written acknowledgement that the adult occupant has received the pamphlet, or (2) obtain a certificate of mailing at least seven days prior to the renovation. If an adult occupant is unavailable for signing an acknowledgment, a firm may employ the self-certification procedures described in 40 CFR 745.84(a)(2)(i), which require the firm to sign and date a statement attesting to the unavailability of the occupant and to the delivery of the pamphlet to the dwelling.
As a reminder, if the work to be performed is an “emergency renovation,” as defined in 40 CFR 745.82(b), the firm need not comply with the pre-renovation education requirements.