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Sean wrote a good blog, at the end he also has links to the public comment section for the new changes.

"As we mentioned in the EPA RRP & HomeStar Updates article back on May 6th, there is a new record keeping regulation that goes into effect on July 6th. Per the EPA in Docket RIN 2070–AJ55 aka Lead; Amendment to the Opt-Out and Recordkeeping Provisions in the Renovation, Repair, and Painting Program"

More here......
 

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I greatly respect Sean, but on this particular issue ... I think he may have jumped the gun.

There is no doubt that the EPA wants us to give some records to the homeowners. Where Sean sees that 745.86 (c) will remain and the change (c)(1) will come after it ... I believe that 745.86 (c) will be taken out and in it's place (c)(1) will take its place.

Ultimately this friendly debate will be decided for us, when it is rewritten.

However, to comply with this will only take a few seconds. All you will need to do is make an extra copy of the Recordkeeping Checklist and hand it to the owner/tenant.
 
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