EPA's Lead Safety RRP Certification Ruling
Do I need EPA’s Lead Safety for Renovating, Repair and Painting (RRP) Training?
If you are a contractor or a sub contractor of ANY trade, and to complete your work you are required to sand, cut, or perform any sort of demolition which can create hazardous lead dust and chips by disturbing lead-based paint, you are required under EPA regulations to have a Renovator Initial certification under Section 402 of TSCA and must follow specific work practices to prevent increasing the risk of lead exposure to occupants of the building and employees of your company. Failure to comply with this regulation may result in fines of $32,500 per offense.
Beginning April 2010 all contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities, federally subsidized housing, and schools built prior to 1978 (or have lead based paint present built after that) must be certified and must follow work practices to prevent lead contamination.
What type of work will be affected by this ruling?
If you are a contractor of any trade (building, plumbing, mechanical, electrical, etc.) and your job, whether it be a renovation or a repair that requires you to disturb lead-based paint, will require this training. This includes, but is not limited to, sanding, cutting, scraping, demolition, renovation, and installation of materials, appliances, or general maintenance of a property.
More specifically, the rules do NOT apply if the work you are performing meets one of the following criteria;
- -Is a lead abatement project
-Consists of minor repairs to maintenance or installations that disturb less than 6 square feet of painted surface per room for interior activities, or less than 20 square feet of painted surface for exterior activities excluding window replacement, demolition, and projects involving prohibited practices.)
- Is in housing that has been determined to be free of lead-based paint either by certified inspectors or risk assessor, or the components being renovated have been determined to be free of lead-based paint by a certified renovator using an EPA recognized test kit.
- Is in a zero-bedroom dwelling (studio apartment, dormitory, etc.)
- Is in housing for elderly or disabled and no children under six years old reside or are expected to reside there.
If any of the conditions above are met (meaning you answered YES) then the RRP program requirements do NOT apply.
All other instances of work, repair, maintenance, demolition, renovation, and painting, RRP certification and program requirements apply.
What if I perform work on a home, school or daycare built prior to 1978, and I do not have this certification?
If you perform work that would require you to have a Lead RRP certification and you fail to obtain that certification prior to starting work, the EPA has the authority to issue fines. The EPA has the authority to seek civil fines of $32,500 per violation and an additional criminal fine of $32,500 plus jail time for knowing and willfully violating the RRP requirements. The EPA may also suspend, revoke or modify a firm’s certification if the Certified Firm or Certified Renovator is found to be in non-compliance.
How Do I Become Certified?
As of April 22, 2010 contractors will be required to obtain this certification by:
- Take training to learn how to practice lead-safe work.
- Training must be from an accredited EPA training provider for renovators under the EPA’s RRP Program.
- If you previously completed an eligible renovation training course you may take a 4-hour refresher course instead of the 8-hour initial course from an approved training provider.
- Submitting an application and fee to the EPA. Click Here to register your firm online.
The EPA has up to 90 days after receiving the completed application required for certification to approve or disapprove the application.
Non Certified Worker Training
As per EPA Lead RRP rules a certified individual and firm will need to document that you have trained non-certified workers in these techniques. You can do your own training, or we have a $40 program that covers all the material that they need to know. At the end, a certificates showing they have completed it is provided online and you can use that as your documented training for non-certified workers. Here is a link to that non-certified worker training online.
Need a form for documentation that was covered in class? It can be found in your training manual but if you've misplaced it, here is a:
Link to Student Manual Lead Safety for Renovation, Repairs & Painting .
Link to the Pre-Renovation Disclosure Form
Link to Renovation Notice - Sample Form
Link to Sample Renovation Recordkeeping Checklist
Paint Chip Sample Collection Guide
Lead Safe Certified Logo Use Guidelines