Frequent Questions About Renovator Certification & Training Under the RRP Rule

Certified Renovator Responsibilities

Is the certified renovator assigned to a specific project responsible for the work practices of other contractors on the project if the certified renovator is an employee of the general contractor of the project?

All firms performing renovations must ensure that all individuals performing renovation activities on behalf of the firm are either certified renovators or have been trained by a certified renovator. A firm acting as a general contractor may satisfy this requirement by hiring another certified firm that takes responsibility for ensuring that all individuals performing the renovation activities are either certified renovators or have been trained by a certified renovator. With respect to assigning a certified renovator who is responsible for any on-the-job training and regularly directing workers who are not certified renovators, a firm acting as a general contractor may satisfy this requirement by hiring another certified firm that in turn assigns a certified renovator to the job. However, this does not discharge the general contractor's liability to ensure compliance with the RRP Rule.

Question Number: 23002-19182

What about a situation where the homeowner is acting as their own general contractor and hires multiple companies to do different portions of the work? In this situation, would each business participating be required to follow the rules and assign a separate certified renovator to supervise their portion of the work including separate containment?

While the homeowner may be performing the role of general contractor by hiring firms and organizing their work, the homeowner is not performing, offering or claiming to perform a renovation and therefore does not need to be a certified firm. The firms hired by the homeowner to perform renovation tasks are responsible for complying with all aspects of the RRP Rule that are applicable to their work, including firm certification. The RRP Rule does not prohibit firms from reaching agreement on which will supply the certified renovator who is responsible for ensuring compliance with the RRP Rule and who directs and trains non-certified workers. However, all firms share liability for ensuring compliance with the RRP Rule.

Question Number: 23002-20939

Getting Certified as a Renovator

How can I find an accredited renovation trainer?

You can locate an accredited training provider using EPA’s Accredited Lead-based Paint Trainer Search tool or by contacting the National Lead Information Center at 1-800-424-LEAD (5323).

Question Number: 23002-16220

Can renovator training courses, both initial and refresher courses, be taught online or via distance learning?

The RRP Rule, like the Lead-Based Paint Activities program, permits the use of alternative training techniques (e.g., video training, computer-based training) as a supplement to the hands-on skills assessment, or as a substitute for the lecture portion of the training course requirements outlined in 40 CFR 745.225.

In addition, 40 CFR 745.225 of the final rule requires all training programs, including those using alternative training methods, to meet the minimum hourly requirements for hands-on activities in their training courses. Under 40 CFR 745.225, all training programs are also required to administer a course test and conduct a hands-on skills assessment.

To ensure the quality of such alternative programs, the final rule requires training providers who opt to use alternative techniques to submit all materials as specified in 40 CFR 745.225 as a part of their application for accreditation. These materials include copies of the course agenda, and student and instructor manuals.

The accreditation of alternative training programs will be based on EPA's review of the training materials submitted under 40 CFR 745.225, including the course agenda and manuals. In its review, the Agency will consider on a case-by-case basis the provisions made by a training program to ensure the quality of its course materials. Based on that review, the Agency may accredit programs offering alternative training and instructional methods.

Question Number: 23002-14757

I am a renovator, and I want to comply with the RRP Rule. What do I need to do?

EPA’s RRP Rule sets up requirements for firms and individuals performing renovations in pre-1978 housing and child-occupied facilities, such as schools and daycares.

Firms must be EPA certified. To become EPA certified, renovation contractors must submit an application and fee payment to EPA. Once certified, the firm will be able to advertise that they are certified by EPA under the RRP Program, and will also be given rights to use EPA’s Lead-Safe Certified Firm Logo.
Renovations covered by the rule must be performed or directed by a certified renovator. Individuals can become a lead-safe certified renovator by successfully completing a one-day training course in lead-safe work practices. The training courses are offered by EPA-approved private training providers; there is no additional fee to EPA. You can find a training provider in your area by using EPA’s search tool.

Training providers must be accredited to provide the specialized, one-day lead-safe work practices training. Classes teach the specific work practices that contractors need to protect themselves and their clients from lead contamination, and to allow them and their firm to work legally Certification is immediate upon successful completion of the training class.

Question Number: 23002-18001

I am a firm and there are no training providers offering classes near me. What do I do?

Many of the EPA-accredited training providers have indicated to EPA that they are willing to travel to offer training classes. You can find a list of training providers, including those who are willing to travel, by using EPA's search tool.

Question Number: 23002-17981

I am a certified renovator and planning to take a refresher training course soon to keep my certification current. How long will my new certification last?

Renovators who recertify by taking a refresher training course with hands-on training from an accredited training provider will have certification that lasts for a period of five years from the date of training. If the refresher training does not include hands-on training then the certification lasts for a period of three years. Individuals who take the renovator refresher without hands-on training must, for their next refresher course, take a refresher course that includes hands-on training to maintain renovator certification.

Question Number: 23002-35001

Training Requirements for Workers

What training requirements apply to non-certified workers who have previous EPA/HUD lead-safe work practices training or accredited abatement supervisor or worker training?

The RRP Rule requires certified renovators to provide on-the-job training to non-certified workers on the work practices they will be using in performing their assigned tasks. The amount of on-the-job training needed and the topics that need to be covered depend on the knowledge and experience of each worker. On-the-job training for a worker who has successfully completed prior EPA/U.S. Department of Housing and Urban Development (HUD) lead-safe work practices training, accredited abatement supervisor or worker training, or HUD’s Lead Maintenance course training, might not have to cover basic lead-safe work practices information. It likely would need to address project-specific information (such as the worker’s tasks on the job, the operation of new equipment the worker is to use, work area exit locations, and waste disposal locations), as well as any new lead-safe work practices information that was not covered in the worker’s course training and that is pertinent to the worker’s tasks.

The certified renovator is responsible for ensuring compliance with the work practice standards at all renovations to which he or she is assigned. The certified renovator is also responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including the requirement to provide on-the-job training to non-certified workers. The renovation firm must keep records showing what training was provided to workers. It would be advisable for the records to reflect any prior training non-certified workers had taken.

Question Number: 23002-23546

The certified renovator is required to have proof of their certification at the work site. If the certified renovator provides on-the-job training to workers, does there need to be documentation of that training at the work site too?

No. Certified renovators must have with them at the work site copies of their initial course completion certificate and their most recent refresher course completion certificate. Certified renovators are also responsible for providing training to non-certified workers on the work practices they will be using in performing their assigned tasks. The renovation firm must keep records showing what training was provided to workers, but these records need not be available at the work site.

Question Number: 23002-20530

If a remodeling company that is a certified firm uses all contractual workers rather than employees, must each contractual worker be a certified renovator, or can the workers be trained on the job by a certified renovator employed by the firm?

Firms hiring contractual workers may provide the certified renovator that oversees the renovation project and provides on-the-job training to contractual workers and other non-certified workers.

Question Number: 23002-18377

Special Training & Certification Questions

Must a certified lead abatement professional also become trained and certified to do renovation or repair work?

Yes. Because some skills are different (such as cleaning verification), RRP training and certification is required even if someone already has abatement certification.

Question Number: 23002-19615

May I as a training provider issue a certificate without a picture to a trainee who has successfully completed the course but objects to having his or her picture taken (or objects to possessing a photograph of him/herself) on religious grounds?

Yes. Training providers may provide a person who objects to having his or her picture taken because of sincerely held religious beliefs with the equivalent of a certificate without a picture. Specifically, the training provider may provide an “Acknowledgement of Completion” that the person has successfully completed the training (containing all the information that a certificate would except for a picture). EPA recommends that training providers include the phrase “photo exception” in the normal place for a picture. Further, training providers should use special coding when assigning Part 5 of the unique certificate number. See for example, R-I-56789-10-E0025. Part 5 (“E0025” in the example) represents the unique number assigned by the trainer. The number is sequential and will always begin with the letter E. The first number E0001 should be assigned to the first “photo exception” student completing training in a given calendar year. More general information about creating unique identification numbers is included in the Instructions for Accredited Training Providers.

EPA further recommends that training providers document the trainee’s objection by having the trainee sign a statement containing the following: “My refusal to be photographed is grounded upon a sincerely held religious belief. I understand that if challenged, I may be found in noncompliance unless I can demonstrate the sincerity of my religious beliefs.” Training providers should submit a copy of this statement to EPA in lieu of a photograph. For anyone who can demonstrate that his or her refusal to be photographed is grounded upon a sincerely held religious belief this acknowledgement will be treated as the equivalent of a certificate.

Note: Training providers must now use CDX to submit post-training notifications to EPA that contain the above-described numbering protocol.

Question Number: 23002-32128