40 CFR §745.86 Every subsection, on every pack — verified, not assumed

The most rigorous §745.86 job file pack a remodeler can have.

RRPClear assembles a documentation-complete RRP Job File Completeness Pack — every required artifact, every missing-item chase, the indexed vault, and the three-year retention calendar — checked against the letter of 40 CFR §745.86 before a specialist releases it.

Every subsection of 40 CFR §745.86Five required artifact categories, gate-checkedPamphlet ack · renovator cert · work-practice docs · cleaning verification · photosSpecialist release on every pack5-business-day SLA
Why files fail

A single missing artifact can trigger a $22k+ penalty.

A remodeler's RRP job file is only as strong as the documentation behind it. Miss a pamphlet acknowledgment, skip the renovator assignment, lose the cleaning verification, or fail to retain records for three years — and an EPA inspection can result in civil penalties of up to $22,263 per violation per day.

Most small firms treat RRP as 'card in the truck.' Job packets live in phone photo rolls, paper pamphlets, and incomplete CRM uploads. The statute has not been read end-to-end since the last certification class. That is exactly where completeness gaps hide.

RRPClear exists to close that gap with a single, exhaustive standard applied identically to every file.

1 of 5
missing artifact categories is enough to jeopardize a file
The benchmark

Measured against the letter of the regulation — subsection by subsection.

We do not summarize the law and hope. Every pack is scored against a versioned rule pack tied to the exact text of 40 CFR §745.86. These are the provisions each pack is held to.

§745.86(a)(1)

Pamphlet acknowledgment

Proof that the EPA lead-safe renovation pamphlet was provided to the owner/occupant before work began — signed receipt or equivalent, present or the pack does not release.

§745.86(a)(2)

Certified renovator assignment

Documentation identifying the certified renovator assigned to the job, including their certification number and date of assignment.

§745.86(a)(3)

Lead determination records

If a lead test was performed, the test kit results or lab report; if no test, a signed statement that the presumption of lead-based paint applies.

§745.86(a)(4)

Work practice documentation

Records showing that work practices complied with §745.85 — containment, waste handling, and prohibited practices — verified by photos or checklists.

§745.86(a)(5)

Cleaning verification

Post-renovation cleaning verification sheet signed by the certified renovator, or dust-clearance test results if performed.

§745.86(b)

Three-year retention

All records retained for at least three years from the date of the renovation. The pack includes a retention calendar and vault link.

How a pack is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A human specialist signs every release. That order is never reversed.

01

Job File Gap Scan

Upload the work order, address, and any existing docs. We return a free completeness read: which §745.86 artifacts you already have, and which are missing.

02

Evidence collection & OCR

As your clerical agent, we OCR pamphlet receipts, renovator certificates, test-kit logs, cleaning verification sheets, and site photos — building an indexed artifact library.

03

Grounded drafting

The job file is assembled from your validated data and the §745.86 rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

All five artifact categories are checked; missing items trigger automated chase messages; the three-year retention date is verified. Any failure blocks release.

05

Specialist release

An RRP documentation specialist reviews the exception queue and signs the release. High-value or multi-state jobs route to attorney review first.

06

Delivery

You receive the pack: scored completeness report, indexed vault link, missing-item chase log, and three-year retention calendar — ready for EPA inspection.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No pack ships without a human signature.
5 days
Standard SLA
From complete intake to released pack.
<1%
Critical-defect target
Tracked against a gold-standard pack library.
5
Artifact categories
Pamphlet · renovator · lead determination · work practices · cleaning verification.
Why RRPClear

Built to be the most thorough option a remodeler has.

Documentation-complete, by design

The deliverable is completeness itself — every required artifact accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run artifact collection as your clerical agent. We never certify field work practices, give legal advice, or perform renovations.

Engagement

Flat fee, per released pack. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a cut of any recovery.

  • A free Job File Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released Job File Completeness Pack; disclosed pass-through search fees.
  • Optional fixed-fee attorney review for multi-state or high-penalty-exposure jobs.
  • Optional Portfolio Monitor Desk for ongoing job file tracking across your entire pipeline.
FAQ

Questions, answered precisely.

Is RRPClear a law firm?
No. RRPClear, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for high-exposure or multi-state jobs.
Do you perform renovations or certify lead-safe work?
Never. RRPClear is not a renovation or abatement contractor and does not perform any field work. The customer's certified renovator remains responsible for all work practices and on-site compliance.
What makes a job file 'complete'?
Completeness is defined by the regulation: the five §745.86(a) artifact categories present, the three-year retention date verified, and all items indexed and chase-logged. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released pack. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released pack, plus disclosed pass-through search costs. No contingency and no percentage of any recovered amount or sale proceeds.

See what's missing before it costs you a penalty.

Start with a free Job File Gap Scan. Send a work order and address and we'll return a completeness read against every subsection of §745.86.

Documentation-completeness service · not legal advice · the customer remains the certified firm.